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Subcommittee on Health
May 8, 2002
10:00 AM
2123 Rayburn House Office Building
I am Dr. Dennis
O'Leary, President of the Joint Commission on Accreditation of Healthcare
Organizations. Our organization
very much appreciates the opportunity to testify today on the important
contributions of the private sector towards improving patient safety in health
care organizations.
For those of you who
are not familiar with the Joint Commission, we are the nation's predominant
health care standard-setting and accrediting body. Founded in 1951, the Joint
Commission is a not-for-profit, private sector entity that is dedicated to
improving the safety and quality of care provided to the public.
Its participating member organizations include the American College of
Surgeons; the American Medical Association; the American Hospital Association;
the American College of Physicians-American Society of Internal Medicine; and
the American Dental Association. In
addition to representation from these organizations, the 28-member Board of
Commissioners provides seats for the field of nursing, and for public members
whose expertise covers such diverse areas as medical ethics, public policy, and
health insurance.
The Joint Commission accredits
approximately 18,000 health care organizations.
In addition to accrediting the substantial majority of hospitals in this
country, the Joint Commission's accreditation programs evaluate the quality of
care provided by home care agencies; ambulatory care centers and offices whose
services range from primary care to outpatient surgery; behavioral health care
programs; nursing homes; hospices; assisted living residencies; clinical
laboratories; and managed care entities. The
Joint Commission is also active internationally and, in fact, has provided
leadership in promoting attention to patient safety in other countries.
The scope and nature of
the Joint Commission's involvement in the health care delivery system places
it in a unique position to both set expectations for patient safety across the
entire spectrum of provider services and to measure adherence to those
expectations.
History of the Joint Commission's
Involvement with Error Reduction
During the late 1980s, the Joint
Commission initiated a complete re-engineering of the accreditation process. The
new standards framework that was finally introduced in 1994 focused on
identified "risk points" in health care delivery processes and substantially
strengthened the Joint Commission's emphasis on patient safety.
In 1995, patient safety assumed
an even more prominent role among the Joint Commission's priorities.
The intensified focus on the occurrences of serious adverse events in
health care organizations - which we call "sentinel events" - grew out
of an apparent "outbreak" of
widely publicized, unanticipated serious injuries and deaths in a variety of
settings, including some of the nation's most highly-regarded hospitals. While
not necessarily unique, as later studies would show, these sentinel events
became a clarion call to the Joint Commission and to others that more needed to
be done to improve the safety and quality of health care in this country.
We understood early on the
critical importance of learning more about the epidemiology of these serious
events, including the types of occurrences, their incidence, and their
underlying causes. Only through
amassing such information could we develop the capacity to share knowledge with
and provide guidance to health care organizations, towards the objective of
reducing future health care errors and sentinel events.
Such information would also prove to be essential to future refinements
of the Joint Commission's standards. The Joint Commission, therefore,
committed itself to a major national leadership role in facilitating the
identification of health care errors and adverse events; in working with
individual organizations to reduce the risk of future adverse occurrences; and
in sharing "lessons learned"
with all accredited organizations. To these ends, the Joint Commission launched
its Sentinel Event Program in 1996.
The Joint
Commission's experience with its Sentinel Event Program provides us the unique
perspectives we wish to share with you today. Our odyssey has been both an
enlightening and sobering experience. The
risk of errors in health care is high - an inevitable correlate of the intense
human effort involved in patient care; the complexity of the services provided;
the expectations as a matter of public policy, that care be provided with fewer
resources; and the progressive introduction of new procedures, new technologies,
and powerful new drugs, each with their potential great benefits and
their potential for leading to patient harm.
But we are dealing with more than the complexity and humanity of patient
care. Most health care errors and even serious adverse events are not made known
to organization leaders. This is
principally because health care professionals involved in such occurrences are
deeply shamed and, at the same time deeply fearful of the humiliation and
punishment that all too often has been the knee-jerk response to human error by
organization leaders as well as by professional licensure boards and state and
federal quality oversight bodies.
In truth, if
responsibilities are to be assigned, they have lain, and continue to lie, with
organization leaders in assuring that safety is prospectively (and today
retrospectively) built into all vulnerable organization systems and processes
that have the potential to impact patient care. Humans, including health care professionals, will always make
errors. The goal, we now
understand, is to prevent those errors from reaching or affecting the patient.
And the continuing challenge for all of us is to leverage and incent
health care organizations and health care professionals to invest in these
preventive efforts.
The Joint
Commission's odyssey has involved the gathering of information, the sharing of
knowledge, and the setting and application of state-of-the-art standards.
However, as reflected in the Joint Commission's Sentinel Event Database,
we are far closer to the beginning of the journey than we are to the end.
