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Key Issues in HFAP Beverly Robins, RN, BSN, MBA Director of October 26, 2012 1 History Began in 1945 American Osteopathic Association Accrediting Hospitals and Other Health Care Facilities for Over 65 Years Accrediting Hospitals Under Medicare since its inception in 1965 HFAP is the oldest, continuous accreditation organization in the U.S. 2 Federal: National Recognition Deeming Authority from the Centers for Medicare and Medicaid Services (CMS): Hospitals, CAHs, ASCs, and Clinical Labs CLIA 88 Deeming Authority from the Substance Abuse Mental Health Services Agency (SAMHSA): Behavioral Health Facilities 3 1

Healthcare Facilities Program Primary Stroke Certification Acute Care Hospital* Critical Access Hospital Ambulatory Surgical Centers Healthcare Facilities Program Behavioral / Mental Health Office-Based Surgery Ambulatory Health Care Laboratory 4 Account Manager Your Account Manager will guide you through the process of becoming and remaining an HFAP-accredited facility. e- Application ASC Account Manager Pre-Survey Survey Event Account Manager Post Survey 5 Survey Process ASC 6 2

Survey Process: What to Expect! Unannounced but on a day you do surgery Physician and/or Nurse Surveyor will arrive Surveyors will observe, review documents, conduct interviews and speak with patients Surveyors will follow a patient from admission to discharge 7 Survey Process: What to Expect! Facility management participation is key Opening conference where a plan for the two days will be established A closing conference will be held to discuss areas requiring an action plan Some deficiencies may be corrected during the survey 8 Survey Process: What to Expect! Survey process is collaborative, educative and participative Questions are encouraged Survey findings are documented in a deficiency report and provided to the facility 9 3

Your Facility Must Meet the Definition of an ASC For Medicare certified facilities only Distinct entity Operates exclusively to provide surgical services to patients not requiring hospitalization expected stay does not exceed 24 hours Has an ASC supplier agreement Complies with ASC CfCs Reason many ASCs operate only part-time & want to use part or all of the same space for other purposes, e.g., physician s office 10 Know the Standards Purchase a Manual Read every standard Share the standards with appropriate staff members Understand the scoring 11 Patient Rights Patient Rights aren t posted No policies to support Patient Rights One or more required rights are absent Grievance process is incomplete with no designated time frames for response 12 4

Policies Purchased policies are not customized Policies lack approval by the Medical Director and Governing Body Required policies are not written Policies are outdated Policies do not include references 13 Infection Control ICO lacks the necessary training There is no annual report Hand washing surveillance and environmental rounds are not documented IC Program lacks all required components IC activities are not included in QAPI 14 Governing Body Minutes IC and QAPI activities are not discussed Approval of policies and contracts has not occurred Equipment updates are absent Physician credentialing elements are incomplete Incomplete documentation of the compliance program 15 5

QAPI Data collection is done but analysis and problem resolution is lacking Outcome data is poorly documented Staff other than management is unable to describe the quality process Laser procedures are not included in QAPI Quality training has not occurred 16 Chart Review Missing H&P and or consent No H&P for laser procedures H&P not updated on day of surgery H&P does not include a comprehensive inquiry by systems and a physical exam Procedure name on consent not written at a forth grade level 17 Medical Records Medical Record security not adequate Physician orders and other documents not signed, dated and timed Pain assessment and reassessment not documented using the pain scale No documentation that the patient received the Patient Rights, Advance Directives, disclosure of ownership and agency phone numbers on the day of surgery 18 6

Human Resources Lack of documentation on orientation, training and competencies References and license (PSV) verification are not documented Yearly employee performance evaluations are not completed in a timely fashion or absent 19 Facility Tour Outdated medications and supplies Unsecured medication in unoccupied areas Unsecured Oxygen tanks Biomedical stickers are absent or not current MSDS not available or accessible OSHA requirements are not met Hours of operation not posted 20 Surgical Procedure Observation Policies not being followed such as labeling of medications on the sterile field Time-out procedure not followed Staffing Issues Use of radiology equipment (fluoroscopy) 21 7

PLAN OF CORRECTION Begin immediately Ask for suggestions Include pictures if appropriate Include audits showing compliance Include information to demonstrate how sustainability will be achieved 22 Congratulations Post your certificate of accreditation Keep policies and approvals up to date Make a plan on how to maintain a state of readiness Continue to conduct mock surveys on a regular basis to correct compliance issues identified 23 QUESTIONS? If you have any questions please contact the Healthcare Facilities Program (HFAP) 312-202-8258 or submit questions online at info@hfap.org 24 8

What s Wrong With This Picture 25 9