Critical Access Hospitals (CAH)

Critical Access Hospitals (CAH) What every CAH needs to know about the Conditions of Participation 2011

Speaker Sue Dill Calloway RN, Esq. CPHRM AD, BA, BSN, MSN, JD President 5447 Fawnbrook Lane Dublin, Ohio 43017 614 791-1468 sdill1@columbus.rr.com 2 2

Part 2 of 3

Governing Body 241 • Has governing body or individual that assumes legal responsibility for implementing and monitoring P&Ps, • Must have 1 governing body or responsible person, • Board must determine what categories of practitioners are eligible for appointment and reappoint to MS (NP, PA, dentist, CRNA) and there is written criteria for staff appointments ,

Governing Body 241 • Done with advice of MS, • Must be consistent with state and federal law requirements, • Board approves MS bylaws and any revisions-surveyor will look for this, • Board responsible for conduct of CAH and for quality of care to patients,

Governing Body • Criteria for MS is based on individual character, competence, training, experience and judgment, • Surveyor will look to see Board or written documentation of person responsible for CAH, • Will look to verify that Board has categories of practitioners for appointment to MS, • Confirm that Board appoints all members to the MS,

Disclosure 242 • CAH discloses the names and addresses of its owners or those with controlling interest, • Either directly or indirectly has 5% or more ownership, • Surveyor will look for policy on reporting changes of ownership, • Need policy on how to reporting changes for person responsible for operation of hospital (CEO) to state agency and also for reporting changes in medical director (243,244),

Staffing 250 • CAH has professional staff that includes one or more physicians, and may include PA, NP, or CNS, • Need to have organizational chart which shows names of all MD/DO and AHP (allied health professionals), • Surveyor will review work schedules,

Staffing 252 • All ancillary staff must be supervised by professional staff, • Have sufficient staff to take care of patients (emergency services, nursing services, Tag 253), • Will review staffing schedules and daily census records,

Staffing 252 • MD, DO, or AHP must be available at all times to furnish care, • Must show practitioner is available and shows up when patients present to the hospital, • Doesn’t mean they have to be there 24 hours a day,

Nurse on Duty 255 • Must have a RN, CNS, or LPN on duty whenever there is one or more inpatients, • Surveyor will review staff schedules to make sure,

Physician Responsibilities 257 • MD/DO must provide medical directions of staff, • Surveyor will make sure is available for consultation and supervision of staff, • Physicians must periodically review charts of PA and NP and surveyor will look for documentation of same, • MD/DO must provide orders for patients and must review and sign all MR cared by AHP (260),

Physician Supervision • Must have a doctor on staff and must perform medical oversight, • Will want evidence that the Dr. provides oversight and is available for consultation, • How do you ensure that the doctor participates in the development of policies and procedures? • What evidence the there is periodic review of patient records by the doctor?

PA, NP,CNS 263 • Must be members of CAH staff, • Must participate in development and review of P&P, • Interview them to determine their participation and knowledge of policies, • Will interview to determine their level of involvement in development of P&Ps, • Policies also need to be consistent with state standards of practice,

Transfer of Patients 267 • Arrange for transfer of patients who need services that can not be furnished, • Must sent the patient’s medical records, • Remember EMTALA is a separate CoP that every CAH must follow, • Make sure you have a transfer policy and it should be consistent with EMTALA,

Patient Admission 268 • Whenever a patient is admitted by NP, PA, or CNS, a physician on the staff must be notified, • CMS requires that Medicare and Medicaid patients be under the care of a MD/DO if patient has medical or psych problems that is outside of the scope of their practice, • Admitting privileges must be consistent with what state law allows, • Surveyor will look to make sure MD/DO monitor care for any medical problem outside their scope of practice,

Patient Care Policies 271 • Services are provided in accordance with appropriate P&P, • Will review policies, • Review sampled records, • Observe staff delivering care to the patient, • P&P need to be developed by group of professional person sand include 1 MD/D and 1 or more PA, NP, CNS if on staff and one member is who not a member of the staff (272), • Will interview DON to determine role in policy development (272),

Policies (Scope of Services) 273 • Need P&P on scope of services provided by CAH directly or through agreement, • Should include statements like “taking complete medical histories, providing complete physical examinations, laboratory tests including” (with a list of tests provided) would satisfy this requirement, • Should include arrangements made with Hospital X for providing the following services with list of specialized diagnostic and lab testing,

Emergency Medical Services 274 • Need P&P for emergency medical services, • Policies should show how the CAH would meet all of its emergency services requirements,

Guideline for Medical Management 275 • Guidelines on managing health problems that include when medical consultation is needed, • And patient referral (275), • Guidelines on maintaining medical records and procedure for periodic review and evaluation of the services provided at the CAH,

