You don’t only have to know when to fold them
You have to know where you shut them off—make sure you label those shutoff valves!
That’s one of the pearls of wisdom dispensed during the most recent Executive Briefings by our friends in Chicago. It appears that there’s been a run on unlabeled shutoff valves during this year’s surveys, so make sure you give those a look-see before your next survey; particularly the gas shutoff in your kitchen areas. Stuff does seem to happen in kitchens that render things invisible/obscured.
As a general note, findings in the physical environment (more on that term in a moment, and yes, I am kind of burying the headline) were generally in the lower levels of the matrix of safer (mostly low, limited) but in the aggregate, about 65% of the physical environment findings were in the low risk category. EC.02.06.01 seems to be the area that is driving a lot of the highest risk findings, which remains kind of like OSHA’s use of the general duty clause—sometimes compliance issues do not fall neatly into a category, so the use of catch-all points for things like cleaning issues, issues with ceiling tile, issues with “non-cleanable” surfaces, etc. (strictly speaking, the infection control-related environmental findings) makes a great deal of sense. As has been noted in this space many times, the management of the physical environment lives at the point of care/point of service, and this is where these findings tend to be identified. It’s also important to note that this means inpatient, outpatient, wherever patients receive care/services. It seems likely that the surveyors will be spending as much time as possible in the care environment—wherever it might be—keep an eye on all of it!
And so, the big news is that the EC & LS chapters are going to be combined into a single chapter in 2025, called Physical Environment. Presumably, we will be hearing more specifics (crosswalks and the like) as that date draws closer, but the word on the street is that I might finally be granted my fondest wish—the discontinuation of the requirement to have management plans as a distinct undertaking. Those requirements have never been reflected in the Conditions of Participation, and it would seem that the combining of the chapters and the reflection of the standards and requirements as reflected in the Conditions of Participation, will make its final melding in this next go-round of changes.
I know there are folks who find the management plans useful, but it’s been a very long time since I’ve been able to gain any operational use for them, unless (and hopefully at this point, this would not be the case) you’re having a difficult time complying with the various elements. This will shift some of the burden of demonstrating compliance to how one actually manages compliance with the standards and performance elements. Some of you may want to continue as a shorthand means of verifying compliance strategies, but, as it should happen, that will be the choice of each organization. I suspect there will remain some sort of requirement relative to annual (or some other period) evaluation of the physical environment management program. I don’t know why you would want to suspend that if you are making good use of the process to inform organizational leadership of what’s going on. You need to be able to escalate problems, ask for consideration of operational strategies, etc. The evaluation process is tailor-made for communicating to the top of the organization (and hopefully back down again because feedback loops are of critical importance) and, much like safety rounding/hazard surveillance activities, etc., we don’t do them because we have to, we do them because they make good operational sense. You can’t oversee the management of the environment from an office or a committee—there’s too much that can go unseen—and, sometimes seeing is not only believing, but it is a means of improving behaviors.
About the Author: Steve MacArthur is a safety consultant with The Chartis Group. 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 an advisory board member for Accreditation and Quality Compliance Center. Contact Steve at stevemacsafetyspace@gmail.com.