October, 1999
E-mail Newsletter

Swain & Associates
Charlotte, NC
www.snaconsulting.com
Paula@snaconsulting.com

Dear Colleague:

We have two masters - JCAHO with accreditation issues and the Office of Inspector General OIG! Their separateness is waning - the work we is required by both groups. Below are some tools that meet the expectations of both!

Over and over the JCAHO and HCFA’s validation surveys, Corporate Compliance requirements, the PRO’s sixth scope of work and the Workplan by the OIG are sounding the same. Here are some examples that describe the overlay.

For example:

1. At a JCAHO conference with a focus on how to comply with the OIGs recommendations, and some "challenging standards from 1999" (see #1).

A. The OIGs basic findings showed "the JCAHO surveys... are unlikely to detect substandard patterns of care or individual practitioners with questionable skills." (see #2)

B. JCAHO’s response to the OIG’s findings include:

-Unannounced surveys will be happening more frequently and with secret topics. I just reviewed two facilities unannounced schedules by two different surveyors and found one went for the Environment of Care issues, the other went for Board reporting of issues and medical staff credentialing.

-The medical record review has been changing. Two years ago the required "open chart review" called Point of Care review was required, but not surveyed very hard. Now however, all records will be reviewed on the floor with the surveyors and staff. Try picking the best of those records - impossible. That’s the idea. A patient who made their way through the OR without an H&P will be spotted immediately. There is a new form that shows the facility trends over time - the surveyors will carry that form and add their findings to it.

Incidentally, the closed chart review will simply review things that are available 14 days post discharge. There will only need to be 10 charts to show those patterns.

• Listen and watch for a lot more interviews requested from patients and staff during the survey. This is in response to the greater need for accountability. The surveyors will be more responsive to complaints. This is disruptive in a survey, but will be added to a survey schedule. Administration will not be part of the complaint interview.
• Improvement efforts are under scrutiny. The OIG recommends "more rigorous review of hospitals’ continuous quality improvement efforts". This review through the leadership standards will provide the window. The Leadership standard #4 is all about effectiveness - PI standard #5 is all about improvement occurring. Programs that show monitoring of quality controls versus projects, and no follow-up with the statistical decision making processes will be hard pressed to demonstrate either - effectiveness or improvement.

There is a lot more about the "Accreditation Process Improvement Initiative" that is underway at the JCAHO contained in their document "Inside Perspective" July, 1999. (See #3)

2. The recent National Association for Healthcare Quality conference in Atlanta was directing us toward outcomes and performance measures. Both keynote speakers directed us to more knowledge based management. Through this knowledge - accountabilities and business decisions can be made.

For example on keynote speaker, Dr. Ware described

• The under treatment of depression is costly and adds a chronic component to most other diseases. A simple survey, completed by the patient at the web site (#4) and carried to the doctor, can show this information to the physician without difficulty.

The survey has been through all the metrics that make it reliable and valid. Think about throwing this tool into the Departments of Surgery, Medicine and Family Practice. Ask them to answer the performance measure - "How often do we assess for depression?" or "How do we know we are effectively treating depression?" Take the survey yourself and find out your functional and emotional levels, then store them In your personal notebook - it is quite eye-opening!

• Sharing data with physicians, administrators and others allows for greater "out of box" thinking, generates innovation and lets the creative juices flow. I am using a site with physician groups that is highly successful in showing that improvement can be replicated. (see #5) Susan Horn, the research expert has a site that shows her research topic, quantifiable sampling and the implications to care, dollars and the community. The data speaks for itself and begs answering the question, "How do we do it?"

For example in the management of surgical prophylactics and polypharmacy in the elderly are described in depth, ready for your use.

3. Finally, do not miss the instruction provided by the OIG for their Workplan (see #6) for 2000. Included in it are many initiatives that should be your initiatives, since that is how you will be judged, for example:

* One-day hospital stays - 10% of all Medicare patients admitted are released the following day;

* Prospective Payment System Transfers - finding over payments of hospitals reporting transfers;

* Medicare Payment for DRG 14 - identify hospitals with high billing patterns for the DRG (Cerebral vascular disorders)

* Billing routine services on a "stat" basis.

Using the information above, I have compiled skills development sessions to enhance your facility’s improvement processes. By addressing these tasks and tools onsite, I can assist you in maintaining compliance with your Accreditation and Corporate Compliance endeavors.

Best Wishes,
Paula Swain

Sites referenced

(#1 at www.snaconsulting.com/whatsnew.htm)
(#2 the entire report is available at www.hhs.gov/progorg/oig/other/jcahco.htm)
(#3 the JCAHO site www.jcaho.org/tip/tip9907.html)
(#4 www.amIhealthy.com)
(#5 www.isisicor.com)
(#6 www.hhs.gov/oig/wrkpln/index.htm)   Note: you need Adobe Acrobat to read this one

Swain & Associates offers workshops detailing the Fraud and Abuse issue. For more information call 1-800-843-6449 or E-mail us at Info@SnAConsulting.com.