More to Learn Than Fear From Ebola

ebolaEbola is scary. Though I try to allay my fears with practicality and common sense, I am – like many Americans – very concerned. The unknown is always scary. I wanted to start with that assertion to place the rest of my observations in context.

We will, I expect, ultimately pull through this latest threat to our lives better than our current fears would predict. Assuming we do, when the dust settles and the national media moves on to cover the next threat to our lives we are going to be left with some very useful case studies that we (hopefully) can use to assess how and why the healthcare industry continues to be unable to effectively embrace and utilize quality process improvement.

Of course, we will have to get past the blame game, name-calling and talking heads wanting to put the fault upon political philosophy rather than where it rightly belongs: the human beings that are involved in the promulgation of guidelines and regulations, the implementation of guidelines and regulations and the adherence to guidelines and regulations.

Already today pointed fingers are flying around Dallas like roof shingles might during a Texas size tornado. Texas Presbyterian hospital administration is accusing the media of sensationalism (go figure). A nurses union is blaming the hospital for not protecting its workers. The CDC blamed – then didn’t – the hospital for not following protocols and guidelines. How George Bush is avoiding blame down there I can’t figure.

Finger pointing in times of crisis is an innately human characteristic that only few people can avoid. Those folks that do avoid it tend to make very good leaders, and unfortunately apparently have an abhorrence for public office. But in a very real sense the finger pointing underscores how far the US healthcare delivery system has to go to change the systemic cultural aspects that impede progress toward quality improvement.

As I have shared in this space before, my colleague Nathan Ives and I wrote a white paper a while back: Aligning Healthcare Organizations: Lessons in Improved Quality and Efficiency from the Nuclear Power Industry. I believe it is informative and particularly relevant today to compare the relative safety records of both the nuclear power and airline industry safety records to healthcare. The potential wide scale impact of an epidemic raises our collective consciousness to view healthcare safety on a par with tragedies in those other industries in a way that one death at a time simply does not, however right or wrong that may be.

Though somewhat dated, there was an interesting journal article written in the December 2003 issue of Quality and Safety in the Healthcare: Applying the lessons of high risk industries to health care. In it the author notes the exemplary safety performance achieved in the oil and gas and aviation industries. And then examines why healthcare – an industry with comparable high risks – has not done nearly as well.

As the author notes, “health care has always taken medical dangers seriously, so the culture cannot be pathological. The lack of systemic risk management suggests that the culture is, at best, reactive, even though there may be the occasional proactive area.” Though we have seen the industry try and address these inherent cultural differences over the past decade since this research was conducted, we only need to look at the flying fingers in Dallas to realize not much progress has been made.

Organizational process improvement leading to the type of sustainable quality and safety that has been achieved in other industries and disciplines cannot and will not be achieved through regulatory compliance alone. It requires a paradigm shift in the thinking and attitudes of healthcare industry participants who have been effectively able to resist change for a long time. If you are looking for a silver lining in this scary period we are living through, it could be that Ebola accelerates that paradigm shift. I do believe we have more to learn than to fear.

Cheers,
  ~ Sparky

P.S. See you at the LeadingAge Conference in Nashville! We’ll be in booth 1829.

NQS 2014 Annual Report

Quick hit to let Pub patrons know that the U.S. Department of Health and Human Services has released the 2014 Annual Progress Report on the National Strategy for Quality Improvement in Health Care. This is an initiative led by the Agency for Healthcare Research and Quality (AHRQ) and contains some interesting Priorities in Action – summaries of programs across the country seeking to leverage the NSQI platform.

For those seeking the snapshot . . .

Three aims

  • Better care: think patient-centeredness, reliability, accessibility and safety
  • Healthy people/healthy communities: think health & wellness, population health management and proven interventions
  • Affordable care: think value

Six priorities:

  1. Continuing to reduce unintentional harm associated with healthcare delivery
  2. Patient engagement
  3. Care coordination via “effective” communication
  4. Emphasis of prevention and treatment priorities for leading cause of mortality conditions
  5. Community-targeted best practices encouraging healthier lifestyles
  6. Encouraging new delivery and business models that can increase value (better outcomes/cost)

Cheers,
  ~ Sparky

QAPI From the Front Lines

One person lifts the word Compliant and others are crushed by non-compliance, as the winner follows This is the PolicyPub’s first post by a contributing author. I have recently written on the upcoming QAPI mandate included in the Affordable Care Act and the impact that will have on nursing homes – particularly those unprepared (which I am coming to realize appears to be the majority).

I am thrilled to have my Artower colleague, Terri Durkin Williams, R.N., L.N.H.A., share her practical experiences with QAPI.

