SESSION TITLE: SPEAKER NAME: SESSION NUMBER: DATE/TIME: CONTACT HOURS: Sterile Processing: Preparing for Accreditation Surveys Rose E. Seavey, MBA, BS, RN, CNOR, CRCST 9015 & 9106R Monday, March 4, 2013, 8-9am & 9:30-10:30am 1.0 CH OVERVIEW: Health care accreditation processes are conducted with a focus on safety and quality of patient care. Sterile processing in health care facilities has become an increasingly larger focus of the accreditation survey process. This presentation is intended to help health care professionals prepare for a Joint Commission (TJC), Centers for Medicare and Medicaid Services (CMS), or other accrediting and/or regulatory agency survey as it relates to sterile processing of surgical instruments and other medical devices in health care settings. OBJECTIVES: 1. Discuss the latest requirements from accrediting organizations specifically relating to reprocessing of medical devices. 2. Describe key published standards and recommended practices for safe and effective reprocessing of reusable patient care items. 3. Identify current resources available to help health care facilities prepare for a successful accreditation survey. CONTACT INFORMATION: Rose E. Seavey, MBA, BS, RN, CNOR, CRCST President/CEO Seavey Consulting, LLC Seavey Healthcare Consulting, Inc. Arvada, Colorado E-mail: rose@seaveyhealthcareconsulting.com FACULTY DISCLOSURE: Rose Seavey COMMERCIAL SUPPORT: Rose Seavey 1., 2. Seavey Healthcare Consulting, Inc. Seavey Healthcare Consulting, Inc. (travel expenses)
TODAY Investigates: Dirty surgical instruments a growing problem in the OR 2/22/2012 Filthy surgical instruments: The hidden threat in America s operating rooms 2009 rotator cuff repair and 7 other joint surgery patients» Arthroscopic shaver & inflow/outflow cannula» MFR updated cleaning IFU 10 steps Final step - use a digital scope to visually inspect the insides of handpieces! http://www.iwatchnews.org/2012/02/22/8207/filthy-surgical-instruments-hidden-threat-americas-operating-rooms http://todayhealth.today.msnbc.msn.com/_news/2012/02/22/10471434-today-investigates-dirty-surgicalinstruments-a-problem-in-the-or 1 Sterilization is a Complex Process Requires: - Environmental controls - Appropriate equipment and supplies - Adequate space - Qualified, competent personnel - ongoing training - Monitoring for quality assurance TJC engineer on site - Review of the environment Eiland, John E, Surveyor, The Joint Commission. Joint Commission presentation at IAHCSMM annual meeting in May 2012. Presentation available on flash drive provided to attendees 1
Accreditation Survey Improving the quality of healthcare - Peer review - Focus on safety and quality Condition of payment - Private insurance companies - Federal funding Measures compliance - Pblihd Published standards d and recommended dd practices - Accreditation standards and supporting documents Seavey, R. Association for the Advancement of Medical Instrumentation. Sterile Processing in Healthcare Facilities: Preparing for Accreditation Surveys. 2011. CMS Compliance with Medicare Conditions HC facilities must be accredited by an accrediting organizations with deeming authority by CMS - Accreditation ti Association for Ambulatory Healthcare (AAAHC) - Accreditation Commission for Healthcare (ACHC) - American Association for Accreditation of Ambulatory Surgery Facilities (AAASF) - American Osteopathic Association/Healthcare Facilities Accreditation Program (AOA/HFPA) - Community Health Accreditation Program (CHAP) - DNV Healthcare (DNV) - The Joint Commission (TJC) Policy and Requirements for an Application for Deeming Authority. Accessed 7/12/2012 at: http://www.cms.gov/medicare/provider- EnrollmentandCertification/SurveyCertificationGenInfo/downloads//applicationrequirements.pdf 2
The Joint Commission Independent, nonprofit Accredits and certifies over 18,000 HC organizations and programs including:» Hospitals,» Doctor s offices,» Nursing Homes,» Office-based surgeries,» Behavioral health treatment facilities, and» Providers of home care services. Nationally recognized as symbol of quality 5 TJC Survey Process Submit an application Pay a fee Resurveyed within three years 2006 unannounced survey process - Between18-39 months after previous survey - Morning of survey» Biographies, and pictures of surveyors assigned Eiland, John E, Surveyor, The Joint Commission. Joint Commission presentation at IAHCSMM annual meeting in May 2012. Presentation available on flash drive provided to attendees. 3
