Top Strategies to Excel in Your Next Joint Commission Survey

Top Strategies to Excel in Your Next Joint Commission Survey

Understand the Accreditation Process

The Joint Commission is a privately-operated entity recognized by the Centers for Medicare & Medicaid Services (CMS) through deemed status to conduct accreditation processes for hospitals receiving federal funding. This accreditation, essential for CMS-funded hospitals, could be performed by different organizations, yet the Joint Commission remains the prevalent choice despite the growing popularity of alternatives like DNV (Det Norske Veritas).

Accreditations are evaluated on a three-year cycle, although inspections can occur as early as 18 months post the previous survey due to various factors. Passing this comprehensive survey grants accreditation but may require hospitals to implement specific work plans to address deficits in areas such as life safety, clinical operations, environmental care, medication management, infection control, laboratory services, and pharmacy practices, among others. The survey extends to examining dietary services to ensure food safety and equipment maintenance.

Surveyors, including life safety code surveyors, assess hospitals across these diverse areas, conducting tracers in different departments like the kitchen to ensure compliance with health and safety standards. This role involves evaluating adherence to codes and standards in life safety, environment of care, emergency management, and more.

For hospital administrators looking to succeed in a Joint Commission survey, understanding the surveyor’s perspective can help. Focusing on preparing for the survey from a remediation standpoint can not only help in achieving compliance but also in enhancing overall knowledge and readiness for the assessment process.

Day One with a Life Safety Code Surveyor

How can a facility director ensure a successful day upon arriving at the hospital on day one?

On the first day, a life safety code surveyor introduces themselves, explaining the survey process duration, which varies from two to five days based on the hospital’s size. They provide a general outline of the survey, emphasizing collaboration and open communication with the facility director. Surveyors encourage directors to challenge any findings they disagree with and mention the involvement of the Joint Commission’s Standards Interpretation Group (SIG) if disputes arise.

The approach is non-confrontational; the surveyor assures that disagreements won’t affect the survey’s outcome. With experience as a former director of facilities, the surveyor understands the challenges faced by hospital staff.

The physical inspection begins with critical areas like the fire panel, fire pump, chillers, and boilers, primarily in mechanical spaces. The surveyor emphasizes the importance of keeping these areas clear, notably ensuring that fire extinguishers are accessible and exit doors are unblocked. Since these spaces often lack drop ceilings, it’s crucial to prevent penetrations, which are among the easiest flaws for a surveyor to spot.

Streamlining Life Safety Code Survey Preparation

Essentially, it’s straightforward – you need someone to ensure everything is prepared and in order. Specifically, it’s crucial that your fire pump operates automatically upon receiving a signal, rather than being manually controlled. Similarly, your generator should operate automatically. Among the basics, another important task involves conducting a thorough review of various documents, which includes checking the presence and organization of fire alarms, fire suppression systems, doors, fire dampers, generators, and electrical switchgear. This document review, taking roughly 2 to 2.5 hours, is vital for presenting a well-organized and comprehensive overview during inspections.

Having your documents and systems properly organized and understood is key to guiding an inspector through them efficiently. The goal is to demonstrate a clear history of equipment tests, including who conducted them, the dates, outcomes, and any corrective actions taken if necessary. Successfully narrating this process will significantly contribute to a positive evaluation.

If all these steps are completed by the afternoon of the first day, it sets a strong foundation for the inspection process, easing the surveyor’s job and consequently fostering a positive impression of your facility’s management program.

In my experience as a director, I found it beneficial to have teams prepared both ahead of and behind the surveyor. This strategy ensures immediate attention to and resolution of any issues discovered during the inspection. For instance, if a flaw is spotted, a team member can quickly address it, document the fix, and present it to the surveyor shortly thereafter. Although this won’t erase the initial finding, it demonstrates proactive management and care for the facility, greatly enhancing the overall impression.

Preparation is indeed the key to a successful inspection, involving meticulous planning, teamwork, and effective communication to address and document maintenance and safety protocols efficiently.

