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CMS Provides Instructions for Teaching Hospitals Regarding Refund of Medical Resident Medicare FICA Taxes

stayalert — Fri, 27 Jan 2012 17:43:11 +0000

The Centers for Medicare and Medicaid Services (CMS) recently issued a MLN Matters article with instructions for teaching hospitals regarding refund of medical resident Medicare FICA taxes. The article informs teaching hospitals and Medicare contractors of the proper way of reporting Internal Revenue Service (IRS) Refunds of Medicare FICA taxes on cost reports. According to the article, teaching hospitals must work with their Medicare contractor to make any necessary changes by January 30, 2012, to their Fiscal Year (FY) 2009 cost reports to be used in the FY2013 wage index.

On March 2, 2010, the Internal Revenue Service (IRS) made an administrative determination that medical residents are exempt from FICA taxes based on the student exception for tax periods ending before April 1, 2005. Recently, the IRS began contacting hospitals, universities, and medical residents who filed FICA (Social Security and Medicare tax) refund claims for these periods.

The MLN Matters article reviews the proper way for teaching hospitals to report the FICA refund for medical residents on the Medicare cost report. The FICA refund must be reported in such a way that it does not impact a hospital’s wage-related costs used to compute the wage index under the Hospital Inpatient Prospective Payment System (IPPS). Follow the link below to review the instructions in detail.

Processing of Laryngoscopy Blades

stayalert — Thu, 26 Jan 2012 19:30:40 +0000

Question:
How should laryngoscopy blades be processed and stored?

Answer:
Laryngoscope blades are considered a semi-critical item according to the CDC’s Healthcare Infection Control Practices Advisory Committee (HICPAC). Semi-critical items are defined as items that come into direct or indirect contact with mucous membranes of the lower respiratory tract. They should be sterilized or subjected to high-level disinfection before reuse.

According to HICPAC, proper cleaning and sterilization or disinfection of reusable equipment are important components of a program to reduce infections associated with devices used for respiratory therapy, pulmonary diagnostic tests, or delivery of anesthesia. Most devices or parts of devices used on the respiratory tract have been categorized as semi-critical because they come into direct or indirect contact with mucous membranes but do not ordinarily penetrate body surfaces, and the associated infection risk following the use of these devices in patients is less than that associated with devices that penetrate normally sterile tissues. Thus, after they are thoroughly cleaned, they can be subjected to high-level disinfection by either using liquid chemical disinfectants that are cleared by the Food and Drug Administration (FDA) for use on medical instruments or by pasteurization at greater than 70 degrees C for 30 minutes.

Recommendations for the processing of laryngoscopy blades from Guidelines for Preventing Healthcare-Associated Pneumonia include:

▪	Sterilization or Disinfection and Maintenance of Equipment and Devices
▪	General Measures:
▪	Thoroughly clean all equipment and devices to be sterilized or disinfected.
▪	Whenever possible, use steam sterilization (by autoclaving) or high level disinfection by wet heat pasteurization at greater than 158 degrees F (greater than 70 degrees C) for 30 minutes for reprocessing semi-critical equipment or devices that are not sensitive to heat and moisture. Use low-temperature sterilization methods (as approved by the Office of Device Evaluation, Center for Devices and Radiologic Health, FDA) for equipment or devices that are heat- or moisture-sensitive. After disinfection, proceed with appropriate rinsing, drying, and packaging, taking care not to contaminate the disinfected items in the process.

According to the Joint Commission, surveyors will evaluate processes addressing the disinfecting of laryngoscope blades to ensure that they are safe for use on the next patient. Laryngoscope blades will be checked to ensure the blades were:

▪	Processed via either sterilization or high-level disinfection.
▪	Packaged in some way as not to contaminate the disinfected items.
▪	Stored in a way that would prevent recontamination. The Joint Commission has given the following examples of storage; compliant storage includes, but is not limited to, a peel pack post steam sterilization (long-term) or wrapping in a sterile towel (short-term). Examples of noncompliant storage would include unwrapped blades in an anesthesia drawer, as well as unwrapped blades on top of a code cart.