Joint Commission Resources Nonprofit affiliate of TJC, publishes the official handbooks used in the TJC survey process Comprehensive Accreditation Manual for Hospitals: The Official Handbook (CAMH) Comprehensive Accreditation Manual for Ambulatory Care (CAMAC) 7 TJC Accreditation Standards Standards = performance objectives Rationales = describe importance Elements of performance (EPs) = scores determine compliance - Minimum score of 90% on every EP Standards relating to reprocessing - Environment of Care, - Human Resources, - Infection Prevention, and control and - Leadership Seavey, R. Association for the Advancement of Medical Instrumentation. Sterile Processing in Healthcare Facilities: Preparing for Accreditation Surveys. 2011. 8 4
TJC Increase Focus on Sterilization/HLD Beginning in 2010, surveyors have spent additional time during survey evaluating the cleaning, disinfection and sterilization (CDS) processes Surveyors received in-depth training on sterilization processes Survey to ANSI/AAMI ST79 (Available to staff) After training more than tripled citing related to noncompliance for Sterilization/ HLD* From 10% to 40% * One non-compliance in Sterilization/HLD = citing (others up to 3)* http://www.jointcommission.org/assets/1/18/jconline_july_20_11.pdf *Louise Kuhny, TJC Survey Process: Second Generation Tracers. AORN webinar 9/22/2011 9 CMS Pilot test on Hospital Infection Control Surveyor Worksheet 5-18-2012 CMS Memo to State Survey Agency Directors - CMS testing three revised surveyor worksheets for assessing compliance with three hospital Conditions of Participation (CoPs): 1. Quality Assessment and Performance Improvement (QAPI), 2. Infection Control, and 3. Discharge Planning. http://www.apic.org/resource_/tinymcefilemanager/advocacy- PDFs/CMS_revised_hospital_surveyors_worksheets_5-18-12.pdf 5
CMS Memo Summary Draft Worksheets Made Public: - Focusing on compliance as a means to reduce hospital-acquired acquired conditions (HACs) - Infection Control/Prevention Program» Module 1: Section 3.A. Reprocessing of Semi-Critical Equipment» Module 1: Section 3.B. Reprocessing of Critical Items Sterilization of Reusable Instruments and Devices - May be additional revisions based on information gathered during the pilot test phase, which will end sometime in FY 2013. https://www.cms.gov/medicare/provider-enrollment-and- Certification/SurveyCertificationGenInfo/downloads/SCLetter12_01.pdf TJC Personnel Considerations Standards and EPs HR.01.06.01: Staff are competent to perform their responsibilities - EP 1. The hospital defines the competencies it requires of its staff who provide patient care, treatment, or services. - EP 2. The hospital uses assessment methods to determine the individual s competence in the skills being assessed.» Note: Methods may include test taking, return demonstration, or the use of simulation. - EP 3. An individual with the educational background, experience, or knowledge related to the skills being reviewed assesses competence. The Joint Commission. 2012 Hospital Accreditation Standards (HAS) 6
Leadership Standards and EPs LD.04.01.11: The hospital makes space and equipment available as needed for the provision of care, treatment, and services. - EP 2. The arrangement and allocation of space supports safe, efficient, and effective care, treatment, and services.» Need for sufficient space to adequate reprocess - EP 5. The leaders provide for equipment, supplies, and other resources. The Joint Commission. 2012 Hospital Accreditation Standards (HAS) The Joint Commission Revision to IC.02.02.01 TJC will survey:» Orientation, training and competency of staff reprocessing medical devices» Levels of staffing and supervision» Standardization of process regardless of whether it is centralized or decentralized» Reinforcing the process (adherence of organization s procedures to manufacturer s guidelines)» Ongoing quality monitoring The Joint Commission Perspectives, October 2009, Volume 29, Number 10 http://www.jcrinc.com/common/pdfs/fpdfs/pubs/pdfs/jcreqs/jcp 10 09 S16.pdf 7
