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CMS Pushes for More Joint Commission Changes

Accreditation Monthly, February 10, 2009

The Joint Commission must for the first time meet CMS expectations to maintain its Medicare deeming authority. This has triggered significant changes, since the current Joint Commission standards and survey processes do not match CMS standards and survey processes. The first wave of change was the 300 or so new elements of performance that took effect January 1, 2009. These changes were made on the fly—without the typical pause for comments from the field—and bring the Joint Commission standards in better alignment with the Medicare Conditions of Participation. We expect more changes in the next few months.

• The Joint Commission will attempt to better define its Immediate Threat to Life trigger for preliminary denial of accreditation.
• The Joint Commission must define which standards or elements of performance trigger a Medicare condition-level finding.
• The Joint Commission must define what it will do when it encounters a condition-level finding.
• We also expect the survey process to change to a more CMS-like tracer. The Joint Commission's tracer methodology was based on the CMS survey methods for long-term care facilities. However, the Joint Commission process does not focus on particular problem-prone issues. We expect that future tracers will focus on patients in restraint and emergency department transfers.

The next few months should be fascinating.

About the author: Mr. Bud Pate serves as vice president for content and development at The Greeley Company, a division of HCPro, Inc., in Marblehead, MA. He is a nationally recognized expert in patient flow and hospital and health system regulation and accreditation, with more than 25 years of experience in high-profile problem solving.

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