Efficient Survey Preparation Strategy

To ensure a smooth life safety code survey, organize a forward team to inspect areas ahead of the surveyor. The process begins with a walkthrough of mechanical rooms, followed by document review, inspections of operating rooms (OR) and psychiatric areas, and then a top-down examination of the building. This team checks doors, possibly lifts ceiling tiles to inspect for penetrations, tests fire doors for proper clearances, and verifies the integrity of firewalls and smoke walls. They also alert clinical staff of the impending visit, helping them prepare patient areas and remove obstructions from exit corridors and stairways.

The goal is to maintain readiness at all times, not just during the survey, to avoid minor oversights, such as obstructed fire extinguishers, which can lead to citations. Starting from the top floor, the surveyor checks stairwells, fire doors, penetrations, and clinical areas, emphasizing the importance of having accurate, updated facility drawings. Knowing the layout and maintaining updated drawings are crucial for accurately identifying and addressing potential issues before they become findings.

Regular updates to your facility’s drawings—at least annually, if not quarterly—are recommended to reflect any changes, such as room repurposing, which could otherwise result in non-compliance. Establishing a partnership with a firm for drawing management can be beneficial, especially for larger facilities. Being proactive and well-prepared helps ensure a smoother survey process, demonstrating an ongoing commitment to safety and compliance.

Conducting a Life Safety Code Survey in a Hospital

Once the discussion commences, the process involves a thorough walkthrough, correct? It’s a comprehensive process, indeed, as you’re navigating through almost every part of the hospital, except for each individual patient room. Usually, the Joint Commission survey begins with the surveyor approaching the nursing station to introduce themselves. For instance, if I were the nurse, they would greet me, they might say, “I’m Mickey, conducting a life safety code survey for the Joint Commission. Could we inspect an unoccupied patient room?” You’d then direct them, perhaps to room 312. Generally, a clinician accompanies the surveyor into the room. It’s not common practice for surveyors to inspect areas above the ceiling tiles immediately upon entry; avoiding potential disruptions in patient rooms is a priority. However, the inspection within a patient room is meticulous, examining the medical gas headboard for signs of damage or wear, the condition of floors, ceilings, and walls for any obvious issues, and even the bathroom facilities, noting the state of the sink, toilet, floor, and shower. Attention is also given to safety features like the emergency call cord, ensuring it’s not improperly placed around grab bars, which could hinder its use in case of an emergency. This detailed assessment, especially focusing on the patient room’s safety and maintenance aspects, is a critical component of the life safety code survey by the Joint Commission.

Optimizing Hospital Survey Walkthroughs for Better Outcomes

Survey teams are encouraged to spend significant time inspecting the hospital, with about a quarter of the first day and nearly all of the second day dedicated to building walkthroughs. The pace of the survey can vary, with a surveyor typically covering 300,000 to 500,000 square feet per day, depending on the size of the hospital and the volume of issues encountered. Finding multiple issues slows progress as each requires documentation and potentially discussions or arguments.

To facilitate smoother interactions and possibly influence the surveyor’s responsiveness, it’s beneficial to include a personable, eager-to-learn team member in the walkthrough. This strategy, often leading the surveyor to be more open and less defensive than they might be with more senior staff, can create a more conducive environment for addressing findings. This approach relies on using the dynamics of interpersonal relationships to ease potential tensions and foster a constructive survey process, emphasizing non-confrontational communication and the readiness to adapt team roles for better engagement with the surveyor.

Balancing Professionalism and Approachability in Hospital Survey Inspections

It’s crucial to carefully select who will interact with surveyors during an inspection, aiming for a balance between professionalism and approachability. Surveyors are focused on their responsibilities and are not looking for flattery but genuine cooperation. They operate under scrutiny from CMS, with their work subject to review, adding pressure to thoroughly assess compliance without intent to embarrass or intimidate the facility staff.

