I have a question. Since when does the Joint Commission (TJC) change their standards and performance guidelines based on a powerful, but knee-jerk and error-prone agency like the Centers for Medicare and Medicaid Services (CMS)?
History shows that the CMS issues memos and mandates specific behaviors based on anecdotal and incomplete information. The memo of December 10, 2011 (available at www.HTMA-SC.org) illustrates this behavior on their part. The memo undid over 20 years of progress that the HTM profession made on selecting carefully crafted PM procedures and frequencies based on the scientific analysis of failures. This change was made by a couple of well-meaning but unknowledgeable folks at an all-to-powerful agency – CMS.
A couple of ill-informed people caused hundreds of thousands of dollars of cost and lost productivity in healthcare while we tried to figure out how to comply (or refute) the obviously incorrect memo. In the end, they modified the original memo and requirements more than two years later in a subsequent memo dated December 2, 2013. Those of us in the HTM profession knew immediately that the original memo was a complete error and should not have been released as “law.”
It took the CMS over two years to correct their error. It would have been much easier if they had taken the time to study the issues beforehand, involve a diverse group of professional maintainers, and crafted an accurate and manageable action memo. Instead, they issued a poorly thought-out and undoable criteria, based on a complete misunderstanding of the accepted practices in the HTM profession. And then, instead of seeing the error of their ways and recalling it immediately, they left it in place for two years until they could “modify” it. The lack of an immediate recall of the original memo shows that they are more interested in saving face than doing the right thing for healthcare.
Jump forward to the now-infamous comments by George Mills of the TJC at AAMI in June 2014. He told a group that CMS would immediately prohibit all outlet strips and extension cords (now called Relocateable Power Taps – RPT) for use on patient care equipment in hospitals. This has lead to a whirlwind of activity, speculation and uncertainty on the part of hospitals, HTM professionals, ISOs and manufacturers(See Shop Talk page 32). CMS has not made a formal statement on this subject. I believe their stance is that they are simply enforcing existing standards in NFPA 99-2005 edition.
In the absence of anything concrete, hospitals are acting in one of three ways: 1) ignoring the dictate until something formal is released; 2) implementing outlet strip tagging, inventory and routine, scheduled PMs and performance verification; or 3) taking the recent comments as the rule of law and spending thousands of dollars to install new outlets and attempting to comply fully with the assumed meaning of the CMS enforcement.
In the meantime, lots of time, effort and money are being spent to solve a problem that is a) being relayed second-hand from CMS (no slight to George Mills, but I always take my marching orders from the original source and tend to ignore any dictates from a downstream source) b) easily solved, if someone would just listen to me and 3) becomes mute if you read the 2012 edition of NFPA-99 Section 10.2.3.6, which allows these RTPs if proper surveillance is given and safeguards are made to prevent additional devices from being plugged into them.
TJC is a deliberative agency which has a track record for thinking through a subject before making sweeping changes that affect over 4,000 hospitals. Why would such a great (not perfect) organization change their carefully crafted standards to reflect those of an obviously ill-informed but powerful federal agency?
If, as the documents from the Joint Commission’s website is correct, “The Centers for Medicare and Medicaid Services (CMS) and 46 state agencies substantially rely on the Joint Commission’s accreditation of hospitals in lieu of conducting their own inspections.” HAP_Value_Accreditation.pdf. , then why does the CMS not rely on TJC to study and modify their rules, instead of short-circuiting their processes by mandating unimplementable rules?
We have a serious problem here. If the CMS continues to make poor mandates, we in HTM – and healthcare in general – will be in a world of trouble in the future. We need to let the accrediting agencies make their own rules, instead of some bureaucratic federal agency who knows not what they are doing.
Please reply with your thoughts to me directly or to firstname.lastname@example.org.
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