Laryngoscope handles are considered contaminated after use and must be processed prior to use on the next patient. Follow the manufacturer’s instructions for processing.

Check your state for additional law or regulations addressing the processing of Laryngoscope blades.

Related Products from MCN:
Infection Prevention and Control Manual

Guidance for Nurses on the Use of Social Media

stayalert — Wed, 25 Jan 2012 20:43:33 +0000

The National Council of State Boards of Nursing recently published a brochure providing guidance to nurses on the use of social media. According to NCSBN, the brochure is intended for both new and experienced nurses and reviews ways in which social media can be used within the nursing profession while complying with privacy and confidentiality laws. The brochure reviews important information including:

• Social media in the workplace

• Confidentiality and privacy

• Potential consequences of social media misuse

• Social medias impact on patient safety and care

• Common myths and misunderstanding of social media

The brochure is available on the National Council of State Boards of Nursing’s website. In addition to making this brochure available to your nurses you should also encourage them to review your hospital’s social media policy to be certain that any social media use is in adherence with organizational policies and procedures.

Joint Commission Modifies Several Laboratory Standard Elements of Performances Effective February 1 2012

stayalert — Mon, 23 Jan 2012 21:27:38 +0000

The Joint Commission has announced revisions, effective February 1, 2012, to several elements of performance (EPs) within the Laboratory Accreditation Program as a part of their application process for deeming authority for clinical laboratories by the Centers for Medicare & Medicaid Services (CMS). The revisions were made to ensure TJC Laboratory EP’s comply with Clinical Laboratory Improvement Amendments of 1988 (CLIA). The revisions were made to the following elements of performance:

• LD.04.05.09, EP 2

• QSA.02.01.01, EP 2

• QSA.05.09.01, EP 2

• QSA.02.01.01, EP 2

• QSA.05.09.01, EP 2

• QSA.08.03.01, EP 5

• QSA.08.04.01, EPs 5, 7

• QSA.08.05.01, EP 2

• QSA.08.06.01, EP 4

The revisions are currently available on TJC’s website. According to TJC, CMS has indicated that further changes to standards will be required. TJC will communicate additional changes as they are made.

OIG Issues Report on Hospital Incident Reporting Systems

stayalert — Fri, 20 Jan 2012 21:53:56 +0000

The Office of Inspector General (OIG) recently issued a report indicating the majority of Hospital incident reporting systems capture only a small percentage of adverse events experienced by Medicare beneficiaries. The report, one in a series about adverse events in hospitals, reviewed October 2008 discharge data for Medicare beneficiaries from 189 hospitals.

As a Condition of Participation in the Medicare program, federal regulations require that hospitals develop and maintain a Quality Assessment and Performance Improvement (QAPI) program. To satisfy QAPI requirements, hospitals must “track medical errors and adverse patient events, analyze their causes, and implement preventive actions and mechanisms that include feedback and learning throughout the hospital.”

The report found the following:

•	Hospital staff did not report 86 percent of events to incident reporting systems, partly because of staff misperceptions about what constitutes patient harm.
•	Hospital accreditors reported that in evaluating hospital safety practices, they focus on how event information is used rather than how it is collected.

Recommendations in the report include:

•	CMS should develop guidance for accreditors regarding surveyor assessment of hospital efforts to track and analyze events and should scrutinize survey processes when approving accreditation programs.

The key take-away in this report is that simply having an incident reporting system in place is not sufficient. You must ensure that hospital personnel is educated and encouraged to use the system you have in place because hospitals rely so heavily on these incident reporting systems to track and analyze adverse events. Improving the usefulness of these systems is critical to hospital efforts to improve patient safety.

Radiation Safety

stayalert — Thu, 19 Jan 2012 19:27:09 +0000

Question:
I’m looking for information or guidelines/standards for documentation of fluoroscopy time and requirements to shield patients.

Answer:
Best practice has always been to shield patients and staff from radiation.

The use of shielding for radiation protection is required by both the National Council on Radiation Protection and Measurement (NCRP), the Nuclear Regulatory Commission (NRC), and various federal and state regulations.

