Inspecting the inspectors: Could JCAHO’s deemed status face a threat?
Watchdog agency plans broad-based evaluation of accreditation process
Experts disagree on how a federal investigation of the Joint Commission on Accreditation of Healthcare Organizations will affect individual hospitals. But one thing is certain: The federal Office of the Inspector General (OIG) is speaking softly and carrying a big stick in the form of a threat to the future of the deemed status that Joint Commission accreditation provides.
The OIG, which serves as the watchdog agency for Medicare, has announced it will visit some hospitals along with surveyors from the Oakbrook Terrace, IL-based Joint Commission. The visits are part of a look at the accreditation process and its mission to assure quality care. Joint Commission officials have said they are not worried about the OIG’s efforts, but they also acknowledge they know little about what will be examined in the process.
While most experts say it is unlikely the Joint Commission will lose the deemed status its accreditation gives hospitals for Medicare, the mere threat to the agency’s core reason for existence is bound to have some effect on your hospital’s next survey.
Remember that the Joint Commission is the target of the investigation, not the hospital. OIG inspectors will likely have little to do with the actual survey process.
"For those few hospitals who get to play host to an OIG inspector along with the JCAHO surveyors, it may just mean they’ll have to order a few more lunch trays at meal time," says Patrice Spath, ART, BA, a consultant in health care quality and resource management in Forest Grove, OR. "They probably won’t feel the pressure of a more intensive survey."
But that doesn’t mean your hospital won’t feel added pressure from the Joint Commission, some experts say. In fact, some quality consultants are saying the Joint Commission could become defensive, triggering a sterner attitude among surveyors in all hospitals not just those visited by the OIG inspectors.
OIG simply reports findings
Spath notes that the survey process is fairly standardized, and it’s unlikely OIG inspectors will interfere with that process while on site. "The OIG has no action-taking authority," she says. (See related article on how the OIG operates, above.) When a serious deficiency is discovered in a government agency’s procedures or practices, such as the Medicare program’s decision to allow deemed status for Joint Commission-approved hospitals, OIG presents its findings to appropriate officials and suggests possible actions or procedural changes to decrease or eliminate the vulnerability.
Yet that very power held by the OIG the ability to call into question the Joint Commission’s approval by Medicare to provide deemed status gives this investigation ominous potential for your future surveys.
If the OIG finds the Joint Commission to be incompetent, its very existence would be threatened.
"The ultimate ramifications of this OIG investigation may be future changes in accreditation standards, the survey process itself, or more involvement by the Health Care Financing Administration to oversee health care quality issues affecting Medicare patients," Spath says.
Ben St. John, public affairs officer at OIG, declines to comment on what OIG will look for or whether the OIG’s presence will trigger inspection of hospital records or procedures not normally examined by the Joint Commission. He also declines to discuss whether the Joint Commission itself could face possible penalties.
Janet McIntyre, a Joint Commission spokes woman, says the commission isn’t concerned. While it is not unheard of for outside observers, such as representatives from state licensing bodies, to accompany inspectors on accreditation surveys, "we don’t know exactly where the OIG is going with this," McIntyre says.
McIntyre denies that the presence of OIG inspectors will make surveyors tougher on hospitals. She points out that surveyors use standardized information sheets "to help them make the same decisions at all hospitals they visit. The standards are what they are, and the surveyors are well aware of them."
Despite these uniform checklists, Judy Homa-Lowry, RN, MS, CPHQ, of Homa-Lowry Consulting in Canton, MI, notes there have always been variations in surveys because of the differing natures and experiences of the surveyors. "Because they’ll be monitored by an agency that has some questions as to the effectiveness of the survey process, it’s likely that surveyors would tend to ensure a tighter application of the standards," she says.
OIG officials expect their findings will yield "policy-level and operational recommendations aimed at an effective system of hospital quality oversight," says St. John.
The OIG plans to send investigators along on a minimum of four surveys between now and October. (See article on how this investigation may have come about, above.) The office remains circumspect in specifying the exact number of facilities to be visited, but a spokesperson confirms that at least one will be part of a national hospital system, such as the Nashville, TN-based HCA/Columbia chain.
During its evaluation, OIG inspectors will review Joint Commission documents, including trend data on facilities’ most recent deficiencies and survey scores. Also, inspectors will look at information about recent adverse events and responses to them.
The OIG outlined the scope of its probe in a memorandum to Dennis O’Leary, president of the Joint Commission. In it, the OIG stated that it is "seeking a deeper understanding of the current system of oversight for hospitals participating in Medicare [at a time when] patient harm in hospitals has become a frequent headline, calling into question the current system of oversight."
The nationwide inspection will focus on the accreditation of general acute care hospitals participating in Medicare. Specialty hospitals such as rehabilitation and psychiatric institutions will be excluded, the memorandum says. While the inspection will include the American Osteopathic Association, which also accredits hospitals for Medicare participation, and state licensing agencies, it will focus primarily on the Joint Commission, says St. John.
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