Jonathan Perlin, MD, who is currently the president and clinical operations and chief medical officer at HCA Healthcare, will replace Mark R. Chassin, MD, FACP, MPP, MPH.
The Board of Commissioners at The Joint Commission (TJC) has appointed Jonathan B. Perlin. MD, as the accrediting organization’s next president and CEO, effective March 1, 2022.
Perlin currently is the president and clinical operations and chief medical officer at HCA Healthcare, which is based in Nashville, Tennessee.
He replaces Mark R. Chassin, MD, FACP, MPP, MPH, who has led the commission for 14 years. Chassin has said he wants to pursue other opportunities in the quality improvement field.
According to the announcement, Perlin was Under Secretary for Health in the Department of Veterans Affairs before joining HCA Healthcare.
Perlin has served previously on numerous boards and commissions including The Joint Commission (2007-2010), the National Patient Safety Foundation, and in 2009 was appointed as the inaugural chair of the U.S. Department of Health and Human Services Health IT Standards Committee.
He currently serves on the Board of Meharry Medical College, a historically black graduate institution (HBGI), the Columbia University Mailman School Health Policy and Management National Advisory Board, Vanderbilt University School of Engineering Board of Visitors, and he is chair of the National Quality Forum.
The rule, which will include hospitals among other facilities, is expected to follow in line with the emergency regulations requiring nursing home workers to be vaccinated that were issued earlier this year.
This article was first published September 15, 2021, by HCPro's Credentialing Resource Center, a sibling publication to HealthLeaders.
Look for an interim final rule in October that will require "staff within all Medicare and Medicaid-certified facilities" to be vaccinated against COVID-19, according to a press release by CMS.
The Biden-Harris administration says it wants to protect the facilities and patients "from the virus and its more contagious Delta variant. Facilities across the country should make efforts now to get health care staff vaccinated to make sure they are in compliance when the rule takes effect," according to the release.
The rule, which will include hospitals among other facilities, is expected to follow in line with the emergency regulations requiring nursing home workers to be vaccinated that were issued earlier this year.
"CMS is developing an Interim Final Rule with Comment Period that will be issued in October," according to the announcement. "CMS expects certified Medicare and Medicaid facilities to act in the best interest of patients and staff by complying with new COVID-19 vaccination requirements. Health care workers employed in these facilities who are not currently vaccinated are urged to begin the process immediately. Facilities are urged to use all available resources to support employee vaccinations, including employee education and clinics, as they work to meet new federal requirements."
The Joint Commission (TJC) has proposed revisions to its Medication Management standard MM.09.01.01 on antimicrobial stewardship, such as strengthening some elements of performance, adding three new ones, and reordering others.
TJC is asking for your input on the changes as part of a standard field review. Comments will be accepted through September 15.
Among other things, the changes include requiring a hospital to have a stewardship program as an organizational priority, that it allocates staffing, financial and technology resources to support the program, and that quality data is reported to hospital leadership.
TJC has set up a survey to solicit input and asks that you read the proposed thoroughly first.
The Joint Commission issued new standards in 2020 to also increase awareness and safety on maternal morbidity and mortality, especially among women of color.
CMS is adding a maternal morbidity quality measure as well as a reporting requirement on COVID-19 vaccination rates among hospital and long-term care hospital workers as part of a 2,295-page inpatient payment rule released late Monday.
The rule is scheduled to be published in the Federal Register August 13, with most elements will be effective October 1. CMS also published a 14-page fact sheet summary.
In a press release highlighting the rules efforts to improve health equity and hospital readiness related to COVID-19 and future emergencies, CMS says it is trying to reduce disparities in maternal morbidity.
The Joint Commission issued new standards in 2020 to also increase awareness and safety on maternal morbidity and mortality, especially among women of color.
“Addressing the maternal health crisis and improving maternal health is a priority to advance health equity, and a quality improvement goal for CMS. To that end, CMS is adding a Maternal Morbidity measure to the hospital quality reporting program that would require hospitals to report whether they participate in statewide or national efforts to improve perinatal health, known as Quality Improvement (QI) initiatives. Many of the factors contributing to maternal morbidity are preventable, and differentially impact women of color. This measure is an important initial step toward implementation of patient safety practices to reduce maternal morbidity, and in turn, maternal mortality,” according to CMS.
