JCAHO, DOH, CAP, AABB, AOA, FDA, NFPAwhat an alphabet-soup world we live in. Standards, regulations, guidelines, goals, suggestions, rumors. Can we be pulled in any more directions? So many organizations are throwing their hats in with their opinions on how patients and medical technology should be managed, that it has become increasingly difficult to anticipate and plan your medical-technology program. To even try to begin to make sense of it all, we have to go back to the basics and refocus on our management program.
Basic number one: If you work in health care, you work for patient care. This is the first and foremost mission. However, we often get bogged down in our program when we confuse clinical patient care with patient technology care. Our work is patient technology care that results in better clinical patient care. In our desire to fix things (which we are very good at) and make everything work well, we often get involved with things that should be left to those who are directly responsible for patient care. Technology is so interwoven with patient care that the separation of where our job ends and the clinicians job begins has to be clearly defined in our technology-management plan and program.
Whatever your plan is, it needs to be written down clearly and reviewed. If you have gone more than 1 year without closely reading it and making needed changes, you have put yourself at risk. Inspection entities, such as the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), want you to have a plan that includes equipment oversight (to include temporary/nonhospital-owned equipment), hazard/recalls, life-support definitions, Safe Medical Device Act reporting, and emergency.
Most of the other inspection entities focus on equipment oversight and documentation. These entities use standards and actual regulations. Always clearly understand the difference between standards and regulations as you create your plan.
Equipment plans came about from trying to list how we have addressed JCAHO Environment of Care standards. They still serve that purpose, but they can also help you outline your equipment-management program. Equipment plans can serve as both as long as you do not confuse equipment plans with policy/procedure-type documents that spell out details and specifics. To effectively show any inspecting entity your entire program, both types of documents need to exist.
Whatever you put in your plan, two factors will drive its success. First, keep the plan simple, because whatever you say you do, you have to do completely. With the amount of technology we are responsible for today, it is almost impossible to do all the things that we did 10 years ago. No matter how complete your plan is, if you cannot really do it, you have set yourself up for failure.
Inspecting entities essentially want a safe patient environment, so they want to see evidence that you have thought the plan through and have documentation to prove that you have actually done the work. Planned prioritization is how we have to work. For example, which would you spend your time ona twice-per-year electrical-safety check of an agglutination viewer, or a verification of temperature-limit safeguards on all equipment that provides a temperature-controlled function?
The second important factor is consistency. Most drilling begins when an inconsistency is noticed by an inspector, so your plans elements and execution must be consistent. If you have more than one tech in your department, it is likely you will have to fight inconsistencies. For example, if you use stickers, all techs must use them in exactly the same way. If you utilize a paperless system, all techs must consistently complete the electronic document.
These basics will not ward off all possibilities of some inspector at your hospital dragging out some arcane regulation that is buried in the microprint of some subregulation, but a well-designed plan and a consistent execution of that plan can solve many of the inspection headaches. From a good foundation, all things are possible.
Mary Coker, CBET, is QA manager at Masterplan, Chatsworth, Calif.
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