ASPMN TJC talk 2011...9/9/2011 10 2011 Transformed to the new TJC Standards are just one leverage...
Transcript of ASPMN TJC talk 2011...9/9/2011 10 2011 Transformed to the new TJC Standards are just one leverage...
9/9/2011
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The Joint Commission Requirements
Paul Arnstein, RN, PhD, FAAN
Clinical Nurse Specialist for Pain Relief
Director: MGH Cares About Pain Relief
Massachusetts General Hospital
Demystifying
Financial Disclosures 2010 ‐ 2011
Advisory Board Consultation
Ortho McNeil
Covidien
Projects receiving unrestricted educational grants
Ortho‐McNeil ‐ PriCara
Purdue Pharma LP
Other Consulting
Nurse Practitioner Healthcare Foundation
Book: Clinical Coach for Effective Pain Management
F.A. Davis
My Personal Journey: Understanding the Joint Commission Orderly
Polish everything
Nursing Student Safety punch‐list
R.N. Endless to‐do lists
Nursing Director Best appearances in preparation for visit
Policies Charts Personnel Hallways
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ASPMN sends a LiaisonBelinda Puetz, ASPMN Executive Director
convinced JCAHO
in 2005 they needed a
Pain Management Nurse
Transitions from JCAHO to The Joint Commission
Bully Pulpit Gotcha mentality Aware of common problems Prescriptive solutions
Shared visions, new pathways Each organization is unique Serve different populations Access to different resources Enduring, meaningful change
JCAHO Takes on Pain 15% Americans major trauma/surgery pain (45 million)
35% Adults have chronic pain (>116 million)
More than diabetes, heart disease & cancer combined
Pain‐related disorders increasingly prevalent
50% of inpatients/outpatients have pain
30% patients give hospital low marks for pain control
Untreated/undertreated pain still common
CDC(2007) Fast Facts A-Z @ CDC.gov Ries et al (2008). SEER Cancer Statistics Review IOM (2011) Martin BI, et al. (2008). Back/Neck Problems. JAMA, 299CDC (2008). Targeting Arthritis: @cdc.gov Jha et al. (2008) [HCAHPS] NEJM, 359 (18):1921-31National Center for Health Statistics (2006), Special Feature on Pain
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Standards justified
Pain Standards added (2000):
Pain is carefully assessed & treated promptly
Pain assessment lapses risk for untreated pain
Reassessment lapses linked to sentinel events
First foray into Evidence‐based practice
Intent to succeed where AHCPR failed
Policy Push to Improve Pain Care
AHCPR genesis
AHCPR guidelines 1, 9, 10, 14 (1992‐4)
Year 2000, JC Standards integrated
Focus: Quality, standardization, & safety
Medicare / Medicaid CoP followed suit
Military Pain Care Acts of 2008, 2010
Affordable Care Act (2010) / IOM report(2011)
Myths about TJC pain standards Pain as a conspiracy by Pharma
Pain as the 5th vital sign
Assessment all non‐verbal patients w/ FLACC
Timing of reassessments
Prohibition of nursing judgment
To select from ordered prn drugs
To dose by a range orders
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JCAHO Focus in 2005 ~perpetuated myths
Very standards focused
Not clear
Not consistently interpreted
NPSGs examined but not integrated
The “Talk” and the “Walk” not in sync
More prescriptive than consultative
Senior leadership unaware of what surveyors said to create & perpetuate myths
e.g. Assessing non‐verbal & range orders
OSH Case: Mr. Abe Sessonumberg
27 y/o Male for I&D cyst on 12/24
Cried inconsolably post‐op
Aggressive morphine use, periods of apnea
ICU – morphine titrated to FLACC scores
Ventilator‐dependent
Eventual switch & revelation
Were standards met for this patient?
Did the patient receive the best possible pain treatment?