The Nursing Home industry is being challenged to develop quality programs that consistently maintain regulatory compliance. This shift in continuous improvement will require organizations to self-assess their operational performance. In turn, this will move organizations from the established routine of monitoring systems to self-assessments.

The federal government has mandated a Quality Assurance and Performance Improvement QAPI standard under the Affordable Care Act. This mandate was to be established and implemented in nursing facilities by December 31, 2011. As yet, regulations implementing the QAPI program have not been released by CMS.

The purpose of the QAPI program is to develop best practice in providing services and care to nursing home residents. This should be the mission of all health care providers. Waiting for the government to lead us in our business is jeopardizing organization survival both financially and in the delivery of services and care.

QAPI is not a new concept: it has been widely used in healthcare organizations for quite some time. The nuclear power industry has embraced this process to assure quality controls, safety, maintain regulatory requirements, increase efficiency and enhance the reputation of individual power plants. Achieving these goals requires a significant commitment of organizational time and personnel.

Given the tremendous cost pressures and narrowing reimbursement, however, management often judges such commitment as an unaffordable expense. The tendency is to not proceed with an in-depth evaluation of organizational functions. This is too often unfortunate short-sightedness of executive management. It leads to undesired consequences such as, poor care resulting in litigation, staffing turn-over, declining census, fines due to regulatory deficiencies, dissatisfied customers and increase in regulatory over-sight to just mention a few potential outcomes.

A common current practice in quality assurance programs is to monitor a task that is being performed by personnel. The evaluator observes the personnel and uses a check list to determine if the standard being monitored is compliant. The pitfalls of this approach include:

  • Observers not being trained in a manner that results in the consistent application of standards used to perform the evaluation; i.e., the evaluation is based on the observer’s personal biases;
  • Personnel performing to the standard while being observed;
  • Personnel documenting what is required, but not assuring that care was delivered according to the established standard;
  • Monitoring as a snapshot observation; it does not tell the entire story;
  • Organizations using limited information that is gathered in the monitoring process to determine compliancy – this can give a false sense of success and prevent the exploration of best practices
  • Monitoring that  does not guide the organization to the root cause(s) of problems, does not allow for personnel to explain their performance and fails to obtain what knowledge the personnel have of the standard being monitored:

  • limits the beneficial involvement of all personnel in the process;
  • is often viewed by personnel as a punitive measure; and
  • creates a disconnect in communication throughout the entire organization.

Poor preforming organizations tend not to take time to complete a comprehensive assessment of their operational issues and challenges. They may feel that they do not have time for a comprehensive assessment. This causes them to guess at what the problem is and just perpetuates a poor practice.

Example Case
I was recently involved working with an 84-bed nursing home that had seven (7) “immediate jeopardy’s” for a period of six and a half months. Their approach to quality assurance was to have nursing managers spend several hours a day monitoring and documenting problems. But there was no understanding of the root cause(s) of those problems. They received fines from CMS of over a half million dollars. This organization would have benefited from a self-assessment program.

The alternative to this chaos is planning for cultural change that will lead to best practices. The embracement of the self-assessments program exemplifies this and is characterized by the following:

  • Supported by organizational leadership;
  • Involvement of personnel at all levels within the organization to promote professional growth;
  • Effective and efficient communication – a team working together and respecting each other;
  • Focus on evaluating the most important aspects of the people, process, and technology;
  • Comprehensive understanding based upon a collection of observations, record reviews, personnel interviews, benchmarking data, and other ongoing assessment information measured against specific criteria;
  • Identification of performance deficiencies and potential causes, organizational strengths and weaknesses and opportunities for improvement
  • Evaluates performance against established best practices;
  • Provides opportunities to change the culture of the organization;
  • Stabilizes daily operations, by consist expectations, policies and procedures and
  • Establishes a culture whereby organizations control their business activities based on mission and purpose.

Key components of a successful self-assessment program include:

  • Executive management and board leadership’s passion for excellence;
  • Identification of an individual that is supported by leadership as the Team Leader in championing the Art of Quality.
  • Entire self-assessment team educated on the organization’s mission and leadership’s expectations – and they are accountable for their actions;
  • Defined sequence of the self-assessment process;
  • Evidence based standards;
  • Requisite IT support that facilitates the collection of relevant data, analyzes information and provides benchmarking; and
  • An ability to have fun, learn and celebrate successes.

To explore how your organization can implement Artower’s EviQual™ Self-Assessment Program using evidence based practice contact me at twilliams@artoweradvisory.com or 216.244.2923.

