For years, healthcare leaders have looked at Most Frequently Scored Standards as a roadmap for compliance. But instead of focusing solely on volume, Joint Commission (JC) recently highlighted issues that are both frequently scored and rated as higher risk on the SAFER Matrix.
The High Risk Most Frequently Scored Standards
When a surveyor identifies these specific issues, they don’t just see a single citation. Instead it raises a red flag that often leads them to question your organization’s broader clinical oversight. In many cases, these are the precursors to Condition-Level findings.
Moving Beyond Standard EP Numbers
Interestingly, JC is moving away from citing specific Element of Performance (EP) numbers in these discussions. Instead, they are categorizing risk into ten generic organizational processes. This approach emphasizes the outcome of the process rather than just the technicality of the rule.
Top 5 Clinical Risk Areas:
- Reducing Healthcare-Associated Infections – This includes expired supplies, improper storage, and failing to follow Manufacturer’s Instructions for Use (MIFU).
- Medication Administration – Ensuring the five rights of administration are followed every time.
- Nursing Policy Implementation – Bridging the gap between what is written in the manual and what happens at the bedside.
- Resuscitation Equipment Availability – Ensuring crash carts and supplies are ready and inspected.
- Pre-Anesthesia Assessments – Confirming assessments are completed and documented before the first dose of sedation.
Top 5 Physical Environment (EC/LS) Risk Areas:
- Safe/Suitable Interior Spaces – General maintenance and safety of patient care areas.
- Critical Pressure Relationships – Maintaining appropriate airflow in ORs, sterile processing, and isolation rooms.
- Clean, Odor-Free Environment – Addressing the “sight and smell” test that influences surveyor perception.
- Hazardous Chemical Handling – Proper storage, labeling, and secondary containment.
- Furnishing Safety – Ensuring furniture and fixtures are well-maintained and don’t pose a ligature or injury risk.
A Top Clinical Challenge – Pre-Anesthesia Assessments
One area where we consistently see organizations struggle is the Pre-Anesthesia Assessment. While dedicated anesthesia staff typically have structured EMR templates, the risk increases significantly during moderate sedation performed by non-anesthesiologists.
The Joint Commission views moderate sedation under the umbrella of Anesthesia. We often find that in these cases:
- The assessment is embedded in a general progress note and is hard for a surveyor to find.
- The EMR navigator is not configured to prompt the provider for specific required elements.
- The documentation is simply missing because the provider didn’t view the procedure as anesthesia.
We recommend you standardize your documentation approach. Whether it is a bedside procedure in the ICU or a colonoscopy in the GI suite, using a consistent template across all specialties ensures that your team can always produce the necessary proof of compliance during a survey.
The Bottom Line: Protecting Your Reputation and Revenue
Compliance is often viewed as a nice to have until a survey goes poorly. A Condition-Level finding doesn’t just impact patient safety—it strains administrative resources, threatens accreditation status, and can lead to costly “Systems Improvement Agreements.”
By focusing on these high-risk areas now, you aren’t just preparing for a survey; you are hardening your workflows against the errors that lead to patient harm and financial risk.
How Patton Healthcare Consulting Can Help
Navigating the subjective nature of the SAFER Matrix requires an experienced eye. Our team of consultants provides Mock Surveys that mirror the current JC methodology, helping you identify these high-risk standards before a surveyor walks through your doors. Contact us to learn more.


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