NOTE: This cohmn is an excerpt of a speech Maryanne L. Popooicb presented in June at the Joint Commission\ Fourth National Conference and ExbibitioMfor Home Care and Hospice in Washington, D.C.
The Joint Commission’s mission is to improve the quality of care provided to the public. One method used to reach that mission is to reevaluate the Joint Commission standards at regular intervals and to add, delete, or revise them and the accreditation policies and procedures to maintain the most contemporary standards possible. This year the Joint Commission reviewed the standards for home care in preparation for the new 199%200~1 Comprehensive Accreditation Manual for Home Care [CMC). This article highlights the changes our currently accredited customers can find in this manual. All changes noted will be effective on Jan. 1, 1999, and will be used for all surveys conducted from that date. Organizations that currently are accredited (or have submitted a current application for accreditation) automatically receive one copy of the CAMHC. If you wish to order addi-
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tional copies, or if your organization is not accredited but is considering accreditation, you may purchase a manual by calling the Joint Commission Customer Service Center at (630) 792-5800.
NEW CHAPTER What probably will be perceived as the biggest change in the new edition of the manual is the addition of a new chapter, Accreditation Participation Requirements, which has been added to all accreditation manuals. The chapter does not include standards but rather requirements that organizations are expected to meet to be in compliance with Joint Commission policies. Many of these requirements are not new and were included in past editions of the manual under the Accreditation Policies and Procedures section. However, as of Jan. I, i 999, these requirements can affect the accreditation decision. Any organization that does not meet one or more of the following requirements is subject to at least a type I recommendation and thus becomes ineligible for accreditation with commendation. Organizations should review this section carefully and make
sure they comply. The requirements in the chapter relate to: l
Survey application
l
Survey acceptance
l
Performance
l
Public
l
Misrepresentation
measurement
information
interviews of information
The performance measurement requirements are for ORYX: The Next Evolution in Accreditation, a new initiative to integrate the use of outcomes and other performance measures into the accreditation process. Under this initiative, organizations are required to select and use performance measures as part of their participation in the accreditation process by Dec. 3 1, 1998. If you are unaware of or unclear about the initiative, please call the Joint Commission’s ORYX Information Line at (630) 792-5085.
STANDARDS-RELATED CHANGES We now will address some of the major changes to the standards in the
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various chapters in the accreditation manual. No substantive changes were made to the Assessment; Education; and Surveillance, Prevention, and Control of Infection chapters. A highlevel overview of some of the chapters that do have changes follows.
or service is initiated, and a qualified individual should review all orders for appropriateness and accuracy before providing care or service. This requirement applies to all home care services when a physician’s order is needed for the care or servicesprovided.
Rights and Ethics. The only truly
In addition, Standard TX.2 requires that care or service be provided as stated or written on the order. In other words, if a physician’s order calls for oxygen at 2 LPM and the surveyor notes that the organization consistently has set the concentrator at 4 LPM, this discrepancy will result in a recommendation. In a pharmacy setting, using a heparin flush without a prescription for the heparin would result in a recommendation at this standard.
new standard for I 999 is included in this chapter. Standard RI.4.2 states, “The organization protects the integrity of clinical decision-making regardless of how it compensates or shares financial risk with its leaders, managers, clinical staff, and physicians.” In other words, organizations are expected to base their clinical decisions on the patient’s health status and his or her care or service needs rather than on financial decisions. An organization might receive a recommendation on Standard RI.4.2 if, for example, a nurse indicates that a patient needs several additional visits because she is paid on a per-visit basis and needs extra money that month. For home medical equipment companies, an example is an organization that provides the patient with unnecessary equipment “extras” because the patient’s insurance covers the associated expenses. An example for pharmacies is a pharmacist who recommended a less expensive antibiotic therapy that is not as effective a treatment because it is less costly for the pharmacy organization. The standards in this chapter have been significantly reordered, and we have tried to clarify the requirements related to physician orders.
Care, Treatment,
and Service.
Standard TX.2 now focuses on providing care on the basis of a physician’s order, whether that order is given orally, in writing, or as a prescription. The order should be obtained before care
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Issues related to physician signatures now are addressed in the Management of Information chapter at Standard lM.9.15. If a physician’s signature is required only for billing purposes (eg, filing for reimbursement) but not by law or regulation, the lack of a signature will result in a recommendation at Standard Rl.3, which relates to ethical billing practices. The phrase “according to law and regulation” has been added to Standard TX.3, which requires organizations to provide service in accordance with standards of practice. If care or service provided violates law and regulation, the recommendation will be scored at Standard TX. 3. For example, surveyors would make a recommendation in this situation if a hospice has a home health aide providing the care that a licensed individual should or if a service technician for a home medical equipment organization sets up a ventilator that by state law can be set up only by a licensed person.