Medical Management 275 • Needs to include the scope of medical acts which may be done by PA or NP, • What medical procedures can PA or NP do? • Guidelines need to describe the medical conditions, signs or development that require consultation,

Drugs and Biologicals 276 • Rules for the storage, handling, dispensing, and administration of drugs and biologicals, • Need to store drugs in accordance with acceptable standards of practice, • Keep accurate records of the receipt and disposition of all scheduled drugs, • and all outdated, mislabeled, or otherwise unusable drugs are not available for patient use,

Schedule Drugs SCHEDULE I • A: Drug has no current accepted medical use. B: Drug has a high potential for abuse. • Class examples: Heroin, Methaqualone, LSD, Peyote, Psilocybin, Marijuana, Hashish, Hash Oil, and various amphetamine variants. SCHEDULE II • A: Drug has current accepted medical use. B: Drug has high potential for abuse. • Class examples: Dilaudid, Demerol, Methadone, Cocaine, PCP, Morphine and certain cannabis, amphetamine, and barbiturates types . SCHEDULE III • A: Drug has current accepted medical use. B: Drug has medium potential for abuse. • Class examples: Opium, Vicodan, Tylenol w/codeine and other narcotic, amphetamine, and barbiturate types.

Schedule Drugs SCHEDULE IV • A: Drug has current accepted medical use. B: Drug has low potential for abuse. • Class Examples: Darvocet, Xanax, Valium, Halcyon, Ambien, Ativan, and other barbiturate types. SCHEDULE V • A: Drug has accepted medical use. B: Drug has lowest potential for abuse. • Class examples: Lomotil, Phenergan, and liquid suspensions

Pharmacy 276 • The pharmacy director, with input from appropriate CAH staff and committees, develops, implements and periodically reviews and revises P&P on the provision of pharmaceutical services, • Store drugs as required by manufacturer, • Pharmacy records detailed to follow flow of drugs from entry to dispensing and administration, • Employees provide pharmacy services within scope of license and education, • Pharmacy must maintain control over all drugs and medications in the CAL including floor stock,

Inspections/Staff Interviews The following must be inspected: • ED services and how services are available 24 hours a day, • Availability of equipment, blood, drugs, and supplies, • Physical plant and environment as part of life safety code, • Drug storage area (C276), • Direct care services; how are diagnostic and therapeutic services provided (C281), • Lab services-CLIA certificate,

Dispensing of Drugs 276 • Drugs must be dispensed by licensed pharmacist, • Only pharmacists or pharmacy-supervised personnel compound, label and dispensedrugs or biologicals, • How do you make sure accurate records of receipt and disposition of scheduled drugs, • Who has access and and keys to drug area? • How do you make sure no outdated drugs or mislabeled drugs? • Will inspect the pharmacy,

Pharmacy 276 • Pharmaceutical services can be provided as direct services or through an agreement, • Does not require continuous on-premise supervision at the CAH’S pharmacy, • May be accomplished through regularly scheduled visits, and/or telemedicine in accordance with law and regulation and accepted professional principles, • A single pharmacist must be responsible for the overall administration of the pharmacy,

Pharmacist 276 • The pharmacist must be responsible for developing, supervising, and coordinating all the activities of the CAH-wide pharmacy service, • And must be thoroughly knowledgeable about CAH pharmacy practice and management, • Job description or the written agreement for the responsibilities of the pharmacist should be clearly defined and include development, supervision and coordination of all the activities of pharmacy services,

Pharmacy 276 • Pharmacy must have sufficient staff in types, numbers, and training to provide quality services, including 24 hour, 7-day emergency coverage, • Must have enough staff to provide accurate and timely medication delivery, ensure accurate and safe medication administration, • Staff to participate in PI, • System so medication orders get to the pharmacy and drugs back to patients promptly,

Pharmacy 276 • Must keep records of the receipt and disposition of all scheduled drugs, • Pharmacist must make sure all drug records are in order and that an account of all scheduled drugs is maintained and reconciled, • From point of entry to administration to patient or destruction or return of drug to manufacturer, • Must have a P&P and system to identify loss or diversion of all controlled substances,

Pharmacy 276 • The P&P established to prevent unauthorized usage and distribution must provide for an accounting of the receipt and disposition of drugs, • All prescribers’ medication orders (except in emergency situations) should be reviewed for appropriateness by a pharmacist before the first dose is dispensed, • Note in next slide where CAH cited if no initial pharmacy review done when pharmacy closed (use tele-pharmacy)

First Dose Rule • Therapeutic appropriateness of a patient’s medication regimen; • Therapeutic duplication, • Appropriateness of the route and method of administration; • Medication-medication, medication-food, medication-laboratory test and medication-disease interactions; • Clinical and laboratory data to evaluate the efficacy of medication therapy to anticipate or evaluate toxicity and adverse effects; and • Physical signs and clinical symptoms relevant to the patient’s medication therapy.