In addition, “CMS is also adopting a measure that requires hospitals and long-term care hospitals to report COVID-19 vaccination rates of workers in their facilities. Having access to information about COVID-19 vaccination rates among health care personnel will help patients, caregivers, and their communities, make informed decisions when seeking care from hospitals, cancer centers and long-term care hospitals.”
The rule also seeks to improve hospital readiness by tracking better data.
“The final rule requires hospitals to attest they are in active engagement with public health agency to submit data for measures related to nationwide surveillance for early warning of emerging outbreaks and threats; automated case and laboratory reporting for rapid public health response; and visibility on immunization coverage so public health agencies can tailor vaccine distribution strategies. Hospital reporting of the measures will support public health agencies as they prepare to respond to both future health threats and long-term COVID-19 recovery,” according to CMS.
In a statement about the final rule, the American Hospital Association praised many of the initiatives but also said it would continue to work with CMS to help ease burden on hospitals.
The American Hospital Association (AHA) is pushing for CMS to continue some COVID-19-related 1135 waivers after the official close of the pandemic.
In a letter to CMS Administrator Chiquita Brooks-LaSure, AHA asked that flexibilities such as the use of telehealth, hospital-at-home programs, and the easing of certain licensure requirements for out-of-state providers and nurse practitioners be continued.
AHA also urged that the hospital Conditions of Participation (CoP) be permanently changed to reconsider “the use of verbal orders and certain requirements associated with discharge planning to better equip providers to assist patients. Doing so would remove unnecessary administrative burden and advance CMS’ 'Patients Over Paperwork' goals.”
In addition, the AHA asked CMS to:
“Permanently scale back current regulations and reconsider the importance of the specific information that is most useful to patients when being discharged to post-acute care facilities, including nursing homes
Continue to grant relief on timeframes related to pre- and post-admission patient assessment and evaluation criteria to ensure patients are treated in a timely manner and allow hospitals to better manage an influx of non-COVID-19 patients returning for care
Continue to allow pathologists and other laboratory personnel to perform certain diagnostic tests and review remotely through a secure network to ensure continued patient access to the best possible care, and
Continue to maintain flexibility in supervision requirements of diagnostic services by continuing to allow the virtual presence of a physician through audio or video real-time communications technology when the use of the technology is indicated to reduce exposure risk for the beneficiary or provider."
The hospital advocacy group also asked CMS to keep changes that allowed expanded care delivery in rural areas. And it asked that the agency consider easing up on hospital oversight much as it has in the heart of the pandemic.
The AHA noted that “it will take time to reestablish the capability for some types of ‘normal operations.’ For example, as CMS has already indicated in several of its fiscal year proposed rules, it may be appropriate to suspend or reassess the use of some of CMS’ quality measures. Similarly, it may be necessary to delay or rethink the scope of compliance surveys to ensure hospitals and other organizations have a chance to undo structures and practices implemented during the outbreak.”
The AHA is also offering healthcare systems resource materials to continue to get out the message to both the public and their own personnel why vaccinations are important.
The American Hospital Association (AHA) is supporting mandatory COVID-19 vaccines for healthcare personnel.
It is also offering hospitals and health systems public service announcements (PSAs) and other resource materials as a way to keep up the push to get more shots into arms in the face of the evolving novel coronavirus.
In a statement approved by the group’s Board of Trustees, the AHA said it was not only encouraging healthcare workers to get vaccinated, but supported healthcare organizations implementing policies to make COVID-19 shots mandatory.
The AHA wrote that it, “supports hospitals and health systems that adopt mandatory COVID-19 vaccination policies for health care personnel, with local factors and circumstances shaping whether and how these policies are implemented.”