The following are regulations/recommendations that address the shielding of patients from radiation and documentation of fluoroscopy time.

•	CMS Conditions of Participation 482.26(b) (1) states that the proper safety precautions must be maintained against radiation hazards. This includes adequate shielding for patients, personnel, and facilities, as well as appropriate storage, use and disposal of radioactive materials.
•	The Joint Commission’s Sentinel Event Alert – Radiation Risks of Diagnostic Imaging offers the following recommendations:

•	Develop and implement policies and procedures that delineate physical protective risk reduction measures to be taken by staff delivering radiation to patients, including appropriate lead shielding for both patients and employees and radiation-protection training for all technologists.
•	Record the dosage or exposure as part of the study’s summary report of findings.

•	Also the subset of sentinel events that is subject to review by The Joint Commission includes any occurrence that meets any of the following criteria:

•	Prolonged fluoroscopy with cumulative dose >1,500 rads to a single field or any delivery of radiotherapy to the wrong body region or >25% above the planned radiotherapy dose

Reference:
Joint Commission Sentinel Event Alert Issue 47, Radiation Risks of Diagnostic Imaging. August 24, 2011.

Related Products from MCN:
Imaging Services Policy and Procedure Manual

Joint Commission Releases Final Revisions to Telemedicine Privileging Standards for Hospitals

stayalert — Wed, 18 Jan 2012 18:06:38 +0000

Since September 2009, The Joint Commission and The Centers for Medicare and Medicaid Services have been working to resolve the discrepancies between their conflicting telemedicine credentialing and privileging requirements. CMS regulations required hospitals and critical access hospitals receiving telemedicine services to privilege each physician or practitioner providing services to its patients as if such practitioner were onsite. This was in direct conflict with the Joint Commission policy of allowing “privileging by proxy”, which allows for one TJC-accredited facility to accept the privileging decisions of another TJC-accredited facility.

On July 5, 2011 CMS’s final telemedicine rules became effective. MCN Healthcare’s StayAlert! Compliance system reviewed that final rule and provided an example policy and procedure to assist with compliance on August 3, 2011. In response to CMS’ final rule, TJC issued a statement that they were reviewing their telemedicine requirements to ensure they were aligned with CMS’ requirement. To that end, TJC recently released final revisions to requirements related to the credentialing and privileging of telemedicine practitioners in hospitals. Standards LD.04.03.09 and MS.13.01.01 are effective for hospitals immediately.

Summary of Revisions for Hospitals:

LD.04.03.09, EP 23: Hospitals using TJC for deemed status must ensure there is a written agreement between the originating site and the distant site that specifically lists the requirements that the distant-site telemedicine providers’ credentialing and privileging process must meet.

MS.13.01.01, EP 1: Hospitals must ensure that distant-site practitioners have a license that is issued or recognized by the state in which the patient is receiving telemedicine services.

Notice: Office of Healthcare Quality Releases Healthcare Associated Infection Prevention Family and Caregiver Education Materials

stayalert — Fri, 13 Jan 2012 16:11:53 +0000

The Office of Healthcare Quality (OHQ) and the Department of Health and Human Services (HHS) Partnership for Patients have released materials associated with the WAVE campaign, an initiative designed to educate families and caregivers about healthcare-associated infections (HAIs) and the steps they can take to protect their loved ones.

WAVE stands for:

“W” – Wash Hands

“A” – Ask Questions

“V” – Vaccinate

“E” – Ensure Safety

Materials are available electronically or in print and consist of an easy to read brochure and wallet card.

Formed in 2011, the HHS Partnership for Patients is a public-private partnership between hospitals, doctors, nurses, pharmacists and other health professionals, employers, unions, patient advocates, health plans, and others to improve the safety of health care in America.

Nursing Care Plans and ASCs

stayalert — Thu, 12 Jan 2012 19:20:12 +0000

Question:
Does an Ambulatory Surgery Center (ASC) need to include a nurse’s care plan in each patient’s medical record?

Answer:
Yes, a plan of care and revisions of the plan of care must be included in every patient’s medical record per Joint Commission standard PC.01.03.01 and RC.02.01.01.

