Accreditation & Regulatory Journal
January 2024

News You Can Use

Compliance Tip of the Month

Provided by Cheri Benander, RN, CHC, C-NHCE – HealthTech
January’s compliance tip of the month is focused on the revised CMS guidance in “Appendix A” regarding the patients right to receive care in a safe setting. The standard outlines the requirement that psychiatric patients who are cared for in non-psychiatric settings must be evaluated, monitored, and cared for appropriately. The hospital is required to identify risks associated with the patient harming themselves or others and mitigate any environmental safety risks.
Surveyors will review policies, procedures, the physical environment, incident/accident reports, and interview staff to ensure that security protections are in place and that staff are trained to identify and report any risks identified.
The revised CMS regulation is listed below for your reference.
CMS
A-0144
(Rev. 216; Issued:07-21-23; Effective: 07-21-23; Implementation: 07-21-23)
§482.13(c)(2) – The patient has the right to receive care in a safe setting.
Interpretive Guidelines §482.13(c)(2)
The intention of this requirement is to specify that each patient receives care in an environment that a reasonable person, similarly, situated as the patient, would consider to be safe. For example, hospital staff should follow current standards of practice for patient environmental safety, infection control, and security. The hospital must protect vulnerable patients, including newborns and children. Additionally, this standard is intended to provide protection for the patient’s emotional health and safety as well as his/her physical safety. Respect, dignity, and comfort would also be components of an emotionally safe environment. To provide care in a safe setting, hospitals should identify patients at risk for intentional harm to self or others, identify environmental safety risks for such patients, and provide education and training for staff and volunteers. Patients at risk of suicide (or other forms of self-harm), or who exhibit violent behaviors toward others, receive healthcare services in both inpatient and outpatient locations of hospitals. Therefore, non-psychiatric settings of all hospitals where patients with psychiatric conditions may be cared for should also identify patients at risk for intentional harm to self or others and mitigate environmental safety risks. Psychiatric patients requiring medical care in a non-psychiatric setting (medical inpatient units, ED, ICU, etc.) must be evaluated, monitored, and cared for appropriately when demonstrating suicidal ideation or potential harm to others. The care could include, but not be limited to, utilizing safety measures such: as 1 on 1 monitoring with continuous visual observation, removal of sharp objects from the room/area, or removal of equipment that can be used as a weapon.
Although all risks cannot be eliminated, hospitals should be able to show how they identify patients at risk of self-harm or harm to others as well as steps they are taking to minimize those risks in accordance with nationally recognized standards and guidelines.
The potential risks include, but are not limited to, those from ligatures, sharp objects, harmful substances, access to medications, breakable windows, accessible light fixtures, plastic bags (for suffocation), oxygen tubing, bell cords, etc.
Hospitals may find the recommendations and resources in the 2018 report, Recommended standard care for people with suicide risk: Making health care suicide safe, issued by the National Action Alliance for Suicide Prevention (Action Alliance), to be highly useful in developing the best practices for effective patient screening and assessment for those patients at risk for harm to themselves, as well as for improving the care of patients at risk of suicide. 1 The Action Alliance is the public-private partnership working to advance the National Strategy for Suicide Prevention and reduce the suicide rate 20 percent by 2025. Notably, the report advances two of the goals of the National Strategy for Suicide Prevention (National Strategy): (a) Promote suicide prevention as a core component of health care services; and (b) Promote and implement effective clinical and professional practices for assessing and treating those identified as being at risk for suicidal behaviors. (To download a copy of the National Strategy, please visit: www.actionallianceforsuicideprevention.org).