The Joint Commission (TJC) Standard IC.01.03.01 The hospital identifies risks for acquiring and transmitting if infections. Element of Performance # 4 The hospital reviews and identifies its risks at least annually and whenever significant changes occur with input from, at a minimum, infection control personnel, medical staff, nursing, and leadership. The Joint Commission: 2012 Hospital Accreditation Standards (HAS) Centers for Medicare and Medicaid Services September 4, 2009 - CMS released a memo to state survey agency directors regarding sterilization practices. If manufacturers instructions are not followed, then the outcome of the sterilizer cycle is guesswork, and the ASC s practices should be cited as a violation of 42 CFR 416.44(b)(5). (CMS, 2009) http://www.ascquality.org/library/sterilizationhighleveldisinfectiont oolkit/cms%20flash%20sterilization%20memorandum.pdf 8
TJC National Patient Safety Goals Goal 7: Reduce Risk of HAIs NPSG.07.05.01 Implement evidence-based practices for preventing surgical site infections. - Implements policies and practices aimed at reducing the risk of HAIs. These policies and practices meet regulatory requirements and are aligned with evidence-based guidelines (for example, the Centers for Disease Control and Prevention [CDC] and/or professional organization guidelines). Includes all areas where reprocessing takes place - Multiple reprocessing sites The Joint Commission. 2012 Hospital Accreditation Standards (HAS) Common High-Risk Areas IUSS (flash sterilization), P&P not standardized, Loaner instrumentation, Torn wrappers, No IFUs, Sets weighing more than 25 pounds, Sterilization ti process failures, and Inefficient staff orientation 18 9
Addressing and Reducing Risks Common high risk areas - IUSS (flash sterilization), ti - P&P not standardized, - Loaner instrumentation, - Torn wrappers, - No IFUs, - Sets weighing more than 25 pounds, - Sterilization process failures, and - Inefficient staff orientation. Risk Reduction Tools - Root Cause Analysis - Failure Modes and Effects Analysis - Tracers Seavey, R. Association for the Advancement of Medical Instrumentation. Sterile Processing in Healthcare Facilities: Preparing for Accreditation Surveys. 2011. The Joint Commission Joint Commission EC 02.04.01 - requires accredited hospitals to maintain medical equipment inventory EC 02.04.01, EP 3 The hospital identifies the activities, in writing, for maintaining, inspecting, and testing for all medical equipment on the inventory -Mechanical cleaning equipment and sterilizers -Endoscopes (flexible and rigid) now included AAMI News: August 2010, Vol. 45, No. 8 and AAMI News: January 2011, Vol. 46, No. 1 http://www.aami.org/publications/aaminews/jan2011/endoscopes.ht ml 10
Survey Hot Buttons October 24, 2011 Laryngoscope blades are semicritical items - Sterilized» Steam, or» Low temperature sterilization - High-level disinfection - Packaged and Stored to prevent recontamination» NOT unwrapped blades: Anesthesia drawers, or Top of core cart Laryngoscope handles processed between patients http://www.jointcommission.org/standards_information/jcfaqdetails.aspx?standards FAQChapterId=69&StandardsFAQId=386 21 CMS Pre-decisional surveyor worksheet Module 1: Infection Control/Prevention Program 1. A.3 The Infection Control Officer(s) can provide evidence that the hospital has developed general infection control policies and procedures that are based on nationally recognized guidelines and applicable state and federal law. https://www.cms.gov/medicare/provider-enrollment-and- Certification/SurveyCertificationGenInfo/downloads/SCLetter12_01.pdf 11
The Joint Commission (TJC) Standard IC.01.03.01 The hospital identifies risks for acquiring and transmitting infections. Element of Performance # 4 The hospital reviews and identifies its risks at least annually and whenever significant changes occur with input from, at a minimum, infection control personnel, medical staff, nursing, and leadership. The Joint Commission: 2012 Hospital Accreditation Standards (HAS) Disinfection and Sterilization Standards, Recommendations and Evidence-Based Guidelines AORN Perioperative Standards and Recommended Practices, 2013 AAMI ST79 Comprehensive guide to steam sterilization and sterility assurance in health care facilities ANSI/AAMI ST79:2010 & A1:2010 &A2:20112011 & A3:2012 CDC Guideline for Decontamination and Sterilization in Healthcare Facilities, 2008 24 12
