A few standards will have been added or modified as a result of the CMS Quality Standards, but the emphasis continues to be on the National Patient Safety Goals. Pay attention to these and be prepared to demonstrate to your surveyor how you meet them!
- The newest goal is for oxygen providers. The goal is to reduce the risk of fires in the homes of oxygen patients. Forms staff use for home assessments (both clinicians and drivers) should be modified to document the presence or absence and working order of smoke detectors, fire extinguishers and fire safety plans; as well as review of all medical equipment for fire risks. This set of checks should occur each time a representative from your company is in the patient’s residence.
- Another component of this goal is to provide education to the patient and family regarding causes of fire and fire prevention activities, and to assess the patient’s level of comprehension and compliance and reports any concerns to the patient’s physician.
The following are not new, but continue to be important enough to discuss again:
- Staff who take orders must have access to a list of ‘do not use’ abbreviations that include the minimum abbreviations as specified on JCAHO’s website. While it is true many HME providers never use these abbreviations anyway, you still need to ensure Customer Service and clinicians on staff are aware of the list. These abbreviations are linked with serious accidents in healthcare, and the goal is to wipe them out of usage across the continuum of care, regardless of whether you think it is relevant to your services or not.
- Read-back of a verbal order after writing it down (pertinent to Customer Service and clinicians).
- Compliance with the CDC hand washing guidelines = Use the waterless hand sanitizer with consistency. Teach staff that they must use this product BEFORE and AFTER a customer encounter--- and that use of gloves does not replace use of hand sanitizer. After the gloves come off, use the alcohol gel!
- Implement a fall reduction program and evaluate the effectiveness of the program. (Measurable reduction in risk for patient falls). The key word here is measurable. Add a checkbox to all the documents your staff use when going to a customer’s residence (probably the delivery ticket or work order) that states ‘___ tripping hazards minimized’. Be sure to in-service and remind staff who go into customer’s homes to be on the lookout for tripping hazards and to do what they can to educate and minimize the chances of a customer tripping and falling. By consistently checking this box to indicate this activity occurred, you can then make a statement in your PI report that ‘100% of the time, when staff are in customer’s homes, tripping hazards are assessed and when identified brought to the attention of the customer’. Be alert for patients that share that they have fallen recently.
- Specifically ask customers about safety and how improvements can be made. Surveyors seem to prefer this to be a question on the satisfaction surveys. While we are on that subject, the new CMS Quality Standards include the requirement that you inquire about patient access to products and services. I believe this is targeted at determining whether competitive bidding has a negative impact on patients ability to get what they need. A suggestion is to add the following question to your customer satisfaction surveys:
How would you rate Medicare's rules regarding home medical equipment and the impact these rules have on your access to the products and services you believe you require?
Graph your Performance Improvement data and incorporate these into reports that discuss whether the findings are acceptable or not. If the data indicates something must be done, you need a concise action plan of who is responsible, and what will change when.
Remember, Performance Improvement is NOT JUST CUSTOMER SATISFACTION! You should be reviewing Infection Control logs, customer chart audits for accuracy, Incidents, Complaints, and tripping hazard minimization at a minimum.
Lastly, an annual study of critical failure points in your business (as related to patient care) should be performed. Actions should be implemented that decrease the risk of this failure from happening and are measurable. For instance, if 25% of your concentrator customers refuse a back-up tank, implement actions to decrease this to as close to zero as possible.
You no longer need to publish, post, and distribute notices to announce your upcoming survey because you don’t know when they are coming. As a result of this, you now need to notify your customers that they may contact JCAHO if they have unresolved concerns after bringing them to your attention. You need to provide your customers with information on how to contact JCAHO. (If your concerns are not addressed to your satisfaction, you may contact the Joint Commission’s Office of Quality Monitoring. To report any concerns or register a complaint call 1-800-994-6610 or email complaint@jcaho.org). Similarly, you need to notify your employees that they may contact JCAHO, and they may do so without retaliatory or disciplinary action.
As JCAHO continues with unannounced surveys, it helps to have a plan. More than one person at your company should know where the Performance Improvement reports are store, in addition to the complaint and incident reports, infection control logs, in-service records, personnel files, and policy manual.
Surveyors generally arrive by 8:30am. You can log on to your ‘Jayco’ extranet to see the name and photo of your surveyor, just in case you want to validate this person is the real thing and not a poser. Think about where the surveyor can setup shop for the day- ideally away from overhearing customer service staff on the phone.
JCAHO continues with the Tracer Method of performing surveys. The surveyor will pick the customer to visit from the stack of work orders. They want to be as non-disruptive to the daily routine as possible by simply tagging along some activity your staff were going to do anyway. The surveyor does not want to see a new setup. The ideal home visit is to a customer that has several pieces of equipment or services from your company, lives close to your business, and has been on service for several months (such as a repair of a bed, a concentrator check, cylinder exchange or a liquid oxygen delivery).