The advice is to treat surveyors respectfully and remember they’re performing a job essential for maintaining standards. However, maintain a level of formality; being overly comfortable can lead to inappropriate comments or unprofessional behavior, which could negatively impact the survey process. It’s a professional environment, and while it’s important to be open and cooperative, maintaining a boundary of professionalism is key to a successful survey experience.

Effective Communication and Knowledge Management in Post-Inspection Reviews

Upon completing the building inspection from top to bottom, the survey might not necessarily conclude. Additional meetings concerning the Environmental Care Tracer or Emergency Management tracer could follow, involving discussions on these areas’ compliance and updates due to frequently changing standards, especially in Emergency Management. It’s advised to have a team member knowledgeable about current Joint Commission standards to avoid adherence to outdated practices.

At the end of each day, a crucial meeting takes place between the surveyor, facilities director or manager, and possibly other staff to review findings. This session allows facility management to understand and verify the identified issues, making note-taking essential for addressing any discrepancies promptly. This is particularly important as surveyors must finalize their findings daily for a comprehensive review with the hospital’s executive team the next morning. Ensuring open communication about these findings helps prevent misunderstandings and ensures that the facilities director is not caught off guard by unaddressed issues during executive reviews. If a surveyor fails to schedule these essential debriefs, it’s recommended to proactively request them.

Navigating Issue Resolution Sessions During Hospital Surveys: Strategies for Effective Dispute Management

During a survey, “Issue Resolution” sessions are designated times for discussing disagreements over findings. These sessions occur on both the first and second days. Even during hectic two-day surveys, where surveyors must finalize all observations and enter them into the system for review, they are still required to share their findings and offer an opportunity for issue resolution.

Facility directors should view these sessions as opportunities rather than confrontations, presenting their disagreements with specific reasons rather than arguing. It’s also advisable to question the source of a cited code if there’s disagreement, as surveyors may focus intensely on areas of personal expertise, potentially leading to over-scrutiny. Asking for code sources enables facility directors to verify the applicability and currency of the standards being used.

Taking notes during these discussions is crucial for effective follow-up, allowing for thorough preparation for any subsequent clarification or appeal sessions. This proactive approach ensures that you are well-prepared to address any discrepancies or misunderstandings in a professional and informed manner.

There’s no need to stress over disputing survey findings. After the survey, if there are disagreements, facilities have the chance to formally challenge these findings by submitting a document outlining their dispute. Some administrators might hesitate to contest findings for fear of upsetting the surveyors, but this concern is largely unfounded. Once a surveyor moves on to their next assignment, they’re not likely to remember the specifics of every survey, especially given the volume of hospitals they evaluate. If a dispute arises, they might have to revisit details from several weeks back, by which point they could have inspected numerous other facilities.

Remember, it’s unlikely you’ll interact with the same surveyor again, so there’s no reason to avoid disputing findings if necessary. Plus, considering the significant fees paid to the Joint Commission, don’t hesitate to question or challenge their evaluations through the proper channels. This process is part of your rights as a participating facility.

Mastering the Final Stages of The Joint Commission Survey: Strategies for the Exit Conference and Beyond

On the last day of the survey, it’s important for directors to be aware that all surveyors gather to finalize their report and ensure a consensus is reached on their findings. This precedes the exit conference, which involves the surveyors and the hospital’s senior leadership, where the survey findings are presented. The size of the attendance can vary significantly, but it’s crucial to approach this meeting with a mindset focused on understanding rather than disputing.

Arguing during the exit conference is not advisable as it’s unlikely to change the outcome and may lead to a dismissive response from the survey team who are preparing to depart. Reviewing the findings presented and responding appropriately after receiving the official report is the best course of action.

It’s noteworthy that the report undergoes a final review at the Joint Commission’s corporate office, where adjustments can still be made based on further evaluations by the standards interpretation group. This process shows that feedback and clarifications can still influence the final outcome, emphasizing the importance of a constructive approach to survey findings.

