Hospital Inspections Are Resuming - Are You Ready?

2020 was a year unlike any other, for reasons we don't need to spell out. Hospitals have been under perhaps the greatest stress they’ve ever dealt with, in the last 18 months. There’s no part of the hospital system that hasn’t been stretched to the brink or hasn’t felt the effects of our current situation. The recent events have caused many hospitals, and the organizations that deal with them, to have to change the way they do things - whether you’re talking about how they schedule elective surgeries or changing the times and number of visitors allowed in. It’s fair to say that healthcare changed more in the past 18 months than in any comparable amount of time in recorded history. Our health care system may never look exactly the same when the smoke clears.

Back before the Delta Variant reminded us that we couldn’t let our guard down too soon, many places were trying to get to their normal ways of doing things - restaurants and grocery stores went back to making masks optional, for example. Yet we shouldn’t think that everything is going to go back to the way it was (and if you’re hiring for jobs, you really see how true this is). Some things have fundamentally changed and it’s not clear if they’re ever going to change back.

What changed? The use of telemedicine went way up during the pandemic because many patients stopped going to hospitals and healthcare facilities because of their fears of possibly being around COVID-infected people. That’s probably not going to go away. More good news - many doctors started meeting patients out in the community and at home. House calls came back in some areas, which was really nice but borne out of necessity. Doctors also really started connecting with patients in new ways, even doing video and audio visits on iPhones.

While new things aren’t going away, other things that did disappear are coming back. For the first time in recorded history, overall healthcare spending went down. Not by much, but still. 2021 looks like things will go back to the way they were. But another thing that was put on hold in many places in 2020 and 2021, but that appears to be back on schedule, is hospital inspections.

The Joint Commission on Accreditation of Healthcare Organizations halted its inspection and survey procedures during the pandemic. JCAHO (sometimes pronounced "JACO") enforces the standards that another group, ACHA, sets for how hospitals and healthcare facilities have to operate. Healthcare administrators have come to dread these necessary evils - we all want to make sure our hospitals are doing everything they're supposed to and that requires some pretty thorough audits to ensure compliance.

During the pandemic, many hospitals have been preoccupied with keeping up with the 29 million (and counting) COVID cases the United States has seen. In response, scheduled audits and inspections were put on hold. As the calendar has passed a year since the start of the pandemic, we've all waited and wondered if things were ever going to get back to normal.

Wait no longer, my friend.

The Joint Commission has announced that they will be returning to pre-pandemic inspection and survey procedures starting Monday, March 15th. What does this mean for hospitals and facilities that fall under their umbrella?  Starting March 15th, unannounced visits by the Joint Commission survey team will resume.  Not only that but there will be no more notifications when an area has been determined to be low-risk for a visit. Hospitals won’t be able to be rest secure in thinking they can’t expect a visit during a given time.

What will the Joint Commission be looking for?

There’s no indication JCAHO criteria have changed and that's part of the problem for some.  Joint Commission audits are extremely comprehensive and look over every aspect of a hospital’s operations. Infection control, record keeping, physical structure, policy and procedures - and all the minute details that go into each thing - all fall under the watchful scrutiny of the JCAHO inspector.  

Most hospital administrators dread these inspections. The biggest complaint that hospitals have if you wanted to put it that way, is a perceived inconsistency in what the individual auditors are looking for in the testing. Most of them stick with the general mission-critical standards for fuel, typically defined by ASTM D975. Yet, they can look for pretty much anything else they want. It’s hard to be confident about such a thing when you don’t think you know exactly what they’re looking for.  We’ve heard stories of inspectors sitting outside of hospitals, waiting to see if someone props open a door (violation). Or of a hospital president freaking out on “game day” when a medical book vendor set up a pre-approved display in the lobby (the president had forgotten about it).  The uncertainty can be unsettling because so much rides on a favorable inspection, including a hospital’s all-important ability to bill Medicaid and Medicare.

How can you prepare for such a significant visit?

Knowing the JCAHO standards for fuel would be a starting point. We start with the knowledge that these kinds of JACO inspections will look at the health of the backup fuel and, just as importantly, the testing documentation that hospitals and healthcare facilities are required to have.

The base information for the fuel requirements can be found at https://www.jointcommission.org/standards/standard-faqs/laboratory/environment-of-care-ec/000001246/

The really short summary of those “JACO rules for fuel” is

• Enough generator fuel to power all the important lighting for 90 minutes
• 96 hours of backup fuel unless they have an alternative supply plan in place
• If the fuel powers “life safety” functions, it has to last for at least 90 minutes

Implied in these rules is that the fuel must meet specifications and that it has to be tested at intervals to demonstrate that it’s not going to fail when needed. ASTM D-975 gives the fuel specification targets - what condition the fuel needs to be in (along with how that is confirmed by testing). Testing requirements or guidelines (i.e. how often you must confirm the fuel's condition through testing) can be drawn from the set of standards known as NFPA 110.

In advance of these inspections, you should be asking if your facility’s backup fuel has continued, through the pandemic, to measure up to the standards it’s going to be judged against as the Joint Commission resumes its inspections. Does your fuel meet the D-975 specifications, right now? When's the last time you had it tested to the extent NFPA 110 requires? You must have good answers to the questions because you can bet that the JCAHO inspector will be looking for proof that you have them. 

Why Does ASTM D975 Matter Here?

D975 documents all of the essential “fuel properties” that the fuel has to have, right now, in order to function as diesel fuel should. Everything from essential combustion characteristics like flash point and cetane value to whether it contains harmful contaminants like water and sediment. All of these are confirmed by standard fuel testing.

Yet, there are a few things D975 doesn’t cover, and some of them are important to the life of the fuel. Oxidative or thermal stability measures are "predictive tests", so they’re not included in D-975 because they predict what is likely to happen with the fuel in the future (while D-975 is only concerned with the state of the fuel right now, in the present). Microbial count tests (like ATP-By-Filtration) are growing ever increasingly important, as microbial contamination problems are almost universal across the land. SO microbial testing is really important, but again, not included in D-975. We would recommend any hospital consider addressing microbial contamination in their mission-critical fuel if only because it can be the gateway to many other problems (and because it’s difficult to get rid of). 

Hospitals and health care facilities have had a lot to deal with during the pandemic.  JCAHO has tried to be considerate of that. It’s time to get things cranked back up and you want to be sure you're ready.