Ambulatory Surgery Centers are accredited under the Joint Commission standards for Ambulatory Care.

Standard PC.01.03.01 requires that healthcare organizations plan the patient’s care. Planning for care, treatment, or services is individualized to meet the patient’s unique needs. The first step in the process includes creating an initial plan for care, treatment, or services that is appropriate to the patient’s specific assessed needs. To continue to meet the patient’s unique needs, the plan must be maintained and revised based on the patient’s response

Standard RC.02.01.01 states that the clinical record contains information that reflects the patient’s care, treatment, or services. The clinical record contains the following clinical information:

• The patient’s initial diagnosis, diagnostic impression(s), or condition(s)

• Any findings of assessments and reassessments

• Any allergies to food

• Any allergies to medications

• Any conclusions or impressions drawn from the patient’s medical history and physical examination

• Any diagnoses or conditions established during the patient’s course of care, treatment, or services

• Any consultation reports

• Any progress notes

• Any medications ordered or prescribed

• Any medications administered, including the strength, dose, and route

• Any access site for medication, administration devices used, and rate of administration

• The patient’s response to any medication administered

• Any adverse drug reactions

• Plans for care and any revisions to the plan for care

• Orders for diagnostic and therapeutic tests and procedures and their results

Related Products from MCN:
Outpatient Surgery and Ambulatory Services Policy and Procedure Manual

About MCN Healthcare:
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Learn more at www.mcnhealthcare.com.

CMS Updates Guidance Related to Hospital Facility and Medical Equipment Maintenance

stayalert — Wed, 11 Jan 2012 20:16:01 +0000

The Centers for Medicare and Medicaid Services recently published updated guidance for Appendix A of the State Operations Manual related to hospital facility and medical equipment maintenance. Section 482.41(c)(2) requires that hospital facilities, supplies, and equipment must be maintained to ensure an acceptable level of safety and quality.

According to CMS, Hospitals expected to maintain equipment inventories and documentation of their maintenance activities. Federal or State laws and regulations (including Life Safety Code requirements adopted as part of Federal regulations) may require that equipment maintenance activities (i.e., maintenance, inspection and testing) be performed in accordance with the manufacturer’s recommendations, or may establish other maintenance requirements. In these instances, the hospital must be in compliance with the most stringent maintenance requirements mandated. Absent such mandated requirements, it is acceptable for the hospital to follow the manufacturer’s recommended maintenance schedule, to schedule more frequent maintenance than the manufacturer recommends, or, in some cases of non-critical equipment, to schedule less frequent equipment maintenance than the manufacturer calls for.

In summary CMS clarifies the following in this updated guidance:

•	Alternate equipment maintenance schedules permitted in some instances: Hospitals may adjust maintenance, inspection, and testing frequencies for some facility and medical equipment below those recommended by the manufacturer, based on an assessment by qualified personnel of the risk to patient and staff health and safety.
•	Manufacturer-recommended maintenance frequency is required for: All equipment critical to patient health and safety; and Any new equipment until a sufficient amount of maintenance history has been acquired.
•	Alternative equipment maintenance methods are not permitted: Hospitals must continue to follow the manufacturer’s recommended techniques for maintaining equipment, even if the hospitals alter the frequency of maintenance activities.

If a hospital is adjusting non-critical equipment maintenance frequencies to be below those recommended by the manufacturer, such adjustments must be based upon a systematic, evidence-based assessment. The hospital must document the assessment for all equipment with less frequent maintenance than what the manufacturer recommends, including the selected maintenance strategy that led to the lower adjusted frequency, and supporting evidence. The evidence must provide support that the frequency adjustment will not adversely affect patient or staff health and safety. The assessment of whether it is appropriate to use a maintenance strategy that results in less frequent maintenance than what the manufacturer recommends must be performed by qualified personnel. In the case of medical equipment, a clinical or biomedical technician or engineer would be considered qualified.

To be compliant you will want to ensure your procedures address hospital-approved equipment maintenance strategies, equipment maintenance reporting and policies addressing maintenance of specific pieces of equipment.