By Chris Hayhurst
The Duke University Health System medical equipment management plan (MEMP) quite possibly is only an interesting read if you are the manager of a clinical engineering, healthcare technology management (CE/HTM) department, or maybe the accounting department. But the document is essential to ensuring Biomed techs have the tools they need to maximize uptimes for the life-saving equipment clinicians require to provide quality patient care.
The Duke MEMP, which accessible online, “defines the mechanisms for interaction and oversight of the medical equipment used in the diagnosis, treatment, and monitoring of patients.” It then details how the health system’s clinical engineering department manages equipment risks and inspects and maintains devices according to its policies and procedures. It also offers insight on the CE department’s attention to performance improvement, and on its process for evaluating the plan itself. Overall, the report is organized and clearly written—and is slightly less than six pages long.
“For a medical equipment management plan to be effective it has to be concise,” says Matthew Baretich, PE, PhD, a clinical engineering consultant and president of Baretich Engineering. In his work, he says, he’s helped a number of organizations revise their MEMPs (he’s also done consulting work for Duke, but he did not contribute to their MEMP). And while most that he’s seen have contained the information that’s required by hospital surveyors like the Joint Commission, many have also been very poorly written and hard to follow. “Your management plan doesn’t have to be fine literature, but it does need to communicate what you’re doing in a way that’s easy for readers to understand.”
ECs, EPs, AEMs, & RPTs
In a 2016 article about writing MEMPs that Baretich penned for 24×7, he notes that the plan is meant to help HTM departments meet The Joint Commission’s standards. Those standards, EC.02.04.01 (“The hospital manages medical equipment risks”) and EC.02.04.03 (“The hospital inspects, tests, and maintains medical equipment”), each include Elements of Performance (EPs) that surveyors use to assess and score compliance. “The MEMP is our roadmap for HTM activities,” Baretich wrote. “Within the constraints of The Joint Commission requirements, we get to draw our own map.”
According to Baretich, since 2016 he’s become aware of just two major changes to those requirements. The first involves alternative equipment maintenance (AEM) programs, while the second has to do with relocatable power taps (RPTs). On the AEM side of things, Baretich says, organizations must now either “include the details of any AEM program in the MEMP or reference it somehow so a surveyor knows where to find it.” (In the Duke University Health System MEMP, they address their AEM program by noting that their maintenance schedule is kept in their database management system, and that “items included in the AEM will be recommended by Clinical Engineering and be based on records provided by the hospital’s contractors, information made public by nationally recognized sources or records of the hospital’s experience over time.”) The new requirement for RPTs is similarly straightforward, Baretich says. “Again, all you need to do is briefly explain that you handle RPTs according to your organization’s power strip policy and refer to that written policy.” (Baretich provided a sample RPT policy in a November 2017 article here.)
When it comes to the writing itself, Baretich says, he recommends dropping “the stuffy, formal language” and instead focusing on the basics. “When I help someone rewrite their management plan, I typically just say to put down the paperwork, and then I read them one of The Joint Commission requirements and ask them to tell me how they address it.” Most people, Baretich says, will reply with a few really good sentences. “So, then we just go ahead and write them down. Nothing fussy, just right to the point so everything is clear.”
Fun Yet Serious
An HTM professional who is already in line with Baretich’s approach to medical equipment management plan writing is Benjamin Esslinger, CHTM, CBET. As the manager of medical engineering with Eskenazi Health at Sidney and Lois Eskenazi Hospital in Indianapolis, Esslinger has worked on the facility’s MEMP each of the last three years, he says. “Creating this document and then walking away from it is absolutely not acceptable in our environment,” he notes. “So, we do an annual review of the actual program; but then we also make changes ongoing throughout the year.”
The revision process, Esslinger explains, is a collaborative effort involving not only HTM, but also members of the organization’s facilities team, and especially the safety officer from the environment of care committee. “It’s read by a multitude of people—HTM staff, leaders within the organization, and then, obviously, The Joint Commission surveyors. We look at everything, and we consider everyone’s feedback, and we’re always trying to make it better.” One thing he personally tries to do is make the document “fun” to read. “If it’s monotonous and boring, no one will want to look at it. It’s not that we’re making jokes or anything—we take it very seriously. But we really want people to read it, so we try to tie it into our operations and the things that are happening on a daily basis.”
The MEMP has become so important to their work, Esslinger adds, that new HTM hires are required to read it as part of their orientation. “They spend the better part of a day reviewing it, and then that afternoon or the following day they sit down with me and I ask them questions about each of the main, pertinent areas. We want to know that they understand how we operate as a department—that they understand the guidelines they need to operate within.” For that reason, he says, they’ve even added certain topics to their MEMP that aren’t required by The Joint Commission. “Like our communication policy, for example. The surveyors may not care about that, but to us, that’s an important part of equipment management.”
