TJC communication standards in full force
But many hospitals unaware, and unprepared
It happened six months later than first expected, but on July 1 organizations became responsible for meeting the requirements of the standards for patient-centered communications, Advancing Effective Communication, Cultural Competence, and Patient- and Family-Centered Care: A Roadmap for Hospitals. An exception was the visitation standards, which went into effect July 1, 2011. While the added time was probably a blessing for many hospitals, others are probably still not ready to be held to account for all the aspects of the standards, says Sue Dill Calloway, RN, MSN, JD, a nurse attorney and President of Patient Safety and Healthcare Consulting and Education.
While some of the issues that organizations face may be technical in nature — for instance, the race and ethnicity collection requirements were required for both inpatients and outpatients, and that may have caused trouble with creating a process that worked for both sets of patients — there are parts of the standards that Calloway believes are just not completely understood. There are currently five standards in four different chapters of the Joint Commission manual that make up the patient-centered communication standards. These were previously referred to as the patient providers communication standards.
One example, she says, is that human resources departments need to make sure that all interpreters used by the hospital — whether employees or not — are qualified to interpret in a healthcare setting. "If you are fluent in Spanish, that doesn't mean you are qualified to be an interpreter, and the Office of Civil Rights says that unless it is an emergency situation, you can't use a child or family member to translate for you," she says.
What makes someone qualified? For example, a deaf interpreter for a hearing impaired patient would need to be certified. A person takes a 40-hour course and passes it. This person would be qualified to be a Spanish interpreter. There are two organizations that offer an oral and written test so the qualified interpreter can become certified. Competency is a different issue from being qualified. The standards demand that you determine the competency of the translators yourself, or by using a service to determine that they have proficiency in English and the desired language of translation. (For a list of resources related to interpreter services, see box, below.) It used to be there was only a certification program for Spanish, but now they are available for other languages, and the number is growing.
Resources related to health care translation services • American Translators Association — http://www.atanet.org. • List of state interpreter association websites — www.ncihc.org/mc/page.do?sitePageId=57031 • Certification Commission for Healthcare Interpreters — http://www.healthcareinterpretercertification.org. • International Medical Interpreting Association — http://www.imiaweb.org. • National Board of Certification for Medical Interpreters — http://www.certifiedmedicalinterpreters.org. • National Council on Interpreting in Health Care — http://www.ncihc.org. • Registry of Interpreters for the Deaf — |
Calloway, who conducts webinars on this subject regularly, says she still gets questions on collecting race and ethnicity information. "Some organizations don't understand that this is about self-reporting ethnicity by patients," she says. "If they say they are white and Italian, even if they never lived in Italy and we don't consider Italian an ethnicity, we have to allow them to do that."
Related to the ethnicity information you collect, Calloway says if you find you have a particular percentage of patients who need help in a particular language, you will have to have some of your documents translated for them. "If you have 5% of your population reporting as Hispanic or some other ethnicity, or at least 1,000 patients speaking a language, you will want to translate particular documents." The Joint Commission's Roadmap for Hospitals related to these standards (available at http://www.jointcommission.org/assets/1/6/ARoadmapforHospitalsfinalversion727.pdf) lists the following documents as vital:
- informed consent documents;
- complaint forms;
- information on free language assistance programs and services;
- notices of eligibility criteria for, rights in, denial or loss of or decrease in benefits or services;
- intake forms that may have clinical consequences.
The above would be among the documents you would want to have in any language that a significant number of your patients speak.
CMS's hospital transmittal on visitation was published on Dec. 2, 2011, and it was 34 pages long.
The standards on visitation are put forth in 34 pages that Calloway still shakes her head at. Despite her constant study of it, she says it is difficult to understand and could easily confuse the brightest and most competent of people. "My mom had surgery. She is competent, but my sister was her patient advocate/support person — there to ask questions, take notes, or whatever else my mom needed. CMS says that if something needs to be a consent signed, they both should sign it." That means that whatever you do that needs a patient OK must also have the assent of the patient advocate, even if the patient herself is perfectly competent and not incapacitated. The patient advocate should also be given a copy of the written patient rights, even though the competent patient is given a copy also. "It is different from the way we have done things in the past. It is one of the hardest things I have to explain to people," she says.
Calloway recently heard from a patient advocate who mentioned in passing that their ICU policy notes that there are only two visitors permitted, and they must be spouse or next of kin. That's now a violation of CMS and Joint Commission rules. "I was shocked," she notes. Most hospitals are rewriting their visitation policies to reflect that who may or may not visit is now at the discretion of the patient. If you limit visitation in the ICU, which CMS discourages, to two visitors, the patient gets to pick who the visitors are, even if it is his or her neighbor, same-sex partner, spouse, or best friend.
Another element that gives hospitals trouble is that information on advance directives policies have to be given to all inpatients, but also for emergency department patients, observation patients, and those who are having same-day surgery. "People didn't realize that these three classes of outpatients were part of this," she says.
Some people complain about these requirements, but Calloway says there are good reasons for every element. Communication is a key to safe, high-quality care, and since there are 50 million people living in this country whose primary language isn't English, you need to be ready for that. "It doesn't matter if you have strong opinions on immigration or whatever: The law is the law no matter what you think."
That means that people who don't approve of same-sex relationships have to swallow their feelings and make sure that their policies and procedures and the people who implement them follow the rules related to gay, lesbian, bisexual, and transgender patients. "It's called patient-centered because it's about what the patient wants, not what we want," she notes.
These changes don't have to be onerous or expensive. The increasing use of technologies like video conferencing or phone language lines allows translators to be anywhere and still be there in the patient's room. And hospitals can also band together to share the cost of qualified interpreters, she says.
Organizations had a total of 18 months to prepare for these standards, and now what a surveyor finds counts. She suggests going through the Roadmap, which has some excellent resources and checklists because, from what she can tell, there are still a lot of organizations out there that haven't got this right.
For more information on this topic, contact Sue Dill Calloway RN, Esq., CPHRM, AD, BA, BSN, MSN, JD, President, Patient Safety and Health Care Consulting, and Chief Learning Officer for the Emergency Medicine Patient Safety Foundation, Dublin, OH. Email: [email protected]. Telephone: (614) 791-1468.
It happened six months later than first expected, but on July 1 organizations became responsible for meeting the requirements of the standards for patient-centered communications, Advancing Effective Communication, Cultural Competence, and Patient- and Family-Centered Care: A Roadmap for Hospitals. An exception was the visitation standards, which went into effect July 1, 2011.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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