Follow us on Twitter Friend us on Facebook Look for us on Google Plus Share with your Friends Print this Page
Friday 3:57 CST, April 18, 2014

Blog Detail Page

Musings...Ambulatory Patient Safety

RSS Feed RSS By: Michael Kulczycki, Ambulatory Health Care

The musings of a healthcare executive – concerned about patient safety in ambulatory settings –  who writes about the industry…..accreditation & safety issues, customer trends, stakeholder news, and developments at The Joint Commission, the nation’s largest accrediting body.

Desperately Seeking (Urgent Care) Patients?

Apr 15, 2014 | Comments (0) | 340 Views

danderson_title_blogSpring is in the air, bringing with it a renewed sense of how urgent care organizations can set themselves apart from others.

Having just returned from the Urgent Care Association of America’s (UCAOA) spring conference in Las Vegas, I was struck by the effort physicians and urgent care leaders are exerting dealing with the fact that they’re now in two businesses: providing healthcare services and working in a retail environment. 

I decided to jot down some great ideas and resources to help urgent care organizations think like retailers:

  • Sell yourself: It’s doubtful that medical school taught location scouting; pro forma budgeting; or how to talk to bankers, partners, spouses, rich uncles, etc. about capital needs. Luckily, there are resources available for the harried operator. Here’s a link to a healthcare management guru, which readers may find useful. Two other self-help marketing resources are UCAOA’s website and Tom Charland’s information-filled site, Merchant Medicine.
  • Sell your services: There are compelling reasons for operators to market occupational health services.  From the provider side, there is service capacity, access, and relatively straight-forward DOT certifications.  Plus, targeted outreach to employers can be easy to organize and achieve. From the employer side, the pluses are service, convenience, known costs, and a service point-of-contact.  In short, a win-win for both parties. How can an operator approach occupational medical services? Read the "Selling Wellness Services to Employers" from the April 2010 issue of the Journal of Urgent Care Medicine.
  • Sell your value proposition: Take the time to stop and reflect on how accreditation can bring value to your organization and how you pass that value on to your customers. It’s obvious that accreditation is a badge of distinction for the urgent care provider. It’s a no-nonsense commitment to the provision of quality care, and it helps the provider get organized to boot. The leading urgent care organizations are increasingly recognizing the quality proposition and organizational value of getting accredited.


Have more questions? The ambulatory care business development staff of The Joint Commission would be happy to chat with you; just call us at 630.792.5286. You can also find further information on how to become accredited on our website.

Focusing on Provider-Performed Microscopy Procedure Requirements for Ambulatory Health Care

Apr 01, 2014 | Comments (0) | 487 Views

Do you find the laboratory Clinical Laboratory Improvement Amendments (CLIA) requirements for ambulatory health care a little confusing? 

olea-blogThere certainly are some gray areas. So we asked Stacy Olea, field director for the laboratory and ambulatory health care programs, to provide some clarity on the requirements for organizations that have Certificates of Provider-Performed Microscopy Procedures (PPMP).

First things first; let’s look at the basics. A Certificate of PPMP permits an organization to perform a limited list of moderate complexity tests, as well as any waived tests.  The PPMP procedures must be performed on a specimen obtained during the patient’s visit and testing can only be performed by a physician, a mid-level practitioner, or a dentist.  The instrument for PPMP is a microscope limited to a bright-field or phase-contrast microscopy. 

Some of the more common PPMPs are:

  • All direct wet mount preparation for the presence or absence of bacteria, fungi, parasites or cellular elements
  • All potassium hydroxide (KOH) preparations
  • Urine sediment examinations
  • Qualitative semen analysis limited to the presence or absence of sperm and detection of motility

OK, now that that’s out of the way, let’s start to clarify some of those confusing points. 
According to Olea, because PPMP’s are considered moderate complexity tests, anyone performing these tests must undergo an annual competency assessment that uses the six methods of evaluation required by CLIA. All methods should be used unless they are determined to be not applicable to the test. The six methods include the following:

  1. Direct observations of routine patient test performance, including patient preparation, if applicable, and specimen collection, handling, processing, and testing;
  2. Monitoring, recording, and reporting of the test results;
  3. Review of intermediate test results or worksheets, quality control, proficiency testing, and preventative maintenance performance;
  4. Direct observation of performance of instrument maintenance function checks and calibration;
  5. Test performance as defined by laboratory policy (for example testing previously analyzed specimens, internal blind testing samples, external proficiency, or testing samples); and
  6. Problem-solving skills as appropriate to the job.

PPMP_Blog_ImageCredentialing and privileging is not an acceptable substitute for a competency assessment.  It would be a good practice to include the review of successfully completed annual competency as a part of the credentialing and privileging process. In addition to an annual competency assessment, the organization must meet all the applicable requirements of participation in proficiency testing, patient test management, quality control, and quality assurance. 