According to the statement, the AHA recommends that if a hospital or health system does implement mandatory shots that those vaccination policies also:
“Provide exemptions for medical reasons and accommodations consistent with Federal Equal Employment Opportunity Commission guidelines (e.g., a sincerely held religious belief, practice or observance);
Follow relevant Centers for Disease Control & Prevention (CDC) infection control guidelines, Occupational Safety and Health Administration (OSHA) requirements, and other federal and state regulations regarding use of personal protective equipment and other infection control practices for unvaccinated staff receiving an exemption or accommodation. For example, unvaccinated personnel may be required to wear a mask at all times even if CDC guidelines and OSHA requirements were to relax mask requirements for vaccinated personnel;
Ensure the policy is implemented in a manner consistent with local and state laws;
Follow requirements and guidelines from the Food and Drug Administration (FDA) and CDC on which individuals are eligible and should be prioritized for vaccination;
Monitor national safety and efficacy data for all FDA authorized or approved vaccines in use;
Continue providing education about the efficacy and safety of COVID-19 vaccines to encourage staff to obtain the vaccine voluntarily; and
Offer scheduling flexibility and/or time off to ensure personnel have time to obtain the vaccine and recover from its possible side effects.”
Remember that if your organization does choose to make vaccines mandatory, you should have a clear policy. Also remember surveyors will survey to your written policy.
With a theme of “Ask questions, follow science, get vaccinated,” the materials include pre-recorded PSAs featuring AHA Board Chair Rod Hochman, M.D., president and CEO of Providence, and chairs from the AMA and the American Nurses Association in an effort to add credibility to the push.
Hospitals and health systems can add their own branding to 30-second and 15-second PSAs and will soon also provide information in Spanish as well as English, according to the AHA.
The announcement also included a continued push for the AHA’s own #MyWhy vaccination campaign, which focuses on getting healthcare workers to sign up for their vaccinations. That should include those in non-clinical roles, says the AHA.
“Hospitals and health systems are encouraged to have their teams share their own #MyWhy and join the campaign. Ready-to-use materials and resources are available on AHA’s #MyWhy webpage,” said the announcement.
In the statement urging mandatory vaccines, the AHA noted that vaccines “provide strong protection against workers unintentionally carrying the disease to work and spreading it to patients and peers.”
The COVID-19 pandemic continues to take a toll on hospitals and the healthcare industry, which has seen a number of nurses and clinicians suffering not only higher rates of burnout than before but also simply leaving the industry.
And there has been a financial toll, of course. Some estimates are that the average hospital cost for a COVID-19 patient without insurance is more than $70,000. And then there is the cost in canceled elective procedures, which some estimates have put at between one-third and one-half of patient volume before the pandemic.
HHS has promised to give states at least 60-days notice before lifting the PHE, which allows among other things waivers or flexibility on certain CMS requirements for participating in Medicare.
The declaration of a public health emergency (PHE) on COVID-19 has been extended another 90 days, according to a Department of Health and Human Service (HHS) announcement posted July 19.
The 90 days is up on October 18, but could be extended again. HHS has promised to give states at least 60-days notice before lifting the PHE, which allows among other things waivers or flexibility on certain CMS requirements for participating in Medicare.
While CMS and all the accreditation organizations (AO) have resumed unannounced surveys, they also have said that leniency may be shown to hospitals that are in the middle of a COVID-19 patient surge and still actively working under their emergency incident command structure during the PHE.
Also remember that hospitals and other health organizations have until August 20 to comment on OSHA’s interim rule establishing an emergency temporary standard (ETS) to protect healthcare workers against COVID-19 exposure.
The ETS was issued on June 21 with only 14 days-notice to implement most of the requirements, but the American Hospital Association, the Association for Professionals in Infection Control and Epidemiology and others have pushed for OSHA to delay implementation.
OSHA announced on July 8 that it was extending the comment period until August 20 on the interim rule that creates a new Subpart U in the OSHA standards. The federal agency is asking, among other things, whether the emergency temporary requirements should become permanent.
The agency says comments can be submitted electronically on Federal Register interim rule, Docket No. OSHA-2020-0004, via the Federal eRulemaking Portal at www.regulations.gov. Please follow the online instructions for making electronic submissions.
Many of those commenting noted that it is already becoming increasingly hard to fill open jobs for nurses, doctors, and other healthcare and hospital personnel.
You still have time to comment on OSHA’s emergency temporary standard (ETS) to protect healthcare workers against COVID-19, which was issued on June 21 with only 14 days-notice to implement most of the requirements.
OSHA announced on July 8 that it was extending the comment period until August 20 on the interim rule that creates a new Subpart U in the OSHA standards. The federal agency is asking, among other things, whether the emergency temporary requirements should become permanent.