The Joint Commission's Approach to
Error-reduction
From the outset of its intensified
focus on patient safety in 1995, the Joint Commission has required the
performance of an in-depth analysis ("root cause analysis") of underlying
causes for any sentinel event made known to the Joint Commission either through
self-reporting (currently 80% of known occurrences) or through other sources
such as the media (currently 20%.) The Joint Commission defines a reportable sentinel event as
an unanticipated death or permanent loss of function. The definition also
encompasses certain other serious occurrences such as transfusion reactions,
infant abductions, and patient rape, among others. Joint Commission standards now require organizations to adopt
a definition of sentinel event that is at least as encompassing as that of the
Joint Commission, to establish internal processes for reporting sentinel events,
to conduct root cause analyses of all such occurrences, and to make appropriate
changes in organization systems based on the root cause analysis findings.
Current policy also encourages the voluntary
reporting of sentinel events and the associated root cause analysis results to
the Joint Commission's Sentinel Event Database.
The root cause analysis is in essence a retrospective evaluation of what
went wrong. Almost all of these
analyses identify multiple contributory factors ("latencies"), which can be
addressed through systems improvement. The
value in gathering and sharing this information lies in the reality that these
are in fact rare events with which most organizations have had little or no
first hand experience. The
preventative efforts that they are able to undertake based on this information
have the potential to reduce the overall frequency of future sentinel events.
Development of the root cause analysis
template by the Joint Commission is probably one of the most important
contributions that it has made to patient safety. This tool has been made
available to the field through numerous publications that provide step-by-step
descriptions for completing these analyses. The Joint Commission places such a
premium on the effective conduct of these analyses that failure to perform a
satisfactory root cause analysis after a known sentinel event places the
organization at risk for loss of its accreditation.
While root cause analyses play
a vital role in efforts to reduce health care errors and adverse events, they
are by definition reactive in nature. For this reason, the Joint Commission -
in collaboration with widely-recognized patient safety experts - has now
developed and recently implemented additional patient safety standards that
place the onus on organization leaders to "create a culture of patient
safety." The standards delineate expectations for the organization's patient
safety program that draw particular attention to the needs for teamwork and
effective communications among responsible care-givers.
These latter priorities are based both upon the well-known experiences of
the aviation industry and upon findings from the Sentinel Event Database which
identify communication breakdowns as the most common underlying factor across
all types of sentinel events.
These standards also create new
requirements for the prospective analysis and where appropriate, re-design of
systems identified as having the potential to contribute to the occurrence of a
sentinel event. These "failure mode and effects analyses" (FMEA) are
expected to create learning and preventive opportunities without the actual
experience of an adverse event. Because
there are today multiple vulnerable systems in health care organizations, each
organization is expected to set FMEA priorities based either upon its own risk
management experience or upon external sources such as the Joint Commission's
Sentinel Event Database.
The new patient safety
standards finally create the expectation that unanticipated outcomes will be
communicated to patients and/or their families. Here again, the Joint Commission
has taken a leadership role in addressing the public's patient safety
interests.
By early 1998, the Sentinel
Event Database had accumulated sufficient data to identify significant groupings
of sentinel events and their underlying causes.
With this information in hand, the Joint Commission launched Sentinel
Event Alert as a brief periodic bulletin that would focus upon specific
types of sentinel events, describe lessons learned from the root cause analyses
of that group of sentinel events, and suggest measures that health care
organizations could take to avoid the occurrence of such events in their own
settings.
The first Sentinel Event
Alert issue dealt with the then common practice of storing concentrated
potassium chloride on nursing units. This liquid concentrate is used in the preparation of
intravenous solutions but is deadly when administered in an undiluted form.
The Alert suggested that concentrated potassium chloride not be
available outside the pharmacy unless specific safeguards were in place. By all
reports, this Alert and the attention placed on it by Joint Commission
surveyors has been instrumental in virtually eliminating deaths due to the
unintended administration of concentrated potassium chloride to patients. Since
1998, the Joint Commission has issued 25 Sentinel Event Alerts to its
accredited organizations. These Alerts include over 50 evidence or
expert-based recommendations for preventing adverse events of various types.
The topics addressed cover a wide range of issues - inpatient suicide,
infant abductions, wrong site surgery, transfusion reactions, and patient falls,
to name a few.
During an onsite survey, Joint
Commission surveyors typically assess the organization's familiarity with and
use of Sentinel Event Alert information.
Each accredited organization is expected to consider for its own adoption
information in the Sentinel Event Alerts that is relevant to its
services. This coming summer, the
Joint Commission will focus attention of accredited organizations on a series of
National Patient Safety Goals. Beginning in January 2003, organizations will be
expected to be in compliance with specific recommendations associated with these
Goals that have previously been published in Sentinel Event Alerts or
show that they are using alternative approaches that are just as effective.
The National Patient Safety Goals will be recommended to the Joint
Commission's Board of Commissioners by an expert panel that was appointed
earlier this year.