Note that if your organization only has a Certificate of PPMP no laboratory survey is required, but your organization is still responsible for following all CLIA regulations. If you have a moderate or high complexity CLIA certificate, then your PPMP is surveyed under the Comprehensive Accreditation Manual for Laboratories and Point of Care Testing

Need more information? Reach out to Standards Interpretation Group at 630.792.5900, Option 6, then Option 2 and ask to speak with staff in the ambulatory health care or laboratory programs.

*The Centers for Medicare & Medicaid Services (CMS) regulates all laboratory testing (except research) performed on humans in the U.S. through the Clinical Laboratory Improvement Amendments (CLIA).  

Guest Blogger John Maurer: Asked & Answered – Questions from Ambulatory Care Conference Attendees

Mar 20, 2014 | Comments (0) | 976 Views

ahc_conf2013Today’s blog post is the fourth in a series of posts of questions and answers from the JCR Annual Ambulatory Care Conference of November 2013. The Joint Commission panel of ambulatory experts responded to these questions regarding compliance issues during sessions held at the conference.

This fourth installment continues a focus on environment of care.  We’re happy to welcome back John Maurer, SASHE, CHFM, CHSP. A member of The Joint Commission’s Department of Engineering, John provides support for customers seeking insights specific to the ambulatory care environment.

Q: Some Community Health Centers (CHCs) have school-based programs.  What advice does The Joint Commission have for school-based programs in order to be compliant with the emergency management standards?

A:  While the emergency management standards apply organization-wide, the planning activity should take into account site-specific locations (such as school-based programs) and the challenges each may present based on the organization’s analysis.  Recent challenging requirements are based on leadership participation when developing the emergency management plan (EMP) in addition to understanding and documenting the role the organization may have with the community.  When performing exercises, it is helpful that attention be given to the notes in the elements of performance (EPs) in EM.03.01.03.  When response activity is evaluated for exercises and actual events, be sure to include the multi-disciplinary team in the organization (or all staff that had responsibility during the exercise or event) to effectively critique the response.  Any modifications to the plan must be exercised in subsequent exercises.

mauer-blogQ: We are a business occupancy health care organization that will not be a receiving station for disasters.  Are we required to conduct drills for utilities (e.g., a power outage) if that is a vulnerability according to our hazard vulnerability assessment (HVA)?

A: EM.03.01.03, EP 2 discusses the exercises required for organizations that are community-designated disaster receiving stations.  This notes that an influx of simulated patients is required and if the organization is not a community-designated disaster receiving station, this EP will not apply.  There is no exemption for utilities systems, or other risks, that may be identified in the HVA.

Q: We have two sites.  One site provides primary and specialty care.  The other site provides outpatient psychiatric services.  Must we include the psychiatric clinic in the influx drill?

A: The need to include the psychiatric clinic in a required exercise for an influx of simulated patients should be determined in your EMP.  Exercises are expected to be developed in accordance with the potential emergencies, or HVA, that may impact a facility and additional locations.  If an organization’s EMP specifies actions for the ancillary site(s) when an emergency impacts the primary site, The Joint Commission would expect the organization to respond according to the plan and demonstrate the plan was initiated and acted upon accordingly.

Q: In organizations large enough to empower an emergency preparedness committee to administer the emergency management programs, do members of this group (typically the director and senior director) meet The Joint Commission’s definition of “leaders” or are “leaders” limited to chief or vice president level in the context of developing an HVA and subsequent plans?

A:  The Joint Commission defines a leader as “an individual who sets expectations, develops plans, and implements procedures to assess and improve the quality of the organization’s governance, management, and clinical and support functions and processes.  At a minimum, leaders include members of the governing body and medical staff, the chief executive officer and other senior managers, the nurse executive, clinical leaders, and staff members in leadership positions within the organization.”  Unless specifically stated, the definition allows for the organization to define who the leaders are for an organization.

Q: We noticed our EMP does not include a process for an “active shooter” and training, mock event, etc.  Does The Joint Commission have resources to get us started?  Should “active shooter” situations be covered in EMPs?

A: Joint Commission Resources (JCR) provided articles in the April and August 2013 issues of The Joint Commisson’s EC News relative to the risks associated with an “active shooter.”  Other useful resources for organizations to use are the local law enforcement to help develop strategies for safeguarding and response in addition to Homeland Security that provides suggestions.  To determine if the risk should be addressed in the EMP, organizations should start with the HVA to determine the level of risk.  If this issue ranks high up on an organization’s HVA risk level, the organization should take additional steps to develop plans to safeguard against the potential for an “active shooter.”

Q: Is there a recommendation on where to find the best HVA template or something that can be used to develop a really useful and comprehensive HVA?

A: The Joint Commission offers The Leading Practice LibraryTM to accredited customers that may offer a sample HVA form that organizations can use to develop their own form.  Other sources to pursue that may be useful are in publications available through JCR relative to emergency management or asking nearby health care organizations for samples they may be willing to share.

