If you remember nothing else: Nothing happens in isolation
With the (presumed) onset of regulatory surveys including a more thorough review of survey results past, I would imagine that everyone out there in the listening/reading audience can name at least a couple (if not more) instances of non-compliance that were (for want of a better term) “missed” during survey. Just to use a simple example (which we touched upon back in the wilds of winter), your most recent surveyor may have stopped looking for improperly labeled breakers (spares in the on position; breakers in the on position not labeled, etc.). But the question becomes: How many more are out there…and how carefully did someone look post-survey? Certainly, whatever was identified would have been corrected as part of the plan of correction—you can’t be telling regulators that you did something that you didn’t do, now can you? But what about other potential findings? Now, I recognize that using this particular example is (hopefully) a wee bit hyperbolic in that (again, hopefully), the low risk findings are going to get a mulligan if there are recurrences. If you have really crappy luck, you could have an exit sign burn out every time you have a survey or something similar (can anyone say “improperly segregated compressed gas cylinder”?) but I would think that the little stuff is not going to drive a seriously negative survey result, with perhaps one exception.
The exceptional item (or items) are those in which the management of the care environment crosses into the realm of infection control and prevention: damaged/non-intact surfaces, stained ceiling tiles, etc. The reason for my concern with this stuff is it is really hard to manifest a solid process for managing these incidental conditions without hard-wired participation of point-of-care/point-of-service folks. I don’t know, I’m just having a hard time wrapping my head around taking issue with findings/conditions similar to those found in previous surveys. Now, if we’re talking widespread versus isolated, I can see widespread issues maybe pushing a survey in the wrong direction, but I still think the severity has to come in to play to some degree, as well as the (ever-present) potential for recurrence. To my mind, the stuff that gets broken/damaged tends to be because those are the things that suffer the most “abuse” (and I use that in the most general of meanings). It’s like the fire doors near the loading dock—tell me they don’t have a significantly greater potential for damage, during a survey or not.
At any rate, I think the important thing is to work diligently to ensure that those isolated findings are not the tip of a widespread iceberg. I don’t think we can just stop with what was cited anymore.
Next week, we’ll spend a little time with the “new” expectations relating to the management of workplace violence; I’m still trying to figure out if there’s anything that is truly “new” (I tend to think no, but you never know what might be hiding in the nuances), but we should at least start the discussion of where things seem to be going.
Hope you had a safe and festive Independence Day!
About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at stevemacsafetyspace@gmail.com.