Accreditation & Regulatory Journal
August 2023

News You Can Use

August’s Compliance Tip of the Month

August’s compliance tip of the month is focused on the requirements around discharge planning evaluations. Specifically, the elements that need to be assessed during the evaluation and subsequently documented in the patient’s medical record. The CMS regulation is below for your reference.
Hospitals will frequently be cited during a survey for not adequately documenting a patient’s discharge evaluation. The evaluation must include:
  • The likelihood of a patient needing post-hospital care/services
  • The availability of those services
  • The likelihood of a patient’s capacity for self-care or of the possibility of the patient being returned to the pre-hospital environment.
Organizations are required to perform the evaluation, document the results and then to share them with the patient or their representatives. The evaluation should occur early in the admission to allow adequate time for planning.
CIHQ encourages organizations to evaluate their documentation mechanisms to assure that they comply with the regulations in order to avoid a deficiency during survey.
CMS
§482.43 Condition of Participation: Discharge Planning
§482.43(a)(1) Standard: Discharge Planning Evaluation
  1. Any discharge planning evaluation must be made in a timely basis to ensure the appropriate arrangements for post-hospital care will be made before discharge and to avoid unnecessary delays in discharge.
  2. A discharge planning evaluation must include an evaluation of a patient’s likely need for appropriate post-hospital services, including, but not limited to hospice care services, post-hospital extended care services, home health services, and non-health care services and community-based care providers, and must also include a determination of the availability of the appropriate services as well as of the patient’s access to those services.
  3. The discharge planning evaluation must be included in the patient’s medical record for use in establishing an appropriate discharge plan and the results of the evaluation must be discussed with the patient (or the patient’s representative).
There are tools available to CIHQ accredited and ARS member organizations to assist with compliance:
Resource Library:
#1043 – Form – Patient Discharge Planning Evaluation & Plan
#3063 – Form – Selection of Post-Acute Care Hospitalization Provider
#2402 – Policy – Discharge Planning

CIHQ Now a CMS Approved Accrediting Organization for Critical Access Hospitals

On May 22, 2023 CMS published the approval of the CIHQ Critical Access Accreditation Program. This was the initial application and is applicable from June 1, 2023 to June 1, 2027. CIHQ is extremely grateful to the facilities that acted as our pilot survey and to Frio Regional Hospital that graciously allowed us to conduct our observation survey with CMS in attendance. You can find this exciting announcement in the Register at https://www.federalregister.gov/agencies/centers-for-medicare-medicaid-services

CIHQ Applications to CMS as an Accrediting Organization and Expansion of Accreditation Programs - Update

CIHQ is expanding its accreditation programs to Acute Psychiatric Hospitals. The application has been approved and the virtual office review has been completed. The final decision to accept the application was published in the Federal Register on May 22, 2023. We are excited about welcoming Acute Psychiatric Hospitals to the CIHQ family of accredited organizations. You can find this exciting announcement in the Register at t https://www.federalregister.gov/agencies/centers-for-medicare-medicaid-services
  • Next steps will be the standards and process review. We have completed the five pilot surveys and wish to thank them for allowing us to pilot our process in their hospital.
    • Griffin Memorial Medical Center
    • SD Human Services Center
    • Adventist Health Vallejo
    • East End Behavioral Health Hospital
    • Glendora Hospital – A College Behavioral Health Hospital
  • A virtual office review was conducted from June 21 – 23, 2023
  • An observation survey will be conducted this summer. A huge thank you to the State of Oklahoma and Northwest Center for Behavioral Health for volunteering to be our CMS observation survey.
  • Publication in the Federal Register will occur on or by October 19, 2023

CIHQ Accreditation Survey Top Findings January 1 – June 30, 2023 – Publication Correction from the July Edition