Pharmacy USP 797 276 • Sterile products should be prepared and labeled in a suitable environment by appropriately trained and qualified personnel, • Remember the USP 797 (officially introduced on 1-1-04 and became enforceable by FDA, • Also adopted by TJC and many state pharmacy boards, • Information is available at www.usp.org along with proposed changes,

Pharmacy • Pharmacy should participate in CAH decisions about emergency medication kits, • Supply and provision of emergency medications stored in the kits must be consistent with standards of practice, • and appropriate for a specified age group or disease treatment,

Pharmacy • Pharmacy should be involved in the evaluation, use and monitoring of drug delivery systems (IV pumps, PCA) • Schedule Drugs and potential for error of administration devices, • and automated drug-dispensing machines (Pyxis, Omnicell, Meditol et. al.),

Pharmacy • Medications must be prepared safely, • Safe preparation procedures could include; • Only the pharmacy compounds or admixes all sterile medications, intravenous admixtures, or other drugs except in emergencies or when not feasible (for example, when the product’s stability is short). • Staff uses safety materials and equipment while preparing hazardous medications.

Pharmacy Whenever medications are prepared, staff uses appropriate techniques to avoid contamination during medication preparation, which include, but are not limited, to the following: • Using clean or sterile technique as appropriate; • Maintaining clean, uncluttered, and functionally separate areas for product preparation to minimize the possibility of contamination; (con’t)

Pharmacy • Using a laminar airflow hood or other appropriate environment while preparing any intravenous (IV) admixture in the pharmacy, any sterile product made from non-sterile ingredients, or any sterile product that will not be used with 24 hours; and • Visually inspecting the integrity of the medications.

Drug Storage 276 • All drugs must be kept in a locked room or container, • If the container is mobile or readily portable, when not in use, it must be stored in a locked room, monitored location, or secured location that will ensure the security of the drugs, • Must be stored in a manner to prevent access by unauthorized individuals,

Drug Storage 276 • Persons without legal access to drugs cannot have unmonitored access to drugs, • Cannot have keys to medication storage rooms, carts, cabinets, or containers (housekeepers, security), • Drug storage is a big issue with both CMS and the Joint Commission

Nursing Med Carts/Anesthesia Cart • When not in use, nursing medication carts, anesthesia carts, and other medication carts that contain drugs, • Must be locked or stored in a locked storage room, • If cart is in use and unlocked, someone with legal access to the drugs in the cart must be close by and directly monitoring the cart (276),

Outdated Drugs 276 • Must have a pharmacy labeling, inspection, and inventory management system that ensures that outdated, mislabeled, or otherwise unusable drugs are not available for patient use, • Surveyor will make sure staff is familiar with medication P&P, • Need policy to ensure P&P are periodically reviewed, • Will look to see if access to concentrated solutions is restricted (KCL, NaCl greater than 0.9%),

Surveyor Procedure • Look for policy for the safeguarding, transferring and availability of keys to the locked storage area, • Inspect the pharmacy and where medications are stored, • Inspect patient-specific and floor stock medications to identify expired, mislabeled or unusable medications, • If the unit dose system is utilized, verify that each single unit dose package bears name and strength of the drug, lot and control number equivalent, and expiration date.

Surveyor will……. 276 • Review P&P to determine who is designated to remove drugs from the pharmacy or storage area, • Determine if the pharmacist routinely reviews the contents of the after-hours supply to determine if it is adequate to meet the after-hours needs of the CAH. • Interview the Pharmacy Director, pharmacist and pharmacy employees to determine their understanding of the controlled drug policies,

Reporting ADR and Errors 277 • Procedures for reporting adverse drug reactions and errors in the administration of drugs, • Written P&P to require these be reported immediately to practitioner who ordered the drug, • Entry should be made in the MR, • Significant ADRs should be reported to the FDA in accordance with MedWatch program,

Reporting ADR and Errors 277 • Important to flag new types of mistakes as they occur and create systems to prevent their recurrences (system analysis approach), • System should work through those mistakes and continually improve and refine things, based on what went wrong (example RCA), • See sample forms to use for RCA and FMEA,

Reporting ADR and Errors 277 • Reduction of medication error and adverse reactions by effective reporting systems that proactively identify causative factors and are used to implement corrective actions to reduce or prevent reoccurrences (FMEA), • Need to develop definition of medication error that includes near misses,

High Risk Meds/Definition 277 • System to minimize high risk medications (chemo, insulin, Heparin), • Need to have a policy on high alert drugs and what you do (double checks) • Such systems could include: checklists, dose limits, pre-printed orders, special packaging, special labeling, double-checks and written guidelines,

http://ismp.org/Tools/highalertmedications.pdf

Critical Access Hospitals (CAH)