JCAHO response (Range Order & Nonverbal Assessment remediation)
In Defense of Range Orders Permit flexibility & rapid response to patient needs
Professional judgment is allowed ~based on : Vital signs
Age
Level of consciousness/alertness
Patient condition
Co‐morbidities
Other medications
Anticipated illness trajectory
Target symptom severity
Patient response pattern matters
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Safe, Prudent Approaches Range narrow enough to be safe
Range wide enough to provide flexibility
Start with the lowest dose in the ordered range
Unless assessment indicates need for higher dose
If symptoms are not relieved,
Additional doses within range may be given
Total amount < not to exceed maximum dose
“Rolling clock” notion of limit
Order refinement to increase or decrease dose
Standards interpretation confusion Does every patient (inpatient & outpatient need to be
screened/assessed for pain)? Yes
Why does the FLACC need to be used in populations it
was never validated for? It doesn’t
What do surveyors want for range orders?
Clear indication
Consistent interpretation
Decision‐making within scope of practice
Joint Commission priority 2006‐08To improve the quality & safety of care
New survey method
New scoring
Reorganized, reworded all standards
Emphasis on “Direct Impact” items, for example:
Anesthesia and Sedation
Pain Assessment and Reassessment
Emergency Medication availability
High Alert Medications (including SALAD)
Healthcare Associated Infections
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TJC Standards: Respect right to pain control & train professionals
Rights and Responsibility: RI.01.01.01 (EP8)
Organization respects patient’s right to pain management
Human Resources: HR.01.04.01 (EP4)
Provides orientation to staff on assessing / managing pain
Medical Staff Chapter : MS.03.01.03 (EP2)
Hospital educates all LIPs on assessing & managing pain*
*LIPs = licensed independent practitioners
TJC Standards: Assess, Treat, Reassess & Document Pain PC.01.02.07
Identification & treatment of pain is a key part of care.
Expectation: patients will be asked about pain, and when present services will be provided accordingly.
Elements of Performance:
1. Conduct a comprehensive assessment consistent with scope of care, treatment, services & patient’s condition
2. Assesses pain in an age and ability appropriate manner
3. Reassess & respond to pain based on hospital criteria
4. Either treat pain or refer the patient for treatment
TJC Standards: Assesses & Reassess Patient’s Pain PC.01.02.01
… Patient needs must be reassessed throughout the
course of care, treatment and services.
EP1: Reassessment includes effectiveness and side effects
DEFINE WHEN
EP2: When in‐depth … pain assessments are performed
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New! 2012 Standard: Pediatrics PC.01.02.07 Hospital assesses and manages pain
EP2 … The hospital involves the family, when appropriate, in identifying signs of pain.
PROCEDURAL PAIN REQUIREMENT
EP6: In order to reduce stress and pain related to procedures, the hospital intervenes before the procedure using pharmacologic and non‐pharmacologic (comfort) measures.
TJC Standards: Patient Education PC.02.03.01
Hospital provides patient education based on each
patient’s needs and abilities.
EP10: … Information on safe, effective use of medications…
Discussion of pain, the risk for pain, the importance of
effective pain management, the pain assessment process
and methods for pain management.
TJC Standards: Care after procedures requiring moderate or deep sedation or anesthesia PC.03.01.07
…Sedation and anesthesia … in any setting… for any
purpose, by any route
EP2: … …Monitors the patient’s physiological status,
mental status and pain level at a frequency and intensity
consistent with the potential effects of the …procedure
&/or sedation or anesthesia administered.
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Related Standards MM.01.01.03. (2%)
(C)* Managing high‐alert medications
MM.02.01.01. (<1%)
(A)* Standardized concentrations of drips
(A) Annual review of formulary drugs for safety/efficacy
MM.03.01.01. (34%)
(C) Storage per manufacturer recommendations.
