Joint Commission backs off plan to cut infection control regs after ICPs protest

JCAHO will convene infection control task force to discuss options

In response to strong protests from infection control professionals, the Joint Commission on Accreditation of Healthcare Organizations has dropped plans to reduce the number of infection control standards in 2004, Hospital Infection Control has learned. Instead, the Joint Commission will form an infection control task force in the near future to review the standards and determine if changes need to be made, JCAHO spokeswoman Charlene Hill tells HIC.

"We were trying to simplify the standards and reduce duplication," she says. "The field review showed there was some confusion [about the Joint Commission action]. Rather than perpetuate that perception, we decided we are not going to change the standards. We are leaving the infection control standards intact."

As part of its new Shared Vision – New Pathways accreditation initiative, slated to begin in January 2004, the Joint Commission is streamlining and synthesizing some aspects of hospital accreditation surveys. "It shifts the focus from survey preparation to focusing on operations and internal systems that directly impact the quality and safety of care," says Dennis O’Leary, MD, JCAHO president. Some of the planned changes include:

• A required midcycle (18-month), self-assessment during which the health care organization will evaluate its own compliance with the applicable standards and develop a plan of correction for identified areas of noncompliance. Validation of corrections and other randomly selected self-assessment findings will occur during the on-site survey at the end of the triennial period.

• On-site evaluation of standards compliance in relation to the care experience of actual patients.

• Substantial consolidation of the standards to reduce the paperwork and documentation burden of the survey process and increase its focus on patient safety and health care quality.

It was the "consolidation" aspect of the plan that ran afoul of ICPs. As part of that effort, the Joint Commission planned to rework the current nine hospital infection control standards into three overall standards. But ICPs have long been protective of their historical ties to Joint Commission requirements, which many consider are the only reason infection control programs haven’t been slashed from hospital budgets years ago. Streamlining the standards — even if only done to expedite the survey process — could lead to the perception that infection control programs run by certified professionals were lessening in importance, ICPs feared.

As a result, protest letters were sent to the Joint Commission and posted on the web site of the Association for Professionals in Infection Control and Epidemiology.

"Your purpose may be to give the facilities more flexibility in their programs and to make it easier for them to operate and comply," wrote Robert A. Hotchkiss, consumer director/advocate of the Certification Board of Infection Control and Epidemiology Inc. "I contend that this reduction in specificity has the high probability of bringing about a reduction in both the quality and quantity of infection control and prevention practices and procedures." Indeed, facility management is constantly looking for ways to cut costs, and the proposed changes could give them the leeway to do so, he added. The draft standards reduce the emphasis on infection control and prevention procedures at a time when the public is closely watching patient care and safety in health care facilities, Hotchkiss warned. "Your proposed new policy permits hospitals to decide locally what and how to staff or not staff infection control prevention functions," he continued. "This may well set the stage for increased infection control problems in the U.S."

Moreover, the changes would have de-emphasized certification in infection control — the "CIC" status that gives the field professional credibility, added Keith H. St. John, MT (ASCP), MS, CIC, president of the Certification Board of Infection Control and Epidemiology Inc. (CBIC). Certification validates the knowledge mastery required for infection prevention, control, and applied epidemiology, he told the Joint Commission. "I was dismayed to see that the Joint Commission has drafted proposed revisions of its infection control standards to be less rigorous than in the past 25 to 30 years," St. John stated.

"Specifically, your proposed new IC.1(4) standard ignores minimal educational or experience requirements for those persons assigned to oversee the infection control process," he continued. "With the current emphasis on the prevention of adverse events in health care settings, and the recent media coverage on adverse patient outcomes due to nosocomial infections, we at the CBIC feel that JCAHO is in a leadership position to ensure high-quality health care through accreditation, and by requiring that the qualified persons’ responsible for infection control in health care organizations are educated and certified in infection control and epidemiology."

In addition, reducing the standards flies in the face of the fact that the role of the infection control professional has expanded greatly over the last few years. That increase in the scope of services should be recognized within the Joint Commission standards, St. John noted. He requested that the organization reconsider its proposed revisions with input from CBIC, APIC, the Centers for Disease Control and Prevention (CDC), and the Society for Healthcare Epidemiology of America. According to Hill, ICPs will be represented on the task force that will be formed on the matter.

The concerns were echoed by Georgia Dash, RN, MS, CIC, APIC president, who urged that Joint Commission standards "should specifically recommend the integral involvement of the infection control program in key areas such as bioterrorism preparedness, patient safety, and emerging infectious diseases. There is literature and research to demonstrate the advantages of infection control expertise in these areas."

APIC suggested several other actions, many of which will no doubt be reiterated when the Joint Commission forms its task force on the issue. APIC strongly encouraged the Joint Commission to incorporate the following elements into the revised IC standard:

  • evidence-based practices;
  • performance measures, as suggested in CDC guidelines;
  • accurate and appropriate examples based on current literature and known disease transmission and epidemiological data;
  • the critical need for qualified infection control professionals whose roles have been shown to enhance patient outcomes;
  • appropriate staffing for infection prevention and control;
  • demonstrated practice measures;
  • the importance of infection control in preparing for bioterrorism response;
  • the importance of infection control in designing patient safety processes;
  • infection control risk assessment of the environment.

(Editor’s note: To help ICPs understand and comply with ongoing changes by the Joint Commission, Hospital Infection Control will begin publishing a free new quarterly supplement. Look for the first issue of JCAHO Update for Infection Control in your February 2003 issue of HIC.)