As a manager, Esslinger adds, he often relies on the MEMP himself to help him do his job. “You realize, as an operational manager, that if you put together a good medical equipment management plan and understand the policies and procedures and guidelines of your department, it will answer the majority of questions you get from your staff.” If a technician comes to him asking what to do about a new device that has a relocatable power tap, for example, he’ll go ahead tell him what he knows, but he’ll also show him where he can find that information himself so next time the work goes a little easier. “Because it’s in the guidelines: You follow this UL, and you do this and that… Everything is laid out right there.”
Your Own Needs First
Esslinger isn’t the only clinical engineer who thinks that medical equipment management plans should go beyond The Joint Commission’s requirements. “To me, a MEMP has to have a higher goal, higher aspirations,” says Binseng Wang, ScD, CCE, fAIMBE, fACCE, principal consultant with BSI, a health technology consulting firm. “It needs to be, ‘This is what the team will be doing; this is our mission, our vision statement.’ We do have to think about the accrediting agency and what they want—that is certainly part of the goal. But I also think we have to do better than that and do a lot more than just comply.”
Unlike Baretich, who recommends that the MEMP be organized to reflect applicable Joint Commission standards, Wang suggests writing the plan “in the way that works best for you.” His reasoning is simple, he explains. “In my experience, The Joint Commission is always revising its standards, sometimes quite drastically. So, if you follow how the standards are organized, that becomes cumbersome. You’re condemned to restructure your MEMP frequently, almost every year.”
In addition, Wang notes, sometimes standards are dropped when they probably shouldn’t be. “Up until a year or two ago, for example, there was a requirement that said when a hospital is buying new equipment, the CE/HTM professionals need to be involved.” Just because that element of performance was removed, it doesn’t mean that it’s no longer important for clinical engineering teams to contribute to the procurement process, he says. Similarly, The Joint Commission does not address the need for calibration of test equipment. “If you think about it, doesn’t it make sense that the test equipment you are using to calibrate a ventilator or other critical device is also properly calibrated?” In his opinion, Wang says, “you should have those things in there, because it’s not just about following the law, it’s about really trying to help your clinical users and patients.”
When Wang consults with a healthcare facility about designing a medical equipment management plan (he actually prefers to call it a “program” because it is perennial), he suggests thinking of the MEMP as the tip of a pyramid. “You put the main things, like principles and policies, there.” Under the MEMP you put the supporting materials that go into the “nitty-gritty details” of your program, such as AEM. To make things easier to find for the surveyors, you include a cross-reference chart or table that relates your documents to the accreditation standards. “If you do it this way, it stays a lot more readable. And when The Joint Commission revises its standards, all you have to do is change the table and not your entire MEMP.”
Another tip Wang says he always offers clients: While the MEMP should help facilitate collaboration between HTM and clinicians, it’s not the place for details surrounding clinical care. “Too often, I come across MEMPs that will have a section like ‘Emergency Procedures,’ where they go into the procedures around caring for patients in an emergency situation.” The problem, he explains, is that’s not an area of expertise for the HTM professional. “You shouldn’t be telling anyone, and especially a clinician, what they are supposed to do if the ventilator fails to operate. Sure, after the clinician saves the patient—then they call us to take care of the equipment. But the clinical procedures themselves are not ours to prescribe.”
In the end, Wang, Baretich, and Esslinger all agree that the medical equipment management plan should be a “living document” that is continually updated and revised to reflect the actual needs of the organization and latest in industry best practices. There should be an annual evaluation of its content and accuracy, as The Joint Commission requires. But efforts should also be made to ascertain how the MEMP is impacting your organization. Baretich recommends “talking to your customers,” including the nursing staff and other clinicians who rely on HTM services every day. “Ask them, ‘How’s it working for you? When you read this plan, do you see anything you think needs to be improved or areas where we could be doing a better job?’”
Esslinger, who’s played a role in writing and updating Eskenazi Health’s MEMP each of the last three years, describes the process as difficult, time-consuming, and, ultimately, rewarding. “It’s a mountain of work to go through and get it right. But at the same time, when you’re done, it’s something that you can have personal satisfaction in.” Their MEMP drives efficiency in their department, he says, and it drives quality in everything they do. “In a lot of places, MEMPs aren’t necessarily seen as a technician’s resource, but I think they should be. You know, we operate in a world of manuals, and this is our department manual. It may not cover everything, but it’s a really good start.”
Chris Hayhurst is a contributing writer. Questions and comments can be directed to firstname.lastname@example.org.