CMS Launches New/Improved Validation Process

In a memo published on September 6, 2023, CMS announced its intention to resume the performance of accrediting organization validation surveys under a new and improved process. The validation surveys were to begin with the 2024 fiscal year (October 1, 2023).
The memo went on to state that the validation surveys, now called Direct Observation Validation Surveys, will be conducted by two national survey contractors: HMS for health & safety and Ascellon for life safety. The contractor role is only observation of the accrediting organization.
For more information, you can access the QSO Letter – Admin Info: 23-14-NLTC at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/administrative/resuming-validation-accrediting-organization-surveys
CIHQ underwent the first validation survey in October 2023. The overall experience was very well received. The contractors were collegial and did not interject themselves into the survey process. Coordination and collaboration between the contractors and CIHQ surveyors was efficient and effective.
The observers used tools published by CMS in order to guide the observation. These tools were made available to CIHQ, and the surveyors were oriented to the content and instructed to use them to aid in the Direct Observation Validation Survey process.
The CMS/AO Hospital Observation Worksheet was completed by the contractors and sent to CIHQ on December 18, 2023. Our survey team was amazing, and the Validation Survey results we received are outstanding; CIHQ received an overall score of 97.91%. We are extremely pleased with our score and the new process and believe it will more accurately reflect the ability of the accrediting organizations to follow survey and certification procedures.
Below is a few of the comments that CIHQ received from the observers:
“The AO team was very detailed in their review of all hospital systems, the CoP's and records.”
“The CIHQ team were well prepared and worked well together. They spent a lot of time discussing standards vs conditions vs compliance.”
“The HMS contractors agreed with their decision making and were impressed with their thorough and impressive surveying style.”

CIHQ 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 approval decision was published in the Federal Register on October 2, 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 https://www.federalregister.gov/documents/2023/10/02/2023-21724/medicare-and-medicaid-programs-application-from-the-center-for-improvement-in-healthcare-quality-for
Will you be the first acute psychiatric hospital to be accredited by CIHQ? You can open and account and apply today at CIHQ.org click on “Hospital Programs – United States”, select “Acute Psychiatric Hospitals” and then “Apply for Accreditation” in the blue navigation bar or click HERE. Our standards, policies and survey activity guide are available free of charge and can be found on our website.

Conferences and Sponsorships

CIHQ Announces Plans for 2024 Accreditation & Regulatory Summit
The 2023 CIHQ Accreditation & Regulatory Summit was a HUGE success. It was the largest summit in our history with over 500 in attendance. If you attended, then I am sure that you would agree that it was a great event and valuable to all. If you were not able to attend, then know you were missed.
Everyone, hang on to your hat as we unveil the plans for the 2024 summit! CIHQ is inviting you to help us celebrate our 25th Anniversary Jubilee. Yes, CIHQ will be a quarter of a century old in 2024 and we plan to throw a Texas-sized conference and celebration.
Save the dates: September 24 – 26, 2024
Location: San Antonio, Texas at Pedrotti’s Ranch
The summit will be packed full of relevant topics in the accreditation and regulatory environment. In addition, we are planning to make this the most fun conference you will attend all year. The theme will be a 25th Jubilee Texas style complete with encouragement to dress western (optional) and attend our complimentary rodeo show. Education and fun will be had by all.
In celebration of our 25 years in business we will be hosting a game session during which participants will be teamed up to see who knows the most about CIHQ and its 25-year journey. You may feel you are at a disadvantage. Fear not!
Beginning in January, there will be facts about us published each month in our CIHQ Accreditation & Regulatory Journal. The facts will be in different locations inside of the Journal, but will all be housed in a box with a game-themed border. Below is an example of the border. Search the Journal to learn interesting facts. At the Summit, teams will compete against each other for the level of knowledge and the team that knows the most will win a fun and exciting prize. See below for clues #1 and #2. Beginning in February the bordered box below will be traveling to different pages of the Journal.
Stay tuned in to your journal for facts and fun about us! We can’t wait to see all of you at the Summit! More Summit information will be sent as it is finalized and made available. This is the event that you won’t want to miss!

CIHQ Provides HACP Course in Person to Kentucky Hospital Association Members

The Kentucky Hospital Association (KHA) provided scholarships and invited Rick to teach the Healthcare Accreditation Certification Program (HACP-CMS) to two cohorts in November and December, 2023. CIHQ would like to thank KHA for the opportunity, and congratulations to each cohort! We appreciate the feedback received and would like to welcome each of them to HACP!
“Great educational course, Rick was great! Thank you to KHA for providing this and scholarships!”