Wednesday, January 04, 2012

Tired is bad. A tired organization is worse.

If stating the obvious were a sign of success, we would have to give The Joint Commission an A+.  It issues Sentinel Event Alerts, ostensibly designed to to emphasize pressing safety issues and provide guidelines for organizations on how to address them.  The December 14, 2011 topic:  "When caregivers are tired, they are more likely to make mistakes."

First of all, this is not a sentinel event.  As noted in the paper itself, it is a long-standing and well documented problem.  Characterizing it as something new when it is not quickly loses readership and attention.

The paper goes on to make some helpful suggestions about hand-offs, fatigue management, and the like.  There is nothing wrong with the ideas.  It is just that they do not get to the root problem -- a task-oriented environment in which well intentioned people work beyond their limits.  In other words, the suggestions are window-dressing to the real issue, the need to re-design how work is done in hospitals.

I guess it doesn't do any harm to issue such papers, and it might do a little good.  But, wouldn't it be great if The JC became an effective leader in transforming health care, rather than restating the obvious?  It still doesn't offer open access to its Leading Practice Library, a compendium of best practices from those hospitals it has surveyed.  And the agency has made virtually no progress with regard to reducing the rate of wrong-site surgeries.

I think they are tired in Oakbrook Terrace, Illinois.

Or perhaps I am being unkind.  After all, the main task facing The JC is ensuring that the CMS Conditions of Participation are met.  This is an incredibly detailed list of standards covering all aspects of hospital operations. 

Let me give you an example.  One part of the COP is the Life Safety Code CertificationPart of that certification is guided by this portion of regulations in the Federal Register.  The summary is simple:

The hospital must be constructed, arranged, and maintained to ensure the safety of the patient, and to provide facilities for diagnosis and treatment and for special hospital services appropriate to the needs of the community.

But then, the surveyors' manual relating to these regulations goes into excruciating detail.  Such detail is required, after all, when the regulations say things like this about hand cleansing dispensers: 

(9) Notwithstanding any provisions of the 2000 edition of the Life Safety Code to the contrary, a hospital may install alcohol-based hand rub dispensers in its facility if:

(i) Use of alcohol-based hand rub dispensers does not conflict with any State or local codes that prohibit or otherwise restrict the placement of alcohol-based hand rub dispensers in health care facilities;

(ii) The dispensers are installed in a manner that minimizes leaks and spills that could lead to falls;

(iii) The dispensers are installed in a manner that adequately protects against inappropriate access;

(iv) The dispensers are installed in accordance with chapter or chapter of the 2000 edition of the Life Safety Code, as amended by NFPA Temporary Interim Amendment 00-1(101), issued by the Standards Council of the National Fire Protection Association on April 15, 2004. The Director of the Office of the Federal Register has approved NFPA Temporary Interim Amendment 00-1(101) for incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. A copy of the amendment is available for inspection at the CMS Information Resource Center, 7500 Security Boulevard, Baltimore, MD and at the Office of the Federal Register, 800 North Capitol Street NW., Suite 700, Washington, DC. Copies may be obtained from the National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02269; and

(v) The dispensers are maintained in accordance with dispenser manufacturer guidelines.

So, to be fair, who at The JC would have the energy and time to focus on the big picture?


Anonymous said...

So, the Leading Practice Library is only available to accredited institutions? Ironic. The library would be far more valuable to non-accredited hospitals, not to mention the rest of the world.

Paul Levy said...

Right, Chris. Also to patients. Also to people in the accredited hospitals who don't happen to have access to their hospital's password, i.e., the majority of practitioners.

John said...

My hospital switched to DNV a few years ago and has found their focus on process far superior to the Joint Commission reviews.

Anonymous said...

Is there a correlation between the length and clarity of an organization name and the effectiveness of its work?

Wouldn't we all be better off if the Institute of Healthcare Improvement were given the resources to do the job of the JC?