Mac’s Safety Space: How much does someone really need to 'know?'
Reflecting on the differences between “pondering” and “ponderous” as a function of survey preparedness, I fielded a query from an organization going through survey regarding emergency lighting in an existing business occupancy (the building is of a vintage that might reasonably be referred to as pre-existing, but there’s no Life Safety Code chapter that deals with that).
The query was prompted by a clinician who was surveying ambulatory care locations. As it should happen, this particular care location was located on the main campus of the hospital and was covered by the emergency power supply system, so that was the response provided to the surveyor. But it prompted me to think on the level of detailed information that the occupants of ambulatory care locations should have in the event that questions should be raised during a survey and there’s nobody immediately available from the plant ops side of things to provide clarity.
As a going concern, folks tend not to worry about such things until something goes sideways in the realm of normal operations—as long as (for example) normal power is in place, who really worries about what would happen if normal power were disrupted (beyond you and I—we always worry about this type of stuff)? But, when you think about it, what good is conducting emergency exercises in the ambulatory care locations without interjecting some sort of site-specific disruption? A slight digression there, but back to the main point of this chat.
For folks with multiple care settings out in the community, I think there is a benefit in creating a summary of key utility systems by location, to ensure that there is coordinated operability during survey. For example, it is probable, if not likely, that you have a mix of sites that have sprinkler systems and some that do not; same thing for fire alarm systems—some have ’em, some don’t. The type of equipment, systems, etc., can be different from location to location. So, having a master list of what you have, by location, is useful not only to you, but also to the folks in the spaces for which you are responsible. We know they’re going to call you if something goes wonky, but if the folks at each location know what they have—and even who provides service support to all those systems – they can respond knowledgeably to questions during survey (I think we’ve all seen the “deer in the headlights” look from line staff when you ask about systems, etc., for which their working knowledge is limited).
Particularly when it comes down to provisions/accommodations that can be made in the event of an emergency, the more comfortably knowledgeable folks at the point of care/point of service are, the less likely that you’ll have to “walk back” a mischaracterization. When it comes right down to it, you can always instruct folks to feel comfortable telling a surveyor that “I don’t know the answer to that question, but I know how to obtain that information,” but, in the moment, that comfort level sometimes can’t overcome the thought that they have to give the surveyor something in the way of a response.
Clearly, in looking back at the history of regulatory surveys in healthcare, there are more than a handful of surveyors who love the “gotcha” moment; sometimes it’s because they use a foreign vernacular to ask line staff about their roles in the environment; sometimes it’s because they’re asking a question that wasn’t practiced during tracers.
The example that jumps into my mind’s eye (or is it my mind’s ear) is the whole issue with asking staff about dwell times for disinfectant—I think that’s been sufficiently communicated to not come as a surprise, but for a while, that was a big deal. Likewise asking folks about how they clean/disinfect equipment, etc., as a function of the manufacturers’ instructions for use (IFUs). I get that it’s important for folks to understand and properly maintain whatever equipment, supplies, etc., they’re using, but I also know it is quite challenging to ensure that the response to any of these types of questions could be so standardized that the persnickety surveyor might not try to manifest a case of inconsistent practice (because practice is always reflected in the way that folks describe a process verbally, yes?).
I guess the bottom line on this is you need to make extra sure that the folks in the ambulatory/community care settings are as well-prepared as the folks you see every day (more or less). The focus of the survey process will likely continue to be the generation of as many findings as possible in the physical environment, so, any finding—big, small, or in-between—is fair game.
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.