OR Manager - February 2019 - 14
Patient safety
Pain management
Continued from page 1
Political overtone
" There is a bit of a political overtone to
the new Joint Commission standards, "
Rosing notes. The nationwide opioid
crisis is affecting every community, big
and small, across the country, and the
Joint Commission does not want to be
perceived as having contributed to the
idea that patients have a right to pain
management and a right to not experience
pain, he says.
Whether or not the Joint Commission
bears any responsibility for the opioid
crisis, the organization is clearly resetting
its expectations and taking a more
conservative approach to pain management.
In
the past year, the Joint Commission
has deleted some standards that
were introduced in the 2000s:
* Educating licensed independent
practitioners about pain assessment
and managing pain. (MS [Medical
Staff])
* The right to pain management. (RI
[Rights and Responsibilities of the
Individual])
* The comprehensive pain assessment
and criteria for reassessment
stand alone Elements of Performance
(EPs). (PC [Provision of Care])
* The response to pain EP. (PC)
CMS is also involved because it controls
the funding through Medicare and
Medicaid and,
in so doing, forces accrediting
organizations that survey on
its behalf to adhere to its rules and
regulations.
Early salvo
In March 2014, CMS issued a " Survey
and Certification Letter " to state survey
agency directors that addresses the
administration of IV medications and
postoperative care using IV opioids.
The letter focused on appropriate pawww.ormanager.com
tient
monitoring and updated guidance
for hospital medication administration
requirements to:
* Reflect the need for patient risk assessment
and appropriate monitoring
during and after medication
administration, particularly for postoperative
patients receiving IV opioid
medications, in order to prevent
adverse events.
* Emphasize the need for postoperative
monitoring of patients receiving
IV opioid medications, regardless of
where they are in the hospital.
The 2014 letter was an " early salvo "
aimed at increasing the safety of using
opioids postoperatively, says Rosing.
CMS also issued another statement in
2018, but that was directed more at
Medicare Advantage organizations than
at hospitals.
The 231-page letter summed up by
saying that CMS won't authorize payment
for more than a 7-day supply of
an oral opioid medication, and CMS will
no longer consider pain management
scores when determining value-based
purchasing reimbursement.
New leadership standard
The Joint Commission also released
new and revised pain assessment and
management standards in 2018. These
have overarching statements with EPs
under them, and it is the EPs that are
scored as compliant and noncompliant,
not the standard itself, notes Rosing.
For example, seven new scorable
EPs have been added to the new Leadership
standard, " LD.04.03.13: Pain
assessment and pain management, including
safe opioid prescribing, is identified
as an organizational priority for the
hospital. "
EP 1: A leader or leadership team
is assigned to implement safe opioid
prescribing and to develop and monitor
performance improvement activities.
Rosing notes that this EP " seems
simple enough, " but it went into effect
January 1. He asks: " If your survey happened
today, would you know who that
individual or team is? Are these people
in place? Have they been meeting? Are
there meeting minutes? Is there anybody
who can speak to it? "
EP 2: The hospital provides nonpharmacologic
pain treatment modalities.
" What alternative treatments do you
have available at your hospital? " asks
Rosing. He notes that there is a list
of examples of these treatments, and
hospitals can pick what they want to
do. They don't have to do all of them.
Examples include aromatherapy, music
therapy, and pet therapy.
EP 3: The hospital provides staff and
licensed independent practitioners with
educational resources and programs to
improve pain assessment, pain management,
and the safe use of opioid
medications based on the identified
needs of its patient population. This applies
to physicians and others who can
prescribe medications, such as nurse
practitioners and physician assistants,
says Rosing. " What education and resources
have you provided them? " he
asks. Did you create an intranet page or
brochure or something else that can be
used as guide? "
Rosing notes that when the Joint
Commission uses the term " education "
in an EP, it can be something as simple
as posting an educational piece on the
intranet and usually means testing for
comprehension is not necessary. When
Continued on page 14
OR Manager | February 2019 13
Scale back patients' expectations to reduce
pain without 'high-powered' opioids.
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