  ~ Terri

Culture Change at the Core of QAPI

This past Friday I attended the 2014 Katz Policy Lecture at the Benjamin Rose Institute. Peter Kemper, PhD, Professor Emeritus of Health Policy, Administration and Demography from Pennsylvania State University gave the lecture on Expanding Culture Change to All Nursing Homes: Challenges and Policy Approaches.

Professor Kemper acknowledged early on what is often the opening salvo of critics of culture change – that defining exactly what it is can be a formidable challenge. In fact, as he noted, it may be preferable to think of culture change as a movement instead of a model. This perception would be consistent with the concept of continuous quality improvement where it is recognized that while operational perfection is inherently unachievable, evidence shows its pursuit drives measurably better outcomes.

Cutting through the theory and research, at its core culture change is the ability to create an organizational environment in which individuals are empowered, trusted and valued: and this must be true for both patients and the workforce caring for them. What does this look like? Well, in listening to the lecture I found that we need look no further than the five elements of Quality Assessment Performance Improvement (QAPI).

Element 1: Design and Scope: Culture change can only take place if there is a shared commitment to be cognizant and aware of how each individual’s role and responsibilities support achievement of the organization’s future state vision. To accomplish this there must be an understanding and pragmatic recognition that the approach needs to be comprehensive, inclusive and constantly evolving.

Element 2: Governance and Leadership: It is the organizational leadership’s primary responsibility to create the environment by owning (without controlling) the design and scope process, while the role of governance is to ensure sustainability and accountability of that environment once created.

Element 3: Feedback, Data Systems & Monitoring: The old adage of you can’t manage what you can’t measure, however incomplete in its ability to capture the full essence of organizational behavior, nonetheless is the primary means of incenting desired behavior while discouraging unwanted behavior (i.e., accountability). This must be a fundamental element of culture change, particularly from the standpoint of sustainability.

Element 4: Performance Improvement Projects: The key concepts attributable to culture change here are prioritization and ability to impact. The important nuance that many PA/LTC organizations have difficulty understanding is that PIPs don’t have to be directed retrospectively. They can (and should) be borne out of a comprehensive design and scope process (i.e., Element 1). This is a key element of intersection between culture change and QAPI programming that must be embraced and understood.

Element 5: Systematic Analysis and Systemic Action: Socrates noted that, “the unexamined life is not worth living.” I contend that an organization committed to culture change will continuously assess and examine whether and how well it is able to achieve its vision while fulfilling its mission and always reflecting its core values. This brings us full circle to the concept of continuous quality improvement noted at the beginning of this post.

As Professor Kemper also noted during his lecture, there is nothing necessarily innovative or revolutionary about culture change in PA/LTC. My observation is that it is really a matter of borrowing – or adopting – proven best practices of organizational behavior from other industries and research that dates back to the early 1900s. But going from theory and research to realized benefit takes the type of leadership that isn’t as easy to import. That’s where a lot more work needs to be done before either culture change or QAPI can achieve meaningful and lasting improvement in patient outcomes and life enrichment of the individuals served.

Cheers,
  Sparky

 

 

Picture Credit: Provider Magazine

QAPI: A Steep Learning Curve for Many

Compliance Conceptual MeterI am becoming increasingly concerned that many, if not most, post-acute/long-term care organizations are poorly prepared to embrace the requirements of the looming Quality Assessment Performance Improvement (QAPI) reporting requirements mandated by the Affordable Care Act. I base that conviction on how much I have learned over the past few years working with my colleague, Nathan Ives, of Strategy Driven Enterprises, LLC.

A graduate of the United States Naval Academy, for over two decades Nathan has been immersed in the world of quality assessment, performance improvement and regulatory compliance as each has applied to the nuclear power industry. He has held several influential positions at the Institute of Nuclear Power Operations (INPO) and has led teams of nuclear operations professionals in the performance evaluation of over 24 nuclear electric generating stations from 20 utilities in the United States, Canada, and Japan. He also led the nuclear industry’s effort to redefine performance standards in the areas of organizational alignment, managerial decision-making, plant operations, and risk management.

For the past two years, Nathan has been working with my Artower colleague, Terri Williams, RN, on developing EviQual™, a turnkey regulatory compliance solution that PA/LTC organizations can use to create a QAPI program. Terri has nearly 30 years of experience as a practitioner, educator and advocate for quality improvement and patient safety at PA/LTC facilities. Now, as a I have neither an operational engineering nor clinical background, for me it has been a fascinating learning experience. And what I have learned primarily is that QAPI – as understood from how it has been applied in other industries – is an entirely different approach to outcome quality and patient safety than what most PA/LTC organizations are currently familiar with.