AORN RPs Sterilization and Disinfection Anesthesia Equipment Cleaning and Disinfection Disinfection High Levels Flexible Endoscopes Cleaning and Processing Instruments and Powered Equipment Cleaning and Care of Packaging Systems Selection and Use Sterilization in the Perioperative Practice Setting Customizable Policy and Procedure Template available ANSI/AAMI ST79 Comprehensive guide to steam sterilization and sterility assurance in health care facilities 2006 and A1:2008 & A2:2009 2010 & A1:2010 ST79:2010/A2:2011 13
ANSI/AAMI ST79 2008-2009 amendments: - TASS, - Peel pouches, - Steam quality, - Devices with lumens, - Chemical indicators, - Product families, - Evaluation of containers, - Risk analysis, - Verification of cleaning and sterilization process failures. 2010-2 nd edition changes: - Steam quality requirements, - Paper-plastic plastic pouches, - Mechanical cleaning equipment, - Product quality assurance testing - Risk analysis, - Additional info on Class 6 CIs, - New section on New Product Evaluation. 2011 amendments - Manufacturer s written instructions for use = IFU, and - Hand washing = hand hygiene AAMI ST79 Amendment 3:2012 Examples The term SPD" revised to "sterile processing area". The design considerations = stronger loaner recommendations Anti-fatigue mats are recommended Describer how instruments come to SP» Delicate instruments on top and heavy on bottom» Orderly fashion and» Sharps segregated» Instruments requiring repair identified at the point of use Decontam staff have ready access to the device manufacturer's IFU Workstations should be ergonomic, preferably height adjustable Pre-vac sterilization cycles should be used, unless IFU requires gravity Dietary service items should never be processed in SP area 28 14
ANSI/AAMI ST79 Recommended Practice If You Have This AAMI Document ANSI/AAMI ST79: 2006 What To Purchase Purchase ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2011 What To Download Free ANSI/AAMI ST79:2006 and A1:2008 & A2:2009 Purchase ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 ANSI/AAMI ST79:2010 Download A2:2011 & A1:2010 PDF and replace pages (Consolidated Text) Then download A3:2012 PDF and replace pages 29 ANSI/AAMI ST79 Recommended Practice If You Have This AAMI Document ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 (Consolidated Text) ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 What To Purchase Most up do date What To Download Free Download A3:2012 PDF and replace pages 30 15
CDC Guideline for Decontamination and Sterilization Nationally recognized and are referenced by accreditation and professional organizations http://www.cdc.gov/hicpac/pdf/guidelines/disinfection_nov_2008.pdf CDC - Guide to Infection Prevention for Outpatient Settings The CDC declared Inadequate sterilization of surgical instruments has resulted in SSI outbreaks Evidence-based guidelines produced by the CDC and HICPAC - Minimum infection prevention expectations Infection prevention a priority IP gatekeeper to safe patient care Centers for Disease Control. Guideline for Prevention of Surgical Site infection CDC, 1999, p. 261. http://www.cdc.gov/hai/pdfs/guidelines/standatds-of-ambulatory-care-7-2011.pdf 16
CDC - Guide to Infection Prevention for Outpatient Settings Beyond OSHA bloodborne pathogen At least one individual trained in IP - Policies and Procedures based on evidence-based guidelines - Tailored to the facility - Reassessed on a regular basis - Based on risk assessment» Focus extra attention ti on areas that t pose greater risk (e.g. onsite sterilization ti of surgical equipment) http://www.cdc.gov/hai/pdfs/guidelines/standatds-of-ambulatory-care-7-2011.pdf Other Key Standards and Guidelines APIC - Guideline for Disinfection and Sterilization of Prion-Contaminated Instruments - SHEA/APIC Guideline: Infection Prevention and Control in the Long-Term Care Facility ASGE and SHEA - Multisociety guideline on reprocessing of flexible gastrointestinal endoscopes: 2011 SGNA - Guideline for Use of High Level Disinfectants & Sterilants for Reprocessing of Flexible Gastrointestinal i Endoscopes, 2007 - Standards of Infection Control in Reprocessing of Flexible Gastrointestinal Endoscopes, 2009 17