Last month the Joint
Commission, with the active support of the Centers for Medicare and Medicaid
Services, launched its consumer-oriented Speak Up campaign.
This program seeks to actively engage patients as members of the health
care team and as active participants in their own care by "speaking up." The
key messages of the Speak Up campaign, which are delineated in greater detail in
its eye-catching brochure, include the following:
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Speak up
if you have questions or concerns.
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Pay
attention to the care you are receiving.
Make sure you are receiving the right treatment.
Don't assume anything.
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Educate
yourself about your diagnosis and the medical tests you are undergoing and
your treatment plan.
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Ask
a trusted family member or friend to be your advocate if you can not
advocate for yourself.
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Know
what medications you take and why you take them.
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Use
a hospital, clinic, surgery center or other type of health care organization
that has undergone rigorous on-site evaluation.
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Participate
in all decisions about your treatment.
This campaign
acknowledges that physicians, health care executives, nurses and other health
care workers are working hard to address the problem of health care errors.
This campaign reinforces their efforts.
The Joint Commission has already provided thousands of brochures and
Speak Up buttons to accredited organizations. The brochures, now available in
English and Spanish, are tailored to specific types of organizations such as
hospitals or nursing homes, and contain a blank panel that allows the individual
organization to add its own patient safety message to the brochure. The response
to the campaign has thus far been very positive.
Other groups -- such as pharmaceutical companies, business coalitions,
advocacy groups, and church groups - are also now expressing interest in using
the brochures with their employees/constituents.
The next Joint Commission patient
safety initiative, also of recent vintage is the core component of a Patient
Safety Taxonomy. It is no small irony that the progressively expanding national
discussions on patient safety over the past several years are not based on a
common language. For example, there are no agreed upon definitions of medical
error or adverse event. This
critical missing element has hindered our collective ability to collect patient
safety data in a consistent fashion, analyze of process failures, mine data
(e.g., trends, pattern analysis), and disseminate new knowledge about patient
safety.
The Joint Commission has now
created the framework of a comprehensive Patient Safety Taxonomy and is working
with the Agency for Healthcare Research and Quality and others to finalized a
communication tool that will have broad potential utility for consumers,
provider organizations, health care practitioners, purchasers, researchers and
other audiences. The framework of
the Taxonomy has recently been shared with the Institute of Medicine for
consideration by its newly established committee on patient safety data
standards.
Finally, as the
creator (in 1996) of the highly regarded Annenberg Conferences on patient
safety, the Joint Commission will branch-out over the next nine months to serve
as the convener of four diverse national conferences on topics whose common
underlying theme is patient safety. The
most significant of these -- an invitational conference on the Business Case for
Patient Safety that is being co-funded through the Agency for Healthcare
Research and Quality - will seek to convince health care organization leaders
that financial investments in patient safety will indeed serve the bottom-line
priorities that necessarily drive many of these organizations.
Following the identification of a persuasive business case, the
conference will frame a research agenda that has the potential to support a
future business case for safety.
The remaining three conferences will
bring together both recognized experts and disparate interests to address the
issues of Nurse Staffing, Emergency Preparedness, and Emergency Unit
Overcrowding. The confluence of
factual information across these three sets of issues already suggests that a
progressively under-girded delivery system is unable to either meet public
expectations nor the provision of state-of-the-art or to assure the public of
the safety of the care that is delivered to those able to access service.
Significant public policy recommendations are expected to emerge from
each of these conferences.
In still other collaborative efforts,
the Joint Commission is working with the Centers for Medicare and Medicaid
Services, the Agency for Healthcare Research and Quality, the National Quality
Forum, purchaser-led Leapfrog Group, and others to further these patient safety
initiatives.
The
Challenges Ahead
The road to patient safety is a
never-ending journey this is because the continuing rapid evolution of this
nation's health care capabilities make achievement of our patient safety goals
a moving target. But it is also
because long-standing change will require counter-intuitive strategies, culture
change, and radical alterations in the way health care professionals are
trained.
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Counter-intuitive
strategies must meet the need to protect and support caregivers who make
errors rather than punish them. When
caregivers feel safe, patients are more likely to be safe because such
strategies create the opportunities to truly learn from identified errors.
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If we cannot change
the blame and punishment culture of our society, we must incent and promote
counter-cultures of safety in our nation's health care organizations.
This is a non-delegatable responsibility of organization leaders;
those having the courage to rise to this challenge should be rewarded.
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This country has
trained generation after generation of outstanding individual clinicians -
physicians, nurses, and other professionals who make important, even
life-and-death decisions for and with patients every day.
Now we need to expand the applied knowledge base of future
generations to include systems thinking and analysis, and we need to train
this new advance guard of health care professionals as interdisciplinary
teams.
The patient safety
challenges are neither small in number nor small in magnitude.
But progress is being made by the private sector, by the public sector,
and importantly, by both working together.
We should take great heart in this progress as we continue our journey.
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