Alright, to summarize: When you receive the results from the initial site survey and are satisfied with them, it’s crucial to plan for any necessary fixes. If there are issues identified, it’s expected that these will be addressed. You will be informed of a follow-up visit, typically scheduled within 45 to 60 days, focused solely on previously identified issues. It’s important to ensure that no new issues arise in the areas being re-inspected to avoid additional findings. In case issues persist, having a detailed action plan, including funding commitments, a timeline for corrective measures, and explanations for any delays, is essential.

For The Joint Commission (TJC) survey preparation, remember that familiarity with specific codes isn’t as crucial as understanding general areas of focus, such as maintenance spaces and safety equipment like fire pumps, boilers, generators, firewalls, fire doors, and dampers. Key steps include ensuring all necessary equipment is in optimal condition, conducting all required testing to certify that safety systems are fully operational, and addressing any repairs urgently. Failing to remedy issues, especially those related to critical life safety systems, can lead to escalated scrutiny from TJC, indicating a lack of understanding of these systems’ importance for safety. Finally, while extensive preparation is necessary, it does not need to be overly complex; understanding the standards provided, having a solid plan for compliance, and executing necessary repairs and tests are fundamental to a successful survey outcome.

Joint Commission Eliminates Plans for Improvement – Implications to Healthcare

On July 12, 2016, the American Society for Healthcare Engineering (ASHE) published that The Joint Commission will no longer consider Hospital Plans for Improvement (PFIs) for its Life Safety chapter requirements as of August 1, 2016.

Breaking down the changes:

  • All deficiencies must be addressed within 60 days of being identified
  • The Joint Commission will no longer review open items and will not issue PFI lists as a part of their reports
  • Requests for extensions will be handled by the Regional Centers for Medicare & Medicaid Services (CMS)

In the past, many facilities have used The Joint Commission’s findings to build ongoing Plans for Improvement to address the deficiencies found. Now that a hard deadline of 60 days is being imposed, this method is no longer practical. Knowing that Joint Commission inspections are thorough, preemptive measures are necessary to ensure compliance.

Steps healthcare facilities can take to be proactive with this major change:
1. Assessments 
– utilized primarily by owners and contractors to:

  • Develop a remediation budget
  • Determine the extent of an issue
  • Ensure compliance on a project or facility

Using a certified and reputable contractor to assess the existing condition of barriers prior to The Joint Commission inspections is now more important. The findings of the assessment are then used to develop an internal Plan for Improvement. Identifying and addressing deficiencies before being under the “60-day” clock is crucial.

2. Staying up to date on the latest “hot items”
Building Codes, Fire Codes and NFPA are consistently evolving and are formally updated every 3 years. Prepare for compliance by staying up to date on the existing standards and codes including:

  • Doors within Rated Barriers: The tolerances of the vertical gap and undercut of the door must be ensured. The doors must have proper identification of being fire-rated. Other issues include the door being self-closing and having positive latching.
  • Fire/Smoke Dampers: Dampers used to maintain rated barriers need to be tested to ensure functionality. The sealing around dampers is also highly scrutinized. A common deficiency found is intumescent fire-stopping being used to seal around dampers which goes against the U.L. approved manufacturer installation requirements of most dampers.
  • Missing/Removed Fireproofing: This is a deficiency that has been often identified recently. Fireproofing that is removed to attach clamps for hangers to support mechanical equipment must be replaced. This issue can commonly be found throughout a facility.
  • Fire Barrier Management: Ensure fire-rated wall penetrations (mechanical, plumbing, electrical, etc) have been repaired and sealed to keep their rating.


3. Engaging a specialty contractor to remediate deficiencies

Employing a certified contractor like REMEDI8 to identify deficiencies prior to The Joint Commission prepares your facility to pass inspection. Remediation of deficiencies can be budgeted, and scheduled for the needs of the facility. The documentation provided by a qualified contractor like us can make The Joint Commission inspections less daunting. By using a containment contractor such as REMEDI8 that provides both assessments and utilizes in-house employees for field installation and remediation, facilities can be assured of receiving quality and can more closely monitor and control schedule, cost, and compliance.