Preventing costly CMS readmission fines due to Healthcare-Associated Infections (HAI’s) Part IV: Focus on Mishaps and Utility-related Emergencies

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By Randall B. Charpentier,

HEM, President/Principal Consultant: HealthSafe New England

Randy Charpentier

Randy Charpentier

In my blogpost series regarding the CMS report on fines issued to hospitals for having too many patients return within a month for additional treatments.  I’ve focused my recent posts on Indoor Air Quality (IAQ) and ventilation systems as a primary driver in preventing HAI’s and will present challenges and opportunities to assist healthcare executives in addressing this key component now! (Blogseries IntroPart I-Hand Hygiene, Part II-PPE, Part IIIa-Ventilation, Part IIIb-Ventilation Con’t) In this post I’ll attempt to address utility-related emergency responses and how they may positively or negatively impact HAI’s and therefore readmission fines associated with them.

Mishaps and utility related emergencies

Mishaps and utility related emergencies occur in healthcare facilities all the time. Most likely caused by an aging infrastructure, during routine/corrective/preventive maintenance, during construction and/or renovation activities, and/or a consequence of human factors such as rushing, fatigue, and staffing.  These events include but are not limited to: fire, chemical spill, unanticipated release of energy such as steam, water, medical gases, or sanitary waste water and other plumbing apparatus. All of these scenarios should be outlined in every healthcare facilities emergency response plans.

How a facility responds is key to managing these mishaps/emergencies.

Emergency water release

Emergency water release

Once an event occurs, the affected area should be immediately isolated and non – essential personnel evacuated. If a patient room or suite is impacted, they should immediately be evacuated before the situation is assessed and corrected. Isolation means the impacted area should have at a minimum a physical protective barrier capable of being placed under negative/HEPA filtered pressure that also prevents inadvertent entry by staff, patients, visitors. Secondly after the affected area has been isolated, all personnel should be equipped with PPE depending on the nature of the emergency and problem addressed. A release of particulate, biological and/or chemical agent requires varying levels of PPE and responding personnel should be adequately trained and appropriate PPE provided to protect oneself against exposure to those agents. If exposure to the agent is unknown, than the maximum level of protection must be provided.

When an emergency involves an open ceiling grid, wall cavity, crawl space, or exposed mechanical system

Under no circumstance should an emergency response event expose any personnel to a mishap involving an open ceiling grid, wall cavity, crawl space, or exposed mechanical system that releases an unknown contaminant without maximum protection. These areas are some of the most contaminated parts of a healthcare facility and only trained / adequately protected personnel should be allowed to address the event to prevent additional personal or property-equipment damage. This exposure to HAI’s is typically overlooked and not analyzed in detail due to the focus on the actual emergency response, and not the unintended consequences of pathogen/biological/gas/vapor/mist or chemical contamination on the affected patient/staff/visitor population and areas directly/indirectly impacted. All impacted areas should be tested with direct reading industrial hygiene equipment and confirmed with indirect methodologies such as surface and airborne sampling prior to re-occupancy depending upon the contaminant.

The Joint Commission requires 4 drills annually, but is this enough?

Every healthcare facility is required by The Joint Commission to conduct 4 drills annually, 2 external and 2 internal. Is this an adequate method to determine, evaluate and assess a facilities readiness to respond to an emergency? If experience tells me anything, it falls way short. I’ve seen more facility related emergencies where facility and environmental service personnel respond to the scene with no protective gear or safety equipment, no physical or environment barriers to protect affected parties, or any environmental sampling strategies in place to confirm that the impacted area is free from contaminants allowing patients, staff and visitors to reoccupy once the scene is brought under control. In addition to those required by the Joint Commission, emergency management drills should be conducted at least quarterly with contaminant scenarios changed frequently to allow responding personnel to gain proficiency in proper PPE, Environmental Containment strategies and clearance sampling methodologies under the supervision of an Industrial Hygienist.

In my next and final post in this series I’ll discuss important technology used for controlling HAIs from a safety and risk management perspective.

Randall Charpentier is a 20 year experienced, safety and risk management consultant specializing in healthcare compliance and best practice management. Project experience ranges from leading teams on the construction of the west coast space shuttle project, working internationally & domestically for leading environmental engineering firms conducting real estate assessments involving occupational and environmental risks, assessing business operational risks concerning commercial insurance policies, and reducing/eliminating exposures/hazards, to leading world renowned, top ten/one hundred community based & BioMedical Research/Teaching hospitals, with development and execution of best practices with EOC, Fire/Life Safety, Infection Prevention in Healthcare Construction, and Emergency Management programs.  HSNE’s/Randall’s passion is keeping patients, staff and visitors safe in a healthcare setting.  CMS is measuring safety and quality in healthcare facilities basing reimbursement on healthcare outcomes. Does your facility measure up? If not, you should conduct a risk assessment. Is your facility compliance or results driven? To find out, contact rcharp@hsnellc.com or www.hsnellc.com, or LinkedIn profile.

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