The Joint Commission’s 2011–2012 standards will bring changes for hospital radiology departments, according to Judith M. Atkins, RN, MSN, president and CEO of McKenna Consulting in Charleston, West Virginia, and Robert A. Wise, MD, medical advisor to the Joint Commission’s Division of Healthcare Quality Evaluation. Atkins outlined some of these changes in “Joint Commission 2011–2012: Update for Hospital Imaging Department,” presented in Dallas, Texas, on August 15, 2011, during the annual meeting of AHRA: The Association For Medical Imaging Management; Wise provided comments later.
Changes in accreditation requirements and processes implemented in line with Joint Commission standards are not specific to radiology, Wise observes. They will affect hospital imaging departments in a variety of areas, however.
One such area is personnel. Hospitals must now have in place a chief nurse, with oversight responsibility for nursing wherever it occurs, including the imaging department. Consequently, Atkins points out, “It’s important that you be able to show that your radiology nurses have some connection to your chief nurse, whether it is via quarterly report or by attending some meetings.”
Similarly, the 2011–2012 requirements place a renewed emphasis on scope of practice. Under this umbrella, radiology-department staff members are permitted to perform only those tasks for which they are qualified by their licensure, registration, or certification. No exceptions are permitted.
In a slightly different vein, a modification to the accreditation-participation requirement mandates that the CEO of all participating organizations must sign a contract agreeing to meet all these accreditation requirements in order to participate in the accreditation process. The executive must certify that information pertaining to incidents and initiatives, whether occurring before, during, or after an accreditation survey, is truthful and accurate. Atkins says that this might cause headaches for hospital radiology departments, noting, “When physicians predocument a postprocedural note—and there are many physicians who do so before the procedure—it is fraud, as far as the Joint Commission is concerned. “
In keeping with new accreditation processes implemented for 2011–2012, the Joint Commission will use tracer methodology, wherein surveyors will evaluate radiology and other specific diagnostic areas based on patient care. Systems and processes will be scrutinized in accordance with the experiences of individual patients, as opposed to those of patients as a whole.
“The Joint Commission standard is the goal you need to reach, and the element of performance (EP) is the action step you need to take to reach the goal,” Atkins explains. All EPs listed in the 2011–2012 Joint Commission manual bear a designation of A or C; compliance with EPs designated A is assessed according to whether an adverse event or deviation from a requirement did not occur at all or, if it did, how many times it occurred, while compliance with EPs designated C is assessed on the basis of frequency or percentage.
Numeric scores assigned for EP compliance range from 0 to 2, with 0 indicating noncompliance (less than 80%, or three occurrences); 1 indicating partial compliance (80% to 89%, or two occurrences); and 2 indicating full compliance (90% to 100%, or one occurrence).
When representatives of the Joint Commission are actually at hospitals’ doors, Atkins observes, they consider occurrences instead of percentages in applying the tracer methodology. “If they’re looking for the medical-history and physician-examination update and find one not done, that’s one occurrence, and you can still be compliant,” she says, “but by the third one, you’re out—it’s a zero.”
She adds that the Joint Commission has produced additional EPs to align with the conditions of participation, and will continue to do so. Hospitals will also be issued requirements for improvement when they are found to be in partial compliance with an EP.
Over the next year, Atkins and Wise say, hospital radiology departments can also expect the Joint Commission to focus more keenly on imaging quality and safety. Wise says, “We are thinking about how to assess whether radiology departments are addressing areas of concern—for instance, whether they are identifying problems with their procedures and introducing measures to rectify them, how they determine whether their staff understand the technology