The Joint Commission (TJC) and the Accreditation Association for Ambulatory Health Care (AAAHC) added some flexibility to the accreditation process in response to the COVID-19 crisis.
TJC suspended all regular surveying as of March 16. Surveys for high-risk situations might continue, and no restart date was set.
One day later, AAAHC announced all accredited organizations will remain accredited during the remainder of pandemic, regardless of their anniversary or expiration dates. The organization postponed all non-emergency surveys that were scheduled to occur between March 18 and May 15.
High-priority AAAHC emergency surveys may be completed, depending on surveyor availability, organizational access restrictions, travel limitations, and other factors. Also, the AAAHC change notification is waived, until further notice, for temporary closures, suspensions, and expansion of services directly related to the COVID-19 pandemic. “Priority surveys include immediate jeopardy complaint surveys and initial surveys,” says Therese Poland, RN, BSN, MSN, senior vice president of accreditation services at AAAHC.
AAAHC is calling on organizations, within their survey window, to verify the organization’s hours of operations, procedures, and to find out if there have been any confirmed or suspected cases of COVID-19.
“As a reminder, personal protective equipment [PPE] should be made available to all surveyors during this time,” Poland says. “AAAHC believes that facilities should be survey-ready all 1,095 days of the accreditation term. Should AAAHC conduct an onsite survey during this time, although the survey will proceed in accordance with the standard scheduled, there will be a heightened focus on infection control.”
The Centers for Medicare & Medicaid Services (CMS) survey process also has changed. CMS will prioritize any immediate jeopardy situations for surveys and delayed revisit surveys, said Michelle McDonald, RN, MPH, CJCP, executive director of government regulations & advisory services at TJC. McDonald spoke about CMS’ revisions during a webcast on April 15.
“Federal surveyors will perform targeted infection control surveys of facilities in those areas in most need of additional oversight,” McDonald added.
CMS surveys that are not authorized include standard surveys for hospitals, long-term care facilities, home health agencies, hospices, and immediate care facilities for individuals with intellectual disabilities, according to Kathryn Spates, JD, ACNP-BC, executive director of federal relations for TJC. Spates also spoke during the April 15 webcast.
Since the pandemic started, CMS issued guidance that allows ambulatory surgery centers (ASCs) to enroll as hospitals and provide inpatient and outpatient hospital services to help expand hospital capacity.
In its April 3 memo, CMS wrote, “Any Medicare-certified ASC wishing to enroll as a hospital during the COVID-19 public health emergency should notify the Medicare administrative contractor that serves their jurisdiction of its intent.”
ASCs have to sign an attestation statement. Also, they cannot be certified and enrolled as both an ASC and hospital concurrently. Further, onsite surveys are not required for approval.
“Note that once there is no longer a need for the ASC to be a hospital under their state’s emergency preparedness or pandemic plan, the ASC should come back into compliance with all applicable ASC federal participation requirements, including the conditions for coverage,” the guidance reads.
As some parts of the country reopen public activities and elective surgeries return, surgery centers should follow the rules established by their accrediting organization. For instance, surgery centers accredited by AAAHC should continue to submit their application for survey, regardless of whether COVID-19 affected operations, according to Poland. “Organizations with completed applications on file will remain accredited until the next accreditation decision is rendered,” she added. “Once normal operations resume across the country, AAAHC will schedule surveys through a catch-up process.”
When a surgery center suspects a case of COVID-19 on site and is within a survey window, or it is within 14 days after a survey, the organization must notify AAAHC by calling (847) 324-7485, Poland said. “There is no need to report community outbreaks, just cases in your organization,” she explained. If a primary contact changes during the COVID-19 crisis, the surgery center should send an email to AAAHC at email@example.com, Poland reported.
Once the COVID-19 surge passes and the state lifts shelter-in-place orders and other restrictions, the AAAHC may schedule a survey. AAAHC will develop a plan for prioritizing surveys with consideration to the anniversary/expiration date, program type, state and contract requirements, and other considerations, Poland explained. “The status of each state regarding shelter in place and travel orders will also be factors considered,” she added.
Surgery center administrators should remember that AAAHC officials understand compliance with all requirements might be challenging during the pandemic, Poland noted.
“AAAHC acknowledges that these are unprecedented times and that there are several variables that may impact an organization’s ability to maintain full compliance of certain requirements,” Poland offered. "For example, an organization's decision to temporarily close or change status may impede existing QI [quality improvement studies. They may be required to implement crisis strategy for management and use of PPE, or they may even be utilizing staff with expired ACLS [advanced cardiac life support]," Poland says. "AAAHC will soon be releasing guidance that aims to address such questions."
As the pandemic continues, AAAHC noted ASCs could contract with a local hospital to provide that facility overflow space. As a last resort, ASCs may choose to close shop for the duration. If an ASC chooses this route, AAAHC suggests leaders could sell or lease equipment and other critical supplies to local hospitals in need.