Joint Commission Gets Serious About Patient Grievance

If you’ve been following the changes taking place within the Joint Commission during the past year or so, you know that the healthcare accreditor has been updating standards to more closely align with the Centers for Medicare & Medicaid’s (CMS) Conditions of Participation (CoPs).

HcPro posted an article on their site back in March that nicely outlines several recently released changes to the Joint Commission hospital accreditation standards. This article focuses on one particular addition to the 2009 standards.


For Compliance, Ombuds, Quality, Risk Management, Marketing/Patient Experience, and Medical Staff: 

Joint Commission has added considerable language to the 2009 hospital standards pertaining to patient rights and specifically, responding to patient grievances in a timely manner:


EP 1: The hospital establishes a complaint and grievance resolution process.

EP 2: The hospital informs the patient and his or her family about the complaint and grievance resolution process.

EP 4: The hospital reviews and, when possible, resolves complaints and grievances from the patient and his or her family.

EP 6: The hospital acknowledges receipt of a complaint or grievance that the hospital recognizes as significant and notifies the patient of follow-up to the complaint or grievance.

EP 7: The hospital provides the patient with the phone number and address needed to file a complaint or grievance with the relevant state authority. (See also MS.09.01.01, EP 1)

EP 10: The hospital allows the patient to voice complaints or grievances and recommend changes freely without being subject to coercion, discrimination, reprisal, or unreasonable interruption of care.

EP 17: The governing body reviews and resolves grievances unless it delegates this responsibility, in writing, to a grievance committee.

EP 18: In its resolution of grievances, the hospital provides the individual with a written notice of its decision, which contains the following:

  • The name of the hospital contact person
  • The steps taken on behalf of the individual to investigate the grievance
  • The results of the process
  • The date of completion of the grievance process

EP 19:The process for resolving grievances includes a mechanism for timely referral of patient concerns regarding quality of care or premature discharge to the Quality Improvement Organization (QIO).

EP 20: The governing body approves the complaint and grievance resolution process.

Impact:These standards are new to the Joint Commission but not CMS. The hospital must now have a procedure, approved by and overseen by the governing body. It will be necessary to track the steps of the process.


I have a particular interest in the standards pertaining to patient rights and grievance as I’ve spent considerable time recently updating the Patient Comment & Grievance Tracking Database from Simple Data Solutions.   If you need to develop or improve your patient complaint and grievance tracking process, please take a look at this product to see whether it meets your needs.  It is specifically designed for smaller hospitals, ambulatory surgery centers, dialysis centers, home health agencies, and durable medical equipment suppliers.  There is a free 30 day trial download available from the Simple Data Solutions web site, as well as comments from some current users.

Responding well to patient grievances does more than comply with standards, it improves patient safety, patient satisfaction, and often preserves the organization’s valuable financial resources.


Cavalcade of Risk #80

 First, thanks to Hank Stern for inviting me to host, and for all the work he does to keep the Cavalcade of Risk on target. 

I’m especially honored to host this week’s edition of the Cavalcade of Risk as it is Healthcare Risk Management Week.  In hospitals and healthcare organizations around the country people are asking the question – “Just what do those people in Risk Management do anyway?”  Read the post linked above to get my 2 cents worth on that topic.  

Now, on to the risky business of this carnival:  

 David Williams of the Health Business Blog says that while it’s great news for cancer patients that more oral formulations are coming to market, their availability raises the risk of non-adherence, potentially causing higher costs and worse outcomes over the long term. 

Vaccination is one of the best ways to reduce disease, but paying people to get vaccinated may have unintended consequences as Jason Shafrin of The Healthcare Economist reveals.    

Jaan Sidorov of the Disease Management Care blog (who hosts the next Cavalacade of Risk) examines one of the latest wrinkles in the health care reform debate – the Health Insurance Cooperative.  


In light of the recent horrific death of a young lab research assistant at UCLA, Julie Ferguson of Workers’ Comp Insider looks at the risks to students and researchers in university labs.

In 2007, there were 5,488 fatal workplace injuries in the US, according to the Bureau of Labor Statistics. Nancy Germond of All Business lists a number of workplace safety training resources.  


Mike Feehan from Insure Blog speaks up about The Other Elephant in the Room – Long Term Care, discusses how the Brits are approaching the issue, and asks whether we might learn from their experience.  

