The Joint Commission Update for Infection Control

SHEA protests Joint Commission's proposed infection control standards

Revisions could dilute field, put ICPs back in silos

The Joint Commission has proposed standards revisions that could weaken infection control programs "significantly at a time when health care associated infections (HAIs) are receiving increasing attention by legislators, payers, and consumers," the Society for Healthcare Epidemiology of America (SHEA) warns.

In a letter submitted to the Joint Commission regarding its ongoing Standards Improvement Initiative (SII), SHEA protested a perceived dilution of infection control standards into the Leadership, Human Resources, and Emergency Management chapters.

"In addition, the standards as proposed do not speak to the integration of the infection control program into the organization's quality improvement and patient safety initiatives as strongly indicated in the Centers for Medicare & Medicaid Services (CMS) Draft Infection Control Interpretive guidelines," SHEA president Victoria Fraser, MD, stated in the letter. "This deficit coupled with the removal of programmatic resources, influx of communicable diseases, and staff competency and training to other chapters tends to 'silo' infection prevention and control activities."

Asked to respond to the SHEA comments, Robert Wise, MD, vice president of standards and survey methods at The Joint Commission, says: "Soliciting feedback from the field and the public is a vital part of the SII project and all comments received are taken into consideration. At this time it would be premature to respond to SHEA's concerns because modifications to the standards are still in process."

Specifically, SHEA urged the elimination of proposed standard IC.1.10 EP 2, which states: "When the individual(s) responsible for oversight does not have expertise in infection prevention and control, he or she consults someone with such expertise in order to make knowledgeable decisions."

The proposed standard "appears to dilute the authority of the infection control professional and the physician/hospital epidemiologist by implying that the administrative position to which infection prevention experts report should consult external experts if they themselves have no training or experience in infection control," SHEA argued. "We would propose that if trained and competent individuals are appointed to direct the infection prevention and control program [IPC], there is no need for the individual who had administrative oversight of the program to seek external consultation."

Changes would 'fragment' relationships

If ICPs need additional help or consultation, the more direct route would be for them to seek external consultation from experts as necessary, SHEA noted. "This should be supported by the administration. . . . The authority issue has been the backbone of successful IPC programs . . . It is more important to foster ongoing partnership and effective relationships between ICPs, health care epidemiologists and senior leadership and not to fragment those relationships."

The Joint Commission drew a similar backlash in 2002 after ICPs successfully protested a proposal to consolidate and reduce the number of infection control standards. That flap was followed by press criticisms that the Joint Commission was lax on infection control. As a result, the Joint Commission heavily emphasized infection control beginning with its 2004 patient safety goals and 2005 revised standards. Now, however, we seem to have come full circle, with SHEA warning that the currently proposed revisions will dilute and undermine infection control programs. Other specific points made by SHEA include key comments on the following proposed changes to existing standards:

• Current Standard IC.6.10

SHEA strongly disagrees with moving standards dealing with an influx of communicable disease patients to the Emergency Management Chapter. As indicated in this current standard and in current Environment of Care Standards, an integrated approach to emergency management, including involvement in local, state and national planning activities is key. Removal of this language from the Infection Control chapter dilutes the criticality of IC participation and fosters a silo approach. SHEA suggests instead a cross-reference here to leadership, medical staff, and environment of care standards as appropriate.

• Current Standard IC.7.10 EP 2

SHEA strongly disagrees with moving standards on qualifications of infection prevention professionals to the Human Resources chapter. Infection prevention and control specialists are unique in that literature shows education and specific training are necessary for reliable collection of data. This is especially necessary at a time when HAIs are receiving more and more public scrutiny, and mandatory reporting is required in at least 14 states. Having well-trained and competent ICPs is integral to public reporting mandates whose goal is to provide comparative information on HAI that can be used by consumers to make health care choices. This standard should be retained with a cross-reference to Human Resources.

• Current Standard IC.9.10

SHEA strongly disagrees with moving the IPC program resource assessment and provision to the Leadership chapter. This dilutes the emphasis on IPC resources (IPC as nonrevenue-generator) at a time when HAI are receiving more public and payer scrutiny. This standard should be retained with a cross-reference to the Leadership chapter. SHEA agrees with the Joint Commission focus on risk assessment based on geographic considerations, patient and employee populations, services provided in order to inform surveillance activities and programmatic planning and prioritization. However, the focus on written plans with written goals, objectives, and targets is too proscriptive and values form over substance. This focus may be especially problematic for smaller facilities with fewer secretarial resources.