Tuesday, March 08, 2011

Why do we need a regulatory crosswalk?

In a post below, I talked about the unfortunate marketability of a book that explains The Joint Commission standards in plain English -- both for the hospitals it surveys and for its own surveyors. Now arrives another email with an ad for a $399 service called Patient Safety Monitor, that, among other things, allows you to:

Find and compare state, CMS, and Joint Commission regulations on high-profile patient safety issues such as:
  • Verbal Orders;
  • Critical Test Results;
  • Handoffs
  • Infection Control: Hand Hygiene
I don't want to get into the issue of state regulations today, but the idea that you might pay for a service to provide a "crosswalk" to help you reconcile CMS and Joint Commission regulations is troubling.

The CMS Conditions of Participation are basically the terms that make a hospital eligible to see Medicare patients, and by extension, other patients whose bills are paid by private insurers. In essence, you can't stay in business as a hospital if you do not satisfy the Conditions of Participation.

The Joint Commission has been delegated "deeming authority" by CMS to review a hospital's compliance with the Conditions of Participation.

So should there be any difference between the reviewing standards of the JC vis-à-vis that of CMS? If there is no difference, why is this service being sold? If there is a difference, we have a troubling difficult situation.

The advertised service, by the way, also provides updates in a Patient Safety Monitor Journal of new developments in regulatory review standards. As in the previous post, I wonder why there is a need for a commercial product to offer such advisories. Don't CMS and The Joint Commission offer plain English advisories and interpretations of their own regulations?

All of which reminds me, while we are at it: Whatever became of the idea of The Joint Commission making its library of best practices open to the public? Why doesn't CMS require it as part of the delegation of authority? After all, the JC acquires this information as part of its surveying function. In that sense, it should be public information, like other government sponsored work.


e-Patient Dave said...

*Is* there a need for these things? Or is this just an example of something some fools will buy, not realizing the info is freely available? I'm thinking of the companies that offer info on one's Social Security account, etc, which anyone can have for the asking.

I dunno, just wondering.

Anonymous said...

Could it be the same reason that the Joint Commission also has a consulting arm to help you pass inspection?

"Follow the money."