Steve Grimes’ recent paper “Two Steps Forward, One Step Back—How the Industry Must Take in Stride New CMS and TJC Requirements” (BI&T, November/December 2014), provides an excellent but still disturbing summary of the July 2014 changes in The Joint Commission’s Environment of Care standards affecting medical devices and the difficulty hospital-based healthcare technology management (HTM) departments will have in attempting to achieve a meaningful and sustainable compliance with these new requirements.
As such, the title, perhaps, should more accurately include “Two Decades Backward” since these new requirements that now require all medical equipment to be included in the equipment inventory (EP2, EC.02.04.01), are simply not manageable in a meaningful and practical context. In all but the smallest of hospitals, medical device inventories are inherently unstable, dynamic, and continually in flux as new equipment is being added through conventional capital purchases, rentals, loaners, transfers from other facilities, even patients bringing in their own devices, as well as older equipment being retired, transferred to other locations or facilities, replaced by rental agencies, misplaced, or lost through theft. Attempting to maintain the accuracy and functionality of such inventories is no trivial task. Even if it was possible, to what end is the need? (Here, I’m not equating the importance of general asset management with medical equipment maintenance management).
To test this hypothesis and argue against these new inventory requirements, I would encourage HTM departments to do a simple Pareto analysis on all of the devices currently within their inventories over a recent one- to three-year study period. Assign all known accumulated labor hours, work order volume, and maintenance costs to each of these devices. Separately, sort this file from highest to lowest on each of these three metrics. From such an analysis, it would not then be surprising to learn that:10-20% of your inventoried devices account for 80-90% of all maintenance costs, labor hours, and work order volume. If so, you now have evidence and reason to focus on the highly significant few and effectively, but still responsibly, ignore the nonsignificant many.
While there are absolutely no arguments against identifying and rigorously maintaining inventories of the high-risk, mission-critical devices, what economic, performance, or safety concerns are there to warrant tagging and trying to track otoscopes, tube rockers, sphygmomanometers, and the like? Here, the actual cost of doing so may quickly exceed the cost of the device itself!
For the most part, our various regulatory agencies are doing a tremendous job at encouraging (OK, in some cases, forcing) hospitals to become and stay well-managed, responsible, and safe. It remains the responsibility of the HTM community, however, to ensure that what these agencies eventually mandate—especially on those issues involving our sandbox—is based on meaningful, practical, and value-added principles. Unless and until we rise up to this responsibility we’ll be stuck with requirements that add little if any value and consume resources that we simply do not have.
Larry Fennigkoh, PhD, is professor of biomedical engineering at the Milwaukee School of Engineering and a member of the BI&T Editorial Board.