On a related note, CashMoneyLife asks what’s the financial risk/benefit of purchasing long-term health insurance  

If you live in an area at high-risk for hurricanes you probably know that hurricane insurance costs are on the rise, if you can get coverage at all. Five Cent Nickel elaborates.  


Leave Debt Behind reminds us that due to recent changes in credit card laws, the risk of litigation to collect unpaid balances is greater. 

The Smarter Wallet advises limiting investment risk by investing for the long-term.  

The Digerati Life explains how to use modern portfolio theory to manage risk by diversification.  


These submissions offer worthwhile information that, if one stretches the definition a bit, pertain to the topic of risk. 

Anyone in healthcare who puts making money at the top of the list might be better served in a different profession according to Louise at Colorado Health Insurance Advisor.  

Trust is a high-risk proposition according to Trusted Advisor Associates.  

The Britannica Blog tells the sad economic tale of Dayton, Ohio, reeling after the final Fortune 500 company leaves the city.   

And finally…  


That’s it for this edition.  The next Cav will be hosted on July 1st by The Disease Management Care Blog.  Submissions can be made via Blog Carnival or email.   

Thanks for stopping by!

Healthcare Risk Management Week

Healthcare reform, patient safety, and the public’s concern about potential medical errors are daily front page news.  Never in my experience has there been so much focus on the need to improve quality, safety, and economies in healthcare, which everyone agrees are excellent “big picture” goals. 

June 15-19, 2009 is Healthcare Risk Management Week, with the theme “Thinking Safety, Earning Trust” according to the American Society for Healthcare Risk Management.  Slogans aside, it seems a good time to consider the function and goals of the Office of Risk Management in the heathcare setting.  Since my experience in the field is limited to hospital risk management, I’ll focus there.

Big picture goals have merit, but just like computer imagery, when we zoom in on the big picture we begin to see a multitude of individual, overlapping, multi-colored pixels; lots of little jagged-edged points that come together to create the whole. Making lasting changes to “the picture” requires an understanding of the issue from both overall and zoom-focus perspectives. 

So how does Risk Management help effectively “realign” those pixels? 

Although investigating unanticipated outcomes and determining root causes is often a primary responsibility of Risk Management, focusing narrowly on those elements alone tends to be like looking only at the zoomed-in pixillated image of the problem.  Rearranging the specific elements that caused a problem has value, but rarely will it change the big picture. 

In my experience, the first order of business must be proactive risk education for people at every level of the organization, starting with the most vulnerable – the patients.  Joint Commission launched the “Speak Up” campaign several years ago to educate and empower patients about their role in improving safety and mitigating risk, and supporting the concept of an empowered patient is a start.  As part of my risk management role I worked extensively with an excellent web-based patient education program.  An educated patient provides the first layer of defense against error.  

But risk-avoidance education must go beyond the patient.  For example, are the housekeepers in your hospital educated as to how vital their role is in protecting those in our care from potentially life-threatening infections?  A housekeeper’s work may not be brain surgery, but without it, brain surgery may not save the patient.  Do your housekeepers understand the value of their role in safe patient care and protecting the organization?

How much time is spent educating your nurses and other front-line care givers about ways to minimize risk?  Nurses often manage the most significant risk/reward ratio as they are often the “face” of the hospital in the patient’s mind.  Caring for multiple critically ill patients, documenting that care in a way that would hold up in a court of law, interacting with concerned family members, and dealing with numerous physicians are all in a day’s work.  A skilled, compassionate nurse is a tremendous asset to the organization and its patients.  Nursing care may not be brain surgery (although in today’s world of high-tech medicine it’s getting close) but without it brain surgery may not save the patient.  Do your nurses understand the value of their role in safe patient care and protecting the organization?

On to perhaps the most challenging group, your physicians.  Challenging not necessarily because they aren’t interested in learning how to better mitigate risk, but because it can be so difficult to gain their attention for any length of time.  Does your organization support transparency and apology when care goes awry?  Hopefully so, and if that’s the case, how educated are your physicians in handling those most difficult of conversations?  Do your physicians know where to go for assistance when facing a conversation with a distraught patient or family member?  Often that support comes from the Office of Risk Management. 

Is effective risk management on the minds of your C-Suite executives?  It is if they are educated as to its value; a value that includes protecting patients, protecting the organization’s good name and reputation, and protecting the financial assets that enable the organization to continue its mission.