Already more than 70 people, representing doctor’s offices, health organizations, medical clinics, long-term care facilities, hospitals, and hospital associations, have submitted comments on the interim rule that took up 258 pages in the printed Federal Register.
A sampling of the comments shows how frustrated many healthcare leaders and organizations are at the sudden push to implement OSHA requirements for a pandemic threat that is already 16-months old.
“I am a pediatrician in a mid-sized private practice in Central Florida. I was shocked to find that we have such a limited time to implement a policy that is not a small feat. There are over 250 pages to read, interpret, digest and implement and we have been given less than 14 days to do so,” said one doctor. “This is quite onerous. Several of the mandates are not entirely clear, further complicating the ability to implement them. After 16 months of providing a safe environment for our staff and patients and having zero cases of COVID among our staff from the workplace, I am now going to be held to a standard of having to pay employees who stay home, perhaps for weeks on end, while actively and currently struggling to fill open positions that no one wants since many are getting stimulus subsidies.”
Many of those commenting noted that it is already becoming increasingly hard to fill open jobs for nurses, doctors, and other healthcare and hospital personnel. Trying to train and implement the new requirements at the same time will make the task even harder, they say.
There were also concerns about cost and about how much the ETS conflicted with state and local requirements in many areas. Federal law requires states to have worker protection requirements that are equal or stronger than OSHA standards but bringing those state standards into line is often a long and equally complicated process.
“These regulations are unreasonable expectations to place on long-term care facilities that already need to comply with a host of COVID-19 regulations from CMS, CDC, and state health departments,” noted one facility administrator. “There is a very desperate shortage of health care workers, and facilities can't hire enough workers to care for the residents; therefore, health care workers do not have time to attend meetings to give their input in a Covid-19 plan. Administrators are taking on additional roles as they care for residents and manage the plethora of reporting that CMS is now requiring due to Covid-19. They do not have time to create an OSHA Covid-19 plan, even with templates and resources provided.”
A representative of a community access hospital in Washington said, “I can appreciate OSHA's work. However, this standard is once again placing a continued financial burden on cash-strapped rural hospitals. Our facility has been ahead of the curve throughout the pandemic. Now when those state we are moving towards the end of the pandemic a mask mandate is being initiated. This new standard is well beyond the State of Washington and the Department of Labor and Industries.”
The American Hospital Association submitted comments that it said was “speaking on behalf of almost 5,000 member hospitals, health systems and other health care organizations, and our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups.”
“First, we request that the Occupational Safety and Health Administration (OSHA) delay the ETS compliance dates for at least an additional six months. The agency has dictated that the COVID-19 Health Care ETS be effective immediately upon publication in the Federal Register. This rule is long and complex, and would require changes in hospital policies, procedures and structures. Hospitals and health systems are just now emerging from the disruption caused by the COVID-19 pandemic. Our members have told us that they need more time to implement the many new requirements contained” in the page ETS, wrote Stacey Hughes, the AHA’s Executive Vice President Government Relations and Public Policy.
“For example, hospitals and health systems will have to consider how to deal with the differences between the ETS requirements and guidelines established by the Centers for Disease Control and Prevention, particularly in areas in which the ETS approach will put health care workers at greater risk of COVID-19 infection,” wrote Hughes.
“Among these are the barrier requirements that could impede airflow; another area of concern is the requirement that rooms in which an aerosol-generating procedures are performed be cleaned/disinfected after every such procedure – even when the patient remains in the room and staff are protected by vaccines and personal protective equipment (PPE). Our members also are unsure how they will implement the provisions in the mini respiratory protection standard that permit employees who are not required to wear respirators to bring their own into the hospital,” the AHA comments continued.
“Moreover, this provision will allow employers to provide respirators to employees who are not required to wear them, and without the benefit of fit-testing, medical evaluation or a written program. Many of our members have noted that these requirements, which contradict OSHA’s own PPE and respiratory protection standards, raise huge liability exposures for the employer and puts these employees at additional risk. Changes in hospital policies and procedures are not simply a matter of changing words on paper; they require careful analysis and planning, the acquisition of needed materials and tools, and the retraining of personnel,” wrote Hughes.