(A) Controlled drug storage per law and regulation
(A) Medication security (C) Medication handling when in possession of staff
(C)* Revised expiration dating of multi‐dose vials
(C)* Most ready‐to‐administer form stored on unit
Pain‐related MM StandardsMM.04.01.01. Medication orders are clear & accurate
EP1 …has a written policy that identifies the specific type of medication orders that it deems acceptable for use. (Range orders, titration/taper orders …etc)
The hospital policy defines:
Required elements of a complete medication order
When indication for use is required
Precautions for ordering LASA drugs
Actions to take when medication orders are incomplete, illegible or unclear.
The hospital implements it policies for medication orders
MM.05.01.01 A pharmacist reviews all orders
to be dispensed
All medication orders are reviewed for …
EP5. Existing or potential interactions between the medication ordered and … current medications
EP6 … appropriateness …
EP8 …reviewed for therapeutic duplication.
EP9 … other contraindications.
…. all concerns, issues, or questions are clarified with the individual prescriber before dispensing.
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Additional Pain Clinic Issues NPSG 03.04.01 – Labeling all medications, medication
containers, and other solutions on/off sterile field.
UP.01.01.01 – Pre‐procedure verification process.
UP.01.02.01 – Mark the procedure site
UP.01.02.01 – Time‐out immediately prior to starting the procedure
Non Compliance in 2010Standard Practice Non-CompliancePC.02.01.03 Home Care
Provide treatment per (Rx) order [Scope]
34%
PC.01.02.03 Assess and reassess according to defined time frames
31% Hospital
23% CriticAcces
19% LTC
MM.04.01.01 Medication orders are clear & accurate
28%
PC.8.10 (BehavHe)
All patients’ are assessed for pain
11%
NPSG.03.04.01 (amb)
Label all meds on & off sterile field w/procedure
16%
2009‐2010 New TJC Philosophy
Move away from “Gotcha” mentality
Convergence and synergy
Work together to find high quality, reliable, safe care
Find real‐life solutions to common problems
Provide a national voice for advocacy & support
Change survey to “relationship‐based” approach
1 point person, knows your issues, provides guidance
Booster packs, training webinars, conference calls
More consultative than interventional
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2011 Transformed to the new TJC
Standards are just one leverage point
Partner with organizations with similar goals
Focus on real life issues that make a difference
Accountability
Culture of Safety / Trust
Robust Process Improvement
Highly reliable, evidence‐based care
Communication and leadership
Focus on routine processes that routinely fail
The Joint Commission Mission
Mission: To continuously improve health care for the public, in collaboration with other stakeholders, by evaluating health care organizations and inspiring them to excel in providing safe and effective care of the highest quality and value.
Vision: All people always experience the safest, highest quality, best‐value health care across all settings.
There’s a growing alignment between the “Walk” and the “Talk”
Strategic Approach Improved Accreditation Process
Customer service training
Focus to better understand your organization not theirs
Proactive calls, webinars, conference calls, social media
Move toward relationship‐based model
Support tools
Booster packs
Targeted solutions tools
Leading practices
Frequent touch‐points
Ongoing data transfer
Intra‐cycle monitoring
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Improve TJC processes Use Robust Process Improvement (DMAIC) methods
Define
Measure
Analyze
Improve
Control
Address field staff needs
Surveyor consistency
interpreting regulations & standards
Advance programs & Disease‐specific certification
More robust than •Plan•Do•Check•Act
CMS “Deeming Status” conflicts Much discussion
Most EP’s Have to meet Conditions of Participation
CoP’s outdated & not evidence‐based
TJC has gone light on many … CMS fought back
Ongoing negotiations with CMS, some progress
Those standards sometimes carry caveat
May get “Deemed Status Deficiency”
Not “Conditional Re‐accreditation Status”
Will require a revisit
Accountability Need Accountability and Highly Reliable Solutions
Airlines as a model
If they failed like HC …
More than a crash each day
Leadership must commit to a “O” quality failure goal
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Build a Culture of Safety Balance learning from isolated, small, human errors with accountability for blameworthy errors.
