Matt Baretich: Seize the Day with New TJC Requirements

By now, nearly everyone in the HTM community is aware of the substantial and unexpected changes in Joint Commission requirements for on-schedule completion of scheduled maintenance. I won’t go into the details here because recent webinars from AAMI and ECRI Institute, and one forthcoming from ACCE, are spreading the word. The gist is that we now need to complete 100% of our scheduled maintenance work for all types of medical equipment, not 90% as we have been doing for some equipment.

It’s more complicated than that, of course, and the devil is in the details. When I first heard that these changes were on their way, I was stunned. But it has since become clear that the situation is not dire. We can continue our move from manufacturer requirements for scheduled maintenance to alternative equipment maintenance strategies, where allowed—what some people are calling the shift from OEM to AEM. And we can refine our metrics for performance monitoring of our scheduled maintenance work. We will all be reading more in the coming weeks about how to cost-effectively achieve compliance with Joint Commission (and CMS) requirements.

We can also start adopting risk assessment processes that follow generally-recognized methodologies—techniques have long been applied in other industries and fields of study, but not as commonly in HTM. The central principle is that risk is a combination of probability and severity. In medical equipment maintenance, that means equipment that fails often (that is, with high probability) and whose failure would have high severity (patient death, for example) represents a high level of risk. At the other end of the spectrum, equipment that rarely fails and has little impact when it does, has a relatively low level of risk. In between are intermediate risk levels. Malcolm Ridgway, Steve Grimes, Binseng Wang, and others have written eloquently on how to apply this process to HTM.

Other writers have not been as careful with their terminology, muddling up the concepts of risk, probability, and severity. CMS and The Joint Commission themselves have not always used these terms with clarity. For example, defining “high risk” medical equipment as devices whose failure produces a severe impact, without considering probability, runs contrary to established practice. A patient could die from having his or her tongue lacerated by a broken tongue depressor, but the probability is so vanishingly small that the actual risk is too low to worry about.

I’m convinced that the way forward for HTM includes genuine risk assessment. It’s time to move on from the simplistic approaches of the last quarter century.

All of which brings me to the point of this blog post. The HTM community has long been in a reactive mode, waiting for the regulators to tell us how to do our jobs. In one sense, that’s what exactly what regulators are for, guarding our patients from the harm that irresponsible behaviors can cause. But it’s a two-way street. HTM professionals have a responsibility to inform and educate the regulators so that the regulations they write are effective without being burdensome.

In my opinion, we haven’t done a good job of this. In large part, this because we don’t speak with a unified voice. We have not developed standard practices for basic activities, such as scheduled maintenance and associated performance metrics. Year after year, many of us run on wheels of our own (re)invention. Why should the regulators pay attention to us if we can’t offer a workable, evidence-based, consensus-based alternative in response? Let’s seize this opportunity to build a standard of practice that we can be proud of.

Matt Baretich is president and CEO of Baretich Engineering based in Fort Collins, CO.

2 thoughts on “Matt Baretich: Seize the Day with New TJC Requirements

  1. To address the standard itself (which isn’t Matt’s major point in this blog), it is a bit mysterious to me why this regulation has been made so mysterious that it needs “demystifying” (as one webinar was entitled). Similarly, the popularity of George’s AAMI sessions arises in part because the standards are at least sometimes not actually self explanatory. Wouldn’t it be better if the standards were written such that reading them clearly portrayed what it is that you really need to do?

    • Thank you for your input. I agree that it would be wonderful if all regulations are simple and easy to understand. Unfortunately, in the HTM world, we have too many different types of equipment to accurately regulate. The standards are open for interpretation, because one regulation could not encompass all types of medical equipment at all times. A suction pump is different from a defibrillator. The regulation that could, would be too large to fit on a shelf.
      I feel, what Matt is trying to say is that, as a community we must be able to communicate with each other, and learn what the best practice is through research and statistical analysis. Then be able to accurately describe the regulations for patients and staff safety. I have had the pleasure of working with brilliant, intuitive individuals who have taken the time to address what could go wrong instead of what has gone wrong. That is our purpose. We are here as safety patrol for patients and staff. That is one of our primary directives. We must be able to communicate possible issues throughout the community to include regulators and manufactures.

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