This from organizations “that are already busy caring for their communities’ ill and injured,” said the AHA.
If you want to add your comments, OSHA says comments can be submitted electronically “for Docket No. OSHA-2020-0004 via the Federal eRulemaking Portal at www.regulations.gov. Follow the online instructions for making electronic submissions.”
"CMS’s ERM process did not consider national security risks for any of CMS’s programs in accordance with federal requirements," the OIG states in the summary of its findings, released July 8.
Guess who just got dinged after an audit for not doing a risk assessment adequately? It was none other than The Centers for Medicare & Medicaid Services (CMS).
The Department of Health and Human Services’ Office of Inspector General (OIG) recently investigated The Centers for Medicare & Medicaid Services (CMS) to check whether the agency, which oversees patient safety at hundreds of U.S. hospitals, considers national security as part of its enterprise risk management (ERM) process.
“CMS’s ERM process did not consider national security risks for any of CMS’s programs in accordance with federal requirements,” says the OIG summary of its findings, released July 8.
And why did they fail? Because they relied on someone else to do the job.
“CMS lacked policies and procedures that required its programs to consider national security threats because it relied on HHS’s ERM process. As a result, CMS was unable to ensure that it had implemented effective controls to protect against threats from foreign and domestic adversaries,” said the summary.
And yes, CMS had to respond to the OIG’s findings and create a plan of correction.
OIG recommended that “CMS, as part of its ERM program, implement a process to assess all of its programs for national security risks in accordance with OMB Circular No. A-123’s requirement to include new or emerging risks in the risk profile.”
“In written comments to our draft report, CMS concurred with our recommendation. CMS also stated that it currently participates in the HHS enterprise risk management process, is in the early stages of establishing an agency enterprise risk management program, and it will consider how to assess national security risks across its programs.”
You can read the full 11-page OIG report online here.
If, you know, your risk assessments are up-to-date and you don’t have anything better to do.
Earlier this year, as AOs began to renew onsite, unannounced surveys and to catch up on survey backlogs, they left open the possibility of delaying visits if the hospital was in the middle of a COVID emergency and could not guarantee the safety of surveyors.
DNV Healthcare accredited hospitals, critical access hospitals, and psychiatric hospitals should be aware that the accreditation organization (AO) is returning to unannounced, onsite surveys as of September 7.
“This includes initial accreditation, annual/periodic surveys, follow-ups, special surveys, complaint investigations, and reaccreditation surveys,” said the AO in its announcement July 1.
Earlier this year, DNV indicated it was going to join other hospital AOs and CMS in conducting triennial surveys onsite and unannounced, but would continue to do their annual check-in surveys remotely as needed.
All the AOs and CMS delayed or suspended surveys last year during the height of the COVID-19 public health emergency (PHE) unless a complaint was serious enough to necessitate a visit. Eventually AOs moved to conducting some survey elements remotely if the hospital was not in the middle of a COVID surge.
Earlier this year, as AOs began to renew onsite, unannounced surveys and to catch up on survey backlogs, they left open the possibility of delaying visits if the hospital was in the middle of a COVID emergency and could not guarantee the safety of surveyors.
“Now that COVID-19 prevalence rates are down, vaccines are widely available, and travel restrictions are being lifted, all indicators are pointing towards a return to full onsite annual surveys,” said the DNV notice.
“We acknowledge that normal variations in our year-over-year survey scheduling, combined with a return to unannounced onsite visits, will cause some uncertainty for our customers who expect annual survey in August or September,” said DNV officials.
“This notice allows us adequate lead time for surveyor scheduling and cost-effective travel planning but does not leave room for changes or new exclusion requests. If your facility is due for annual/periodic survey in this timeframe, we encourage you to stay prepared for an advance notification of remote survey throughout July and August. If you do not receive advance notice by August 30, expect an unannounced onsite survey after the Labor Day holiday,” according to the notice.
While the state of the PHE is improved, DNV acknowledged that might change.
The current declaration of the PHE “remains in effect until at least July 19, 2021 and is expected to continue throughout calendar 2021. DNV will continue to monitor the PHE, along with local and national conditions using weekly data provided by CMS and CDC. We will adhere to any AO process changes that may be required by CMS and communicate any future adjustments as they emerge.”
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