Have more questions? Additional questions may be submitted to The Joint Commission Standards Interpretation Group by calling 630-792-5900, Option 6, then Option 2, or by submitting a standards question submission form.

Guest Blogger Pearl Darling: Ambulatory Settings Applying the “Golden Rule” in Adverse Events

Mar 04, 2014 | Comments (1) | 1014 Views

darling-p1aAmbulatory practices face many challenges every day. While they all strive to provide safe, efficient care, there are times when things just go wrong. The key is to take ownership of the situation and ensure a transparent process to address it immediately. Think about your own health care experiences and the vulnerability you feel when things are not being communicated to you. Treat your patient exactly how you would like to be treated.

An article in the February 2014 issue of The Joint Commission Journal on Quality and Patient Safety, “Doing Right by Our Patients When Things Go Wrong in the Ambulatory Setting,” highlights important guidelines for responding and communicating adverse events. The “PROMISES” project (Proactive Reduction of Outpatient Malpractice: Improving Safety, Efficiency, and Satisfaction) focuses on promoting disclosure and apology practices for ambulatory practices in responding to adverse events.


Key components of PROMISES are: 

  • Immediately disclose the situation
  • Ensure patient receives appropriate care or treatment
  • Empathize with your patient and his/her family
  • Follow up and follow through
  • Support your colleagues

journal_screenshotThe Journal article also provides the following patient communication techniques, as simple as:

  • Being attentive
  • Listening actively
  • Apologizing

ahc-blog-darling1The project’s sponsors are intending to disseminate this work to other practices via a large network of health insurers, independent physician organizations, and non-profit and advocacy organizations.

Following these sensible tips can go a long way to improving how adverse communications are perceived by your patient.

Tell us what you think.


Guest Blogger John Maurer: Asked & Answered – Questions from Ambulatory Care Conference Attendees

Feb 20, 2014 | Comments (0) | 1148 Views

ahc_conf2013Today’s blog post is the third in a series of posts of questions and answers from the JCR Annual Ambulatory Care Conference of November 2013. The Joint Commission “panel of ambulatory experts” responded to these questions regarding compliance issues during sessions held at the conference.

This installment focuses on the ‘environment of care.’ To answer our customer’s questions, we welcome guest blogger, John Maurer, SASHE, CHFM, CHSP.  A Joint Commission staff engineer, John provides support for customers seeking insights specific to the ambulatory care environment and is a member of The Joint Commission’s Department of Engineering.

Q:  Are there any standards regarding keeping the anesthesia equipment on all day and changing the equipment filter between each case?

A:  There are no standards that address how long anesthesia equipment may be kept on.  Changing filters on equipment and other maintenance activities would be defined by the manufacturer and should be defined in the policies governing inspection and maintenance activity, per EC.02.04.01 and implemented in accordance with EC.02.04.03.

mauer-blogQ:  What are the challenges with generators?

A:   One challenge The Joint Commission often sees is with the documentation required in EC.02.05.07.  This is relative to generators and automatic transfer switches (ATSs) and how they are maintained in ambulatory settings. Generators are expected to be tested at least monthly for a minimum of 30 minutes under whatever the connected load to the generator is for the facility.  This applies to any type of generator that is being used to supply emergency power in accordance with the elements noted in EC.02.05.03. Some organizations have self-testing generators that will conduct the necessary tests automatically, which is acceptable.  Other organization may use a service company to perform the required tasks.  Regardless of the method used to perform the required inspection and testing of generators, the information must be made available to the surveyor(s) at the time of survey. 

Q:  Does The Joint Commission have a job description for a safety officer, infection control officer, or a performance improvement officer?

A:  The Joint Commission expects organizations to define qualifications and competencies based on the needs and services provided.  Please see the HR chapter (HR.01.02.01) for further information regarding this topic.

Q:  If an ambulatory care center does its laundry in-house, what guidelines do you recommend we follow?  Also, do you recommend inspection? If so, by whom?

A (on guidelines): 
Many organizations have their own laundry service.  Design and engineering issues are addressed in the 2010 edition of the “Guidelines for Design and Construction of Health Care Facilities,” section 3.1-5, as administered by the Facilities Guidelines Institute (FGI).  This applies to new, renovated, or altered spaces as referenced in EC.02.06.05, EP 1, however, and existing spaces should be maintained as they were designed.  FGI recommends the hot water for laundry service to be 160oF, with provisions that may allow for lower temperatures ). 

A (on inspections):  A maintenance and inspection program is required per EC.02.05.01 and EC.02.05.05, and should be developed by using evidence-based guidance, such as the Center for Disease Control’s “Guidelines for Environmental Infection Control in Health-Care Facilities,” 2003 edition, and the equipment manufacturer’s recommendations.  As to ‘who performs the maintenance and inspection?’ this should be determined by the organization, which may choose to use a combination of staff and equipment vendors, for example.


This website is certified by Health On the Net Foundation. Click to verify. This site complies with the HONcode standard for trustworthy health information:
verify here.