Bye bye, business occupancy?
To my fairly certain knowledge, I’ve tried to stay away from anything that might approximate “click bait,” though I will freely admit that this week’s “headline” bumps up against it as a general concept. That said, I do think that the current shifting of survey focuses is such that it may be more sensible in the long run to modify the ways in which we “use” business occupancies as a survey preparation methodology.
What prompted the thought (beyond all the hubbub regarding the new section of the Joint Commission’s Life Safety chapter that deals specifically with business occupancies) is the whole notion of the slow envelopment of the “healthcare facility” descriptor as the go-to term for all care locations, be they inpatient or outpatient in nature/design. It does appear that a day could come in which the business occupancy designation means little or nothing from a compliance standpoint—I shudder to think. When you think about it, the “sharp edge” that separated care locations by occupancy classifications has become rather more blurred than not, some of which is the result of there not being clearly defined expectations/standards. Clearly, the business occupancy section of the LS chapter is a step towards a codification of those expectations—and what that means going forward.
If you look at the overview section of the LS chapter in the online manual, there is a note that the first two standards in the chapter (dealing with general expectations, including the management of life safety drawings, and the practical application of Interim Life Safety Measures) apply to all occupancy types. Truth be told that “note” has been sitting there for a while now, but with the creation of the business occupancy section of the LS chapter, I think we can probably intuit that the “general” requirements are going to be more of a focal point during survey. Past experiences tell us that this stuff won’t all get chased right out of the box, but I think one of the pressure points is going to be what you have for life safety drawings for your outpatient locations. Hopefully, that thought will prove to be most incorrect, but I get this feeling…
Another element in the outpatient setting is the practical application of all things relating to infection control; much as is the case with the physical environment in general, the currently drawn lines are not sharply defined, so it becomes the charge for each organization to define the lines of compliance. A good recent example is this article in Health Facilities Management magazine. I’ll let you read this on your own, but it does speak to a fair level of due diligence in determining what is actually required by code and what is the best strategy for your organization. High-level disinfection, sterilization, management of instruments, etc., is likely to continue as a significant survey touch point—and they’re going to kick those tires fairly exuberantly. You need to have a solid foundation for what constitutes compliance for your organization to present as bulletproof a façade as possible, so if you’ve got any of these IC-related processes “living” in your outpatient settings (and odds are that you do), it’s time to start kicking those tires before the folks with the pointy shoes show up…
Hope you all are well and staying safe through this current transition. While I am optimistic about the future, my personal observations during my travels the past couple of weeks is that hand hygiene numbers are starting to tail off a bit. I guess there are some folks that will only wash their hands if they think it’s a matter of life and death…
About the Author: Steve MacArthur is a safety consultant with 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.