The standards related to reviewing and reporting adverse drug reactions and medication errors have been moved to the Improving Organization Performance chapter. Continuum
of Care. Requirements
from previous Standard lM.9.25, which specified that a copy of the discharge summary be provided to the patient’s physician when required by law and regulation, has been moved to this chapter at Standard CC.5.2. In addition, Standard CC.4.3.1 has been revised to include an element related to communication of relevant patient information to that patient’s physician. Improving Organization Performance. Although the same concepts
of improving organization performance continue, the chapter has been reworded significantly and includes new scoring. This revision was done to make the manuals across all Joint Commission accreditation programs consistent. The essential processes of design, measure, assess,and improve have been renamed design, data collection, aggregation and analysis, and performance improvement, respectively. In addition, all standards in this chapter are now “A” standards, which are those that result in a type I recommendation when scored 3, 4, or 5, even if all other standards in the chapter are in compliance. Table 1 features a list of the A standards. More specifically, Standards PI. t and PI. 1.1 have been rewritten to emphasize the responsibility of leadership in the performance improvement process. These standards will be scored at Standard LD. 13.2 in the Leadership chapter. Standards PI.3 through Pl.3.1.3 identify the specific areas that should be addressed in per-
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1998, VOL. 3 NO. 5
JCAHO
formance measurement. Standards PI.4 through PI.4.4 detail the attributes of aggregating and analyzing performance measurement data.
dard EC.6 relates to incident reporting, and we have included a definition for “incident” in the manual. Management
Standard LD.2.3.1 now requires all organizations to have an annual operating budget, regardless of whether or not law or regulation require it. Standard LD.5, which previously was Standard LD.8.2, states that organization leadership complies with law and regulation. The intent has been rewritten to limit scoring issuesthat relate to facility licensure problems or violations that an organization’s leadership condoned or sanctioned. The intent also identifies the specific regulatory agencies that are considered in evaluating the standard. Leadership.
Environmental Safety and Equipment Management. Standard EC. 1
has a more detailed explanation of what constitutes the organization’s environment, specifying that delivery vehicles (including staff cars) are included in this definition. The intent of Standard EC. 1.6 has a much longer explanation related to fire protection, including the National Fire Protection Agency’s regulations for inpatient facilities. Inpatient hospices will be expected to meet all relevant elements of this intent. Stan-
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of Human
Resources.
The standards for this chapter have been reordered slightly. Staff competence now is addressed at Standard HR.4. A separate standard no longer exists for the orientation and competence of personal care and support staff, which now are included in Standard HR.4. of Information. Several changes have been made to this chapter. First, the requirements from old Standard IM. 3.1, which required data accuracy, have been split into two standards: IM.3.1 and IM.3.1.1. The former specifies that the organization is to make sure the data they use are complete, reliable, and valid; the latter requires the organization to ensure the data are accurate.
Management
Standard IM.9.15 states, “Each home care record contains authenticated, legible, and complete physician orders, as appropriate and as required by law and regulation.” In the past, this standard was not scored here but now will be. This standard ties directly to the previously addressed Standard TX.2. Note that authentication is defined as signed with a date of sig-
nature. Although a so-day period for authentication no longer is required, the organization still needs to be in compliance with any time frames stated in law or regulation. In addition, we have added a sentence to the intent for standard IM.9.15 that reads, “The organization has established a system for the timely receipt of authenticated physician orders when required by law and regulation.” This statement means that an organization should demonstrate it has consistently followed its process and taken every step possible to authenticate the order when required to do so. The wording of the intent of Standard IM.9.25 no longer specifies the required elements of a discharge summary. ADDITIONAL
CHANGES
In the new edition of the manuals, appendices from the 1997-98 CAMIK have been changed to specific chapters. An informative chapter that relates to the ORYX initiative has been added; another chapter is devoted to the Joint Commission performance reports and explains these reports and their format. Organizations also should review the chapter on the home care decision rules that
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govern the accreditation decision because several changes have been made to these rules. In addition, a new chapter called Simplifying Compliance Activities includes information to reduce duplicate compliance activities for the Joint Commission and other organizations. This chapter includes the traditional crosswalk between the 1999-2000 CAMHC and the previous version of the manual. Other crosswalks compare the I 999-2000 standards to the Medicare conditions of participation for both home health and hospice organizations.
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. . . . . . . . . . Inside
. . . . . . . . . . . . . . . . Medical
Medical Maryanne L. Popovich, RN, MPH, is the executive director of the Joint Commission’s Home Care Program. She can be reached by Email at mpopovich @jcoho.org.
Page
. . . . Duragesic
Commission
Vegas.
In the 1999-2000 CAMHC, the Medicare conditions of participation have not been included in the intents of the standards. This decision was made in anticipation of the Health Care Financing Administration’s revision of these conditions. When these revisions are published, the Joint Commission will provide an updated crosswalk to organizations that already have purchased the CAMHC.
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OCTOBER
1998,
Center,
VOL. 3 NO.
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