This month’s Consistent Interpretation column focuses on MM.03.01.01 which describes medication storage requirements. Here are two important interpretation highlights that are important to note.
First, when the manufacturers package insert requires storage at room temperature, ambient temperature or a temperature range between 59 – 86℉, Joint Commission does not require a “temperature management process” or a daily temperature recording log.
Because we have seen this very issue scored many times over the years, this is particularly instructive. Most areas in a hospital have heating and cooling that provide a stable room temperature. But, even with this guidance, TJC will likely score medication storage in an unheated or non air conditioned warehouse.
For example, there is a perception that all vaccine storage should take place according to CDC guidance for vaccines. Now, TJC states that you must adhere to CDC guidance only if:
- They are examining vaccines distributed from the Vaccines for Children’s program
- Your state mandates CDC storage criteria
- The hospitals policy states all vaccine storage must take place per CDC guidance
TJC does state that vaccine storage should be under the individual vaccine manufacturer’s guidance. This is also known as package-insert or manufacturer’s instructions for use (MIFU). Further, hospital policy should reflect this same information.
COVID Vaccine Storage Information
Also, the CDC published their Vaccine Storage Toolkit published earlier this year. Updated in late November, it includes more information on COVID-19 vaccine storage. You can locate this new data on pages 50-56 of the revised document. You may download this revised toolkit here. Plus, you can expect more information from each vaccine manufacturer, the national wholesaler involved in distribution plans and state public health authorities.
Patton Healthcare Consulting
Patton Healthcare Consulting can help you navigate the new normal. Our new remote consultation “Comprehensive Hybrid Readiness Review” is a hybrid remote/onsite support program. It is designed to assist with assessment and education to meet your needs going forward after this national emergency.
In addition, we understand the need for assistance without disrupting your organization or extensive costs. That’s the specific purpose of this program. Contact us at (888) PHC-INC1 for more information or email us at ExpertAdvice@PattonHC.com.