Make changes, take action as appropriate
Without differentiating the two, lose trust
Trust to safely report concerns without repercussions
Trust action will be taken
Intimidating behaviors undermine culture of safety
Condescending language, unreturned calls, impatience
Occurs with all roll groups
Evolution of Quality Improvement
Publish it (passive diffusion)
Hope … they will change
Read it for them (clinical practice guidelines)
Hope … they will become enlightened
TQM / CQI / system redesign it (industrial style)
Hope … they will improve
Hope ….
“Next stop – high reliability”
High Reliability Solutions Highly effective process improvement
Find and fix problems before harm occurs
When harm does occur , analyze with stakeholders
Root Cause Analysis
Failure Modes and Effects Analysis (FMEA)
Build skills:
Identifying hazards
Using tools of highly reliable, sustainable improvement
e.g. six sigma, lean, etc.
Create ways (e.g. dashboards) to monitor proactively
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R3 Reports (e.g. Revised Patient Communication std)
Requirement, Rationale, Reference Required (new standards 2012): Hospital effectively…
Communicates with patients when providing care…
Medical record reflects treatment … and services
Promotes patient rights
Defines qualifications of interpreters
Rationale Change in CMS Conditions of Participation requirement
Changes in Federal Regulations (Limited English Proficiency)
Changes in Research (Health literacy, ethnic/cultural, GLBT)
References (25 cited)
Measurement is the key:
Slippery slope of evidence
Needs to be accurate, timely and meaningful
Some measurements required by all organizations
Some selected based on RPI goals
New way of calculating standards
Press Release September 2011
Achieve >90% on >85% of composite EPs = accredited
Achieve >95% on all standards = “Top Performer” status
2011 Accreditation categories
Preliminary Accreditation
Accredited
Accredited with follow‐up
Replaces provisional accreditation
Follow up ~ 30 days to 6 months
Contingent Accreditation
Replaces Conditional Accreditation (30 day F/u)
Preliminary Denial of Accreditation
Denial of Accreditation
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Moving towards
Support for Integration of Care:
Physical and Behavioral Health
Addiction and mental health care
Prevention and early detection
Focus on transitions in care
Pre‐hospital and post‐discharge
2011 – 2012 What to expect Second generation tracers
More questions asked … more drill‐down
Focus on high risk processes that affect care
Clinical procedures (surgery or interventions) & competency
Blood & medications
Patterns of M & M, and length of stay
Use of consultants … the appropriate treatment team
Cleaning equipment, HH & infection control
Staff/LIP training on assessing & managing pain
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Strategic Surveillance System™ (S3)
Quarterly data transfer + past survey data ID problems
ORYX® core measure data
HCAHPS (Hospital Consumer Assessment of Healthcare Providers) data
Complaint and sentinel event information
Tool aides in drill‐down & clarifies expectations
How TJC defines the priority focus area
Benchmark against national and state comparison
Trend the focus area over the last eight quarters.
Targeting solutions to root cause
Rapidly building a database available to accredited organizations to help solve problems between visits
Each unique facility has unique issues
Can learn from leading practices library
Can use a targeted solution developed by others who successfully solved similar problems
Will not affect accreditation unless an
Immediate Threat to Life noted during survey
No effort to find or fix obvious root causes
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•Root Cause of:
•80% Serious Errors
•#1 Cause of
•Sentinel Events
•Transfer-related malpractice
•Permanent Disability from errors
•11% due to communication
•6% due to professional skill level
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Standardize
Hardwire System
Allow Opportunities to Question
Reinforce Quality & Measurement
Educate and Coach
Our Challenge (move our agenda forward):
Link suboptimal pain control (& improper detox) to:
Culture of Safety
Trust, accountability
Patient Satisfaction
Required education of patients & professionals
Communication breakdowns
Then use RPI methods to
Better understand current state
Improve professional practice
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Thank you for the privilege … to serve as your liaison to TJC