This article appeared in the July edition of the journal and it was incorrect. Please refer to this article when looking for the top condition-level deficiencies. CIHQ analyzes findings cited during accreditation surveys in order to track and trend the top findings. We do this primarily to evaluate whether or not ARS is supplying sufficient and effective resources to assist our facilities with compliance. This also guides the decision to add more tools and resources in order to facilitate compliance. This tracking is also used to evaluate the quality and consistency of how standards are applied and cited.
Below are the top condition-level deficiencies cited during the first half of 2023.
CIHQ Standard Number Title Level of Severity Percentage Cited at Condition-Level
GL-04 Leadership Responsibilities Condition
*Note this standard is cited when condition-level deficiencies are cited regardless of the standard cited
34%
CE-18 Fire Drills Condition17%
CE-19 Inspection & Testing of Life Safety Systems Condition17%
CE-15 Compliance to the NFPA Life Safety Code Condition17%
MM-28 Administration of Medications Condition14%
IC-07 Disinfection & Sterilization Practices Condition14%
CE-14 Emergency Powered Battery Lighting Condition14%
NS-03 Delivery of Nursing Care Condition11%
IC-03 Infection Control Prevention & Control Policies Condition11%
RB-01 Rehabilitation ServicesCondition 9%
Below are the top standard-level deficiencies cited during the first half of 2023.
CIHQ Standard Number Title Level of Severity Percentage of Surveys Cited at Standard-Level
CE-15 Compliance to the NFPA Life Safety Code Standard 83%
MR-05 Minimum Content of the Medical Record Standard 74%
IC-03 Infection Prevention & Control Policies Standard 69%
CE-21 Compliance to the NFPA Health Care Facilities Code Standard 66%
CE-10 Management of Utilities Standard 65%
CE-13 Testing of Emergency Power Systems Standard 63%
CE-03 Provision of a Safe Environment Standard 60%
HR-04 Management of Contract/Volunteer Staff Standard 42%
HR-03 Competency of Staff Standard 40%
GL-04 Leadership Responsibilities Standard 40%

Upcoming Conferences and Sponsorships

 
CIHQ’ own Billy Kinch will be presenting at ASHE as part of the 60th Annual Conference & Technical Exhibition. This conference brings the entire healthcare facilities management profession together for discussion-based sessions and innovative networking opportunities. This is the first time we CIHQ has been invited to speak at ASHE; Billy will provide an update on CIHQ’ adventures and share top findings in the physical environment.

Discovery, connection, and enrichment
Healthcare and community care professionals from across the continuum attend CareForum every year because it offers unmatched opportunities to learn from the industry’s top experts and gain skills to take back to their organizations and put into action.
CareForum is attended by more than 1,000 healthcare executives and leaders from various end markets across health and community care.
CIHQ to Speak at WellSky’s Care Form
Richard Curtis, CEO was accepted to speak at WellSky’s Care Forum in Austin, September 10-13. He’s speaking on Monday, September 11th on Collaborating with the Medical Staff for Successful Regulatory Compliance.

2023 Fall Educational Conference & Expo
CIHQ appreciates the work of rehabilitation hospitals, and will be attending AMRPA’s conference October 15-18, 2023 in Dallas. AMRPA hosts an IRF Boot Camp before the conference to provide rehabilitation managers and medical directors with fundamental knowledge.
The conference program will focus on innovative strategies to keep rehabilitation professionals ahead of the curve and providing the highest quality of care, advocacy efforts in the interest of inpatient rehabilitation hospitals and units, outpatient rehabilitation centers, and other rehabilitation providers.
CIHQ Sponsors the Annual Scrub Ball in Dallas
Scrub Ball is an annual conference and event hosted by SIPS Consults to celebrate healthcare heroes. Sterile Processing professionals are responsible for preparing medical and surgical instruments, one of the most vital contributors to the delivery of safe, high-quality patient care. Frontline professionals were honored over three days of education, networking, and fun events.
Below are two of the featured speakers:
Vangie Dennis, Assistant Vice President of Perioperative Services at AnMed Health and Immediate Past President of AORN spoke about Overcoming Challenges: Leadership Champions. Always conscientious in ensuring adherence to standards of practice, Vangie discussed how effective leadership comes from relational success. As new nurses enter the field, she encouraged them to be patient in developing competencies – it’s not done overnight.
Anthony Bondon, HSPA President Elect, shared on education, personal development, professional growth, and patience all tie together for stronger teams.