Education is a challenging, ongoing, and multi-faceted role of Risk Management.  The only way to effectively manage risk in an organization is with everyone’s help.  Risk education supports improved quality, safety and economy in the heathcare setting.  It’s a big-picture, zoomed-focus kind of role.

Happy Healthcare Risk Management week!

CPMSM CPCS Job Listing Added to Side Bar

I’ve added an interesting little widget to the side bar that posts random jobs around the nation using the search terms CPMSM, CPCS. 

Scroll down and look for the widget on the far right.

Whether or not you’re in the market for a career change, it’s fascinating to keep your eye on current trends in medical staff service positions around the country.


Training – A Worthwhile Return on Investment?

This thought was posted recently on a patient safety list-serve to which I subscribe, I thought it was worth re-posting here for consideration:

There is a very important shortcoming in the healthcare leadership mindset – that training is non-productive down time. As we know, this is not the case in any industry that has achieved highly reliable performance. As long as we treat training as a “perk” that we invest in only when there is money left to spare, or worse, as something to be done during lunch or at home on your own time, then we will continue to have (serious) problems.


Cavalacade of Risk – Three Years and Counting

Hank Stern hosts the third anniversary edition of Cavalcade of Risk this week at Insure Blog, be sure to stop over. 

The next edition, to be published on June 17th, will be hosted here at Supporting Safer Healthcare.  If you'd like to submit a risk-related post for consideration, please send it to me at rkschwab at gmail dot com, and include Cavalcade of Risk Submission in the subject line.  Submission Deadline is Monday, June 15th, although earlier is appreciated.

I'm looking forward to some high-risk reading!

Back By Popular Demand – The Ugly Truth

The Ugly Truth About Credentialing and Privileging was recently featured in the May/June 2009 issue of Synergy, the journal of the National Association Medical Staff Services (NAMSS).  Since many people have asked about it, here it is again – enjoy!


The Ugly Truth About Credentialing & Privileging – Part I

Dear Doctor:

If you’ve been a practicing physician for more than about an hour, chances are you already know the ugly truth. If you’re in medical school or a residency program, odds are good that you don’t have a clue. Not to worry, as a fourteen-year veteran of the credentialing wars, I’m about to enlighten you.

(I feel I must preface this ominous tale with a disclaimer that I am a firm believer in the need for effective, thorough credentialing and privileging – more about that later.)

At last, you’ve completed your training and can begin to practice in your chosen field. You look forward to curing illness, cutting away disease, and finally earning some money so you can start paying back those lovely student loans you’ve accumulated.

Whether you join a large multi-specialty group or bravely hang a solo-practice shingle, you will no doubt need to apply for privileges at one or more hospitals, and perhaps a few ambulatory surgery or urgent care centers as well. If you hope to make even a small dent in those outstanding loans, you’ll also need to join various managed care panels.

How bad can it be, right?

You’re about to find out just how many ways you can be asked to document every place you’ve been, every job, license, certification or board you’ve ever held, whether or not you have any disabilities for which you’ll need accommodation, whether any professional privilege has ever been denied, revoked, limited or suspended, and whether to the best of your knowledge anyone is even thinking about denying, revoking, limiting or suspending anything of yours.

You’ll also need to produce the names, addresses, phone, and fax numbers of various individuals who will serve as your references. Some you’ll get to select, others may be prescribed. If you apply to a number of organizations all at once the people you name will get the joy of responding to multiple requests. If they don’t answer in a timely fashion you’ll be given the opportunity to prod them along. You may want to practice groveling, as nothing delays privilege approval quite as effectively as references who fail to respond.

Getting the picture? Verification of credentials is a huge, time-consuming, pain in the neck. Establishing that you’re currently competent to request and perform a vast array of delineated privileges only adds to the discomfort.

Unlike fine wine, the process does not become more palatable with age. The longer you’ve been in practice the more years of experience there are to verify, and the more proof you’ll need to produce to show that you’re still proficient at the ‘otomy, ‘ectomy and ‘ostomy that you learned way back in training.

There’s more, but I don’t want to discourage you overmuch with too many dark, dire warnings of a future decorated in red tape and dominated by writer’s cramp. (And we haven’t even touched on medical records documentation!)

Take heart – I have some tips to share on ways to make the credentialing process a slightly less bitter pill to swallow, so continue reading “The Ugly Truth – Part II to get your next dose of “Realdox.”


The Ugly Truth About Credentialing & Privileging – Part II

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