IUSS Position Statement http://www.aami.org/publications/standards/st79_immediate_use_statement.pdf Sterile Processing: Preparing for Accreditation Surveys Help facilities prepare for a accrediting agency survey relating to sterile processing Includes: - Accreditation standards, - Evidence-based guidelines and recommend practices, - Crosswalk between AAMI ST79 and TJC - Risk reduction tools, and - Sample audit tool Crosswalk http://www.aami.org/publications/books/sphc.html Seavey, R. Association for the Advancement of Medical Instrumentation. Sterile Processing in Healthcare Facilities: Preparing for Accreditation Surveys. 2011. 18
Preparation for an Accreditation Survey Accreditation Preparation Committee Accreditation Documents Relevant Professional Standards and Recommended Practices Representatives should include: - Sterile Processing, - Operating room, - Infection prevention and control, - Clinical/biomedical engineering, - Endoscopy, - Risk management, - Quality, - Safety, - Education, Administration, and - Materials management etc. Preparation for and Accreditation Survey Polices and Procedures - Facility design and housekeeping, - Personnel qualifications, training i and continuing i education, - Dress code -PPE, - Sterilization monitoring, - Receiving purchased or loaned items, - Handling, collection, and transport of contaminated items, - Assembly, package configurations and sterilization monitoring, - Following manufacturer s written IFU, - Maintenance and repair of medical devices. Staff involvement 19
References: Seavey, R. Association for the Advancement of Medical Instrumentation. Sterile Processing in Healthcare Facilities: Preparing for Accreditation Surveys. 2011. The Joint Commission. Updated: The Joint Commission s position on steam sterilization. Joint Commission Perspectives. July 2009:29(7):8. Accessed 7/8/2012 at: http://www.jointcommission. org/joint_commission_online_july_20_2011/ CMS Director of Survey and Certification Group memo to State Survey Directors on Flash Sterilization Clarification-FY 2010 Ambulatory Surgical Center (ASC) surveys, September 4, 2009. Accessed 7/8/2012 at: http://www.cms.gov/surveycertificationgeninfo/downloads/scletter09_55.pdf Young, Martha L. 3M Sterile U inservice in Sterilization Assurance Continuing Education. Preparing for a Joint Commission Survey. May 2012. Access at: http://multimedia.3m.com/mws/mediawebserver? mwsid=66666uf6evssyxtto8ta4xm6evtqevs6evs6e Vs6E666666-- &fn=joint%20comm%20survey_march2012.pdf Seavey, Rose. 3M Sterile U Inservice in Sterilization Assurance Continuing Education. Sterilization and High-Level Disinfection: What Centers for Meidcare and Medicaid Services (CMS) Will Be Looking For. September 2012. Accessed at http://multimedia.3m.com/mws/mediawebserver. ST79 - Comprehensive guide to steam sterilization and sterility assurance in health care facilities, ANSI/AAMI ST79:2010 & A1:2010 &A2:2011 & A3:2012 Recommended Practices for Sterilization in the Perioperative Practice Setting. In: Perioperative Standards and Recommended Practices. Denver, CO: AORN, Inc; 2012 Recommended Practices for Cleaning and Care of Surgical Instruments and Powered Equipment. In: Perioperative Standards and Recommended Practices. Denver, CO: AORN, Inc; 2012 CDC Guideline for Decontamination and Sterilization in Healthcare Facilities 2008 http://www.aami.org/meetings/summits/reprocessing/materials/2011_reprocessing_summit_publication.pd f Policy and Requirements for an Application for Deeming Authority. Accessed 7/12/2012 at: http://www.cms.gov/medicare/provider-enrollment-and- Certification/SurveyCertificationGenInfo/downloads//applicationrequirements.pdf Eiland, John E, Surveyor, The Joint Commission. Joint Commission presentation at IAHCSMM annual meeting in May 2012. Presentation available on flash drive provided to attendees. Louise Kuhny, TJC Survey Process: Second Generation Tracers. AORN webinar 9/22/2011 Immediate-Use Steam Sterilization. Accessed 7/8/2012 at: http://www.aami.org/publications/standards/st79_immediate_use_statement.pdf Policy and Requirements for an Application for Deeming Authority. Accessed 7/12/2012 at: http://www.cms.gov/medicare/provider-enrollment-and- Certification/SurveyCertificationGenInfo/downloads//applicationrequirements.pdf Eiland, John E, Surveyor, The Joint Commission. Joint Commission presentation at IAHCSMM annual meeting in May 2012. Presentation available on flash drive provided to attendees. Louise Kuhny, TJC Survey Process: Second Generation Tracers. AORN webinar 9/22/2011 Immediate-Use Steam Sterilization. Accessed 7/8/2012 at: http://www.aami.org/publications/standards/st79_immediate_use_statement.pdf