Mac’s Safety Space: ASHE 2023 – San Antonio rose to the occasion

I’m penning this as a quick quasi-reaction piece as I wait for the first leg of my flights back to Boston; I don’t know that I’d mentioned this previously, but this was the first time I’d been able to attend the annual ASHE conference (generally, the conferences were scheduled when I was on vacation in Maine—I love my job, but I think Maine and vacations are just a little bit more to my liking.)

At any rate, it was really interesting to see the types of presentations on offer (lots of stuff about general compliance, sustainability, etc.), but also interesting to note that there was less of a “presence” (if you will) on the physical environment as it relates to the management of behavioral health patients (there were one or two vendors with behavioral health-related design / furnishings products). I think, to a degree, that might have something to do with the shifting of the TJC survey finding allotments (that might not be quite the right term, but something like that) through the establishment of the National Patient Safety Goal (NPSG) addressing the management of patients at risk for self- and other harm.

In looking at the Top 10 information on the physical environment/life safety side of the equation, there’s no easy/simple way to capture the NPSG fallout in the physical environment, at least as a function of the Environment of Care (EC)/Life Safety (LS) chapters. I don’t know if this was a missed opportunity or if the audience represented at the ASHE conference hasn’t yet been targeted. (Maybe next year—recognizing that my data set is limited to this year—perhaps the management of the behavioral health environment has been covered ad nauseum in the past and folks are ready to move on.)

I can tell you from practical experience that findings in the behavioral health physical environment are still driving adverse accreditation decisions, but maybe it’s not the folks who attend ASHE who are having trouble “keeping up.” To my mind, the management of the behavioral health environment, along with the management of the perioperative environment and the management of construction/renovation activities are the areas that would benefit from interdisciplinary collaboration—each in their own way can be “problematic” (representative of increased vulnerability). There’s always an opportunity to be better – and I think these are the areas that would most benefit from being better.

Just a quick round-up of some other “thoughts” that look like they might be prescient relative to the future state of the survey:

• TJC is continuing the standard simplification process (including making Conditions of Participation comparative analyses—maybe the management plans will finally retire to some sunny destination);
• Recognizing that any Condition-level survey result is going to drive a finding under Leadership, it does sound like there will continue to be more focus on what physical environment conditions/findings are the result of gaps in leadership support. I think, in general, if you have infrastructure issues that are difficult to resolve, you better make sure that you’ve done an effective job of communicating those issues to the top of your organization. You have to do everything in your power to make sure that your boss (and your boss’ boss—and your boss’ boss’s boss…) have a clear understanding of what the needs are. Unfortunately, infrastructure isn’t as “sexy” as, say, the latest imaging technology, but without appropriate infrastructure, a lot of technology can struggle to be useful.
• It seems likely that CMS will once again be “shadowing” accreditation survey teams, probably in the Fall 2023; what this means is anybody’s guess, but you can anticipate something close to a potential doubling of the eyeballs surveying your building— happy, happy, joy, joy!
• Increasing focus on Interim Life Safety Measures (ILSMs), particularly as it relates to the assessment and mitigation of life/fire safety risks; be mindful that ILSMs are not equivalent to a corrective action—they are what you do to manage the risk(s) until something is corrected. It sounds like some folks have been playing the ILSM card in their corrective action plan responses to accreditation organizations. There was also some encouragement to not overplay your ILSM implementation; for example (and this is a paraphrase), you don’t need to let the entire organization know about a soiled utility room door that’s going to need to be replaced. The occupants of the area should suffice from a practical standpoint in many, if not most, cases.
• No surprises on the Top 10 EC & LS lists–I think we can consider these “universal vulnerabilities” (I daresay, UV’s); the average number of physical environment findings during survey (which dipped a bit during the public health emergency) is starting to rise (I suspect that by the end of 2023, the average will be around 20). If you look at EC/LS findings as a function of severity, the physical environment tends to “live” in the low-to-moderate portion of the matrix. But if you get enough findings—and don’t resolve them during the survey—there is some indication that the severity level can be elevated. I need to think more about that as a general thought, but I would caution you: Try not to be in a position of fixing something that is not, in fact, a code or standards deficiency. I suppose it’s a variation on the old saw “if it ain’t broke…”

At any rate, it’s nice to see so many folks who are committed to the improvement of the physical environment.  I don’t know how many folks are within the sound of my voice, but my thanks to all for your dedication and hard work. As far as I’m concerned, there is no dichotomy (it’s not anything versus anything else), everyone who works in healthcare is a caregiver—direct or indirect—and it was great to see all of you in one place sharing ideas and passions.

About the Author: Steve MacArthur is a safety consultant with Chartis Clinical Quality Solutions (formerly known as The Greeley Company) in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at stevemacsafetyspace@gmail.com.