Understanding JCAHO’s continuity requirements

You must establish access to medical records

Is your organization prepared to answer tough questions about how information is shared across the continuum of care? It had better be if you want to win approval from the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), experts say.

Increasingly, the Oakbrook Terrace, IL-based Joint Commission is stressing effective integration among practitioners and affiliated organizations in coordinating patient care, says Patrice Spath, ART, BA, a health care quality and resource management consultant based in Forest Grove, OR.

Indeed, as part of the Joint Commission’s survey process, expect to undergo an interview specifically designed to assess how your organization plans and provides continuity of care. Typically conducted toward the end of the survey, it’s an opportunity for surveyors to probe any continuity-related problems they’ve managed to uncover during the first three days of the survey.

Be aware that as part of the continuum-of-care interview, the surveyors will want to speak with representatives from related organizations or agencies, including home care, hospice, long-term care, and social work, says Susan Goodwin, RN, MS, CPHQ, director of quality management at Columbia/HCA in Nashville, TN.

Generally speaking, the surveyors will want to hear from any organization that is "organizationally or functionally related" to your own, or to any organization that the general public perceives to be related (for example, through joint advertising), says Goodwin.

The following are sample questions that managers and staff might be asked during a continuum-of-care interview, according to Michelle Pelling (Hospital Manager’s Guide to Joint Commission Standards, 1997. Forest Grove, OR: Brown-Spath & Associates; 1996.)

What criteria does your department use to determine the appropriateness of a patient’s entry to your service or setting?

Upon a patient’s entry or admission, are there mechanisms to provide patients and families with information about the care they are going to receive?

What procedures have been instituted to ensure continuity of care for patients as they move to different areas in the organization?

What mechanisms are in place for coordinating patient care among health care professionals?

How do you obtain patient care and clinical information when patients are being admitted, referred, transferred or discharged to your service area?

What mechanisms are in place to assure that you provide adequate patient care and clinical information to other settings when you are referring, transferring or discharging a patient?

If you have services and medical records in different locations, such as the hospital and at the home health care agency with which you contract, it’s crucial that you have the ability to assemble those records if necessary for the care of a patient, says Goodwin. You must also be able to articulate a consistent procedure for accessing those records.

ED physician may need home health records

For example, a patient comes the hospital’s emergency department for treatment. Previously, the patient had received care from a home health care agency that has a contractual arrangement with the hospital. The ED physician decides that she needs to see the agency’s records to determine what has been going on with the patient in the home setting. If the hospital and the agency are considered part of the same overall organization, then the Joint Commission standards would require the hospital to have the ability to pull the home health care records together and supply them to the emergency department physician.

The hospital and home health agency could be considered part of the same organization if, for example, they reported to the same governing board that controlled their budget and resource allocation, they shared policies and procedures, the employees of the home health agency were employees of the hospital, or if the agency was being advertised as an agency of the hospital.

Spath cautions, however, that even if the hospital and home health agency are not considered part of the same organization, it’s still important to explain how those records could be accessed. "I don’t think it’s acceptable to say, ‘Well, we don’t have a contract, so we don’t have a way of accessing [the home care record].’"

Consistency is the key in establishing how information flows throughout the system, Spath adds. "You must be able to say, ‘I know the next step to take, whether it’s a contracted provider or not a contracted provider,’" she says. "You need to define in your organization how you’re going to be able to do that and then be able to articulate that next step to a Joint Commission surveyor. The worst thing to say to a surveyor is, ‘I didn’t know we had to worry about that.’ The best thing is to be prepared with an answer."

Joint Commission surveyors may also assess continuity-of-care issues through document review, medical record review, visits to different patient care settings, and various leadership interviews.

"The Joint Commission is trying to get us to think like a network," says Spath. "Ultimately, they want to place some responsibility on everyone in the provider system to work together as a team. How quickly that’s going to occur depends on how quickly we become integrated systems rather than individual providers."

Spath adds, however, that, regardless of what the Joint Commission wants, "what’s best for the patient is that information flows throughout the continuum of care. It’s also in your best interest as a health care provider. And believe me, as you move more into capitation, you will not be able to be financially viable unless you have an information system that will allow you to collect data throughout the continuum."