The lead article in the April issue of The Joint Commission Perspectives lists the top 10 most frequently scored standards by program for all of calendar year 2015. The list is 90% familiar to our readers and as we have mentioned repeatedly in the past, the key to using this data is to assess your own compliance with these thorny issues, and make corrections as necessary. One familiar problematic standard fell off the top 10 listing and that is. While TJC does not indicate how far down it fell, we would assume it has not gone far, as it remains a frequently scored standard that we see in client reports due to the many elements of performance and the need to have well organized testing data about fire suppression systems.
With one familiar issue falling off, there is one new one coming on the scene, and this is a bit of a surprise. The new #9 most frequently scored standard isand we have not seen this in the top ten listing in the past. The standard states: “The hospital provides care, treatment and services as ordered or prescribed, and in accordance with law and regulation.” There are then 3 elements of performance for hospitals; one requiring obtaining orders prior to providing care, a second to use the most recent orders and a third to use a read back process for verbal or telephone orders and critical results.
While this standard has not previously made the hospital top 10 list it has been on the home care top ten lists for at least 15 years. In home care there has been a long standing difficulty of matching active orders being provided with the periodic physician authorization in the 485 plan. Rather than this being indicative of an entirely new issue hitting the hospital industry, we believe this is more likely the result of advice being given to surveyors on where best to score some issues, which do arise on hospital surveys. Relative to EP 1, we do from time to time see findings where staff initiated some treatment in anticipation of a physician order, but there is not yet a physician order, nor is there a hospital approved standing order to do so. For example, the patient that shows up in the morning for an outpatient surgical procedure and staff start an IV, prior to the physician making rounds to actually order the IV. Similarly, when a newborn infant receives vitamin K, or erythromycin eye ointment prior to staff actually obtaining orders, and again there is no hospital approved standing order to do this. Another example we have seen more recently is when a patient has a stratified pain order set for oral Percocet for mild pain and IM Dilaudid for moderate to severe pain and staff treat outside of the structured order set parameter. In other words, they provide Percocet for severe pain, or Dilaudid for the mild pain.
The second EP, actually numbered as EP 7 requires treatment according to the most recent orders. This is interesting as orders have gotten so complex, with so many different medications and treatments, that sometimes staff fail to note subtle changes in the orders and continue to use an older order that should have been modified slightly. The third EP, numbered as EP #20, is the write down/read back concept for verbal orders and critical results. We don’t believe this is the newly problematic EP for this standard. The process seems pretty well hard wired and we have not seen RFI’s for this in several years.
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