Whereas historically those organizations have focused a great deal of attention on observing, recording and diagnosing the cause(s) of adverse events, the whole point of a quality assessment program is to proactively diagnose existing practices, policies and performance to create an environment in which such events don’t happen in the first place. It is a paradigm shift in thinking and approach that for most organizations must be accompanied by changes in organizational culture.

That’s why in creating EviQual™ we have sought to leverage the already existing knowledgebase of what has been proven effective in improving quality and safety in an industry that has many parallels with healthcare. In fact, Nathan and I collaborated on a white paper  some time ago on the applicability of lessons learned in the nuclear power industry to aligning healthcare organizations via quality and performance improvement.

The Centers for Medicare and Medicaid Services has made available QAPI at a Glance, a step-by-step guide focusing on 12 core elements ranging from organizational sponsorship and leadership to tactical  program implementation. A very well written accompaniment to that guide was just recently completed as a series of articles for Long-Term Care Magazine by Nell Griffin, LPN, EdM. Both are wonderful resources if you are new to understanding QAPI and the important ramifications it will have on PA/LTC organizations.

The first step in the 12-step process for implementing a QAPI program focuses on leadership, responsibility and accountability. What this requires is the active and committed sponsorship of the QAPI process by senior executives and board members. So when I hear leadership teams at PA/LTC organizations say they are confident their clinical teams are proactively addressing the QAPI requirements, I can’t help but fear those organizations have already stumbled out of the gate.

Cheers,
  ~ Sparky

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Pressure Mounts on SNF Performance

As a follow up to my post this past Friday, some additional political pressure aimed at assessing and improving safety and quality of care in America’s nursing homes has come in the form of a letter from Senators Bill Nelson (D-FL) and Charles Grassley (R-IA) to CMS chief Marilyn Tavenner. In that letter, dated April 2, the senators reference the now much discussed OIG report – Adverse Events in Skilled Nursing Facilities: National Incidence Among Medicare Beneficiaries – and challenge the CMS Administrator to reconcile the reported performance weaknesses with the current certification and survey process for nursing homes.

They went on to request an understanding of what steps CMS is taking to address the identified weaknesses in the survey and approval process. As has already been discussed, a primary means of response that CMS is counting upon is implementation of the long-awaited QAPI initiative, which will require SNFs to self-assess and critique their existing operational and clinical performance while developing a comprehensive plan to address and remedy identified performance gaps. And the resulting QAPI program of those facilities will then become subject to the state survey process.

The letter also referenced an IG report from November of 2013, Medicare Nursing Home Resident Hospitalization Rates Merit Additional Monitoring. The key finding of that report on which the senators focused was the noted variation in readmission rates across geographic areas (i.e., the associated hypothesis being that following existing best practices of better performing facilities could yield overall lower rates of readmissions – and thus lower costs to Medicare and Medicaid).

The upshot here is that SNFs now have giant targets on their backs. Provider advocates and trade associations now probably wish even more so that the QAPI regulations had not been so long delayed, as there might now be at least some political cover from being able to report work was already underway to assess these issues and challenges. Now when then QAPI regulations are released there will be heightened attention, focus and expectations of organizational compliance.

Bottom line for SNF organizations: if you haven’t started to familiarize yourself with QAPI, yesterday would be a really good time to start.

Cheers,
  Sparky

QAPI ~ Ready (or Not?)

2013-01-09_14251sI have been receiving a fair amount of anecdotal intelligence that many post-acute/long-term care providers are not at all prepared to implement the Affordable Care Act’s QAPI when (still waiting . . . ) those regulations ultimately get published. So I thought sharing this post again might be useful.

Section 6102(c) of the Affordable Care Act – Quality Assurance and Performance Improvement Program (or QAPI) requires the Secretary of Health and Human Services (as delegated to CMS) to, “establish and implement a quality assurance and performance improvement program …” and to, “…establish standards relating to quality assurance and performance improvement with respect to [nursing] facilities and provide technical assistance to facilities on the development of best practices in order to meet such standards.“

Last Friday CMS released a memorandum to state survey agency directors announcing the rollout of electronic assistance and compliance-oriented materials on the QAPI website. HHS/CMS has still not yet published the condition of participation regulation that will provide nursing facilities with compliance guidance (facilities were to have already been compliant in March of this year), but there already exists comparable regulations for other healthcare provider types that will serve as a template. Once that regulation is finally published nursing care providers will have one year to develop an acceptable QAPI plan.

QAPI compliance for nursing facilities is not entirely new. The nursing facility QAPI is based in part on existing Quality Assessment and Assurance (QA&A) regulations. However, the new planning and reporting provision significantly expands the level and scope of QAPI activities that nursing facilities must enact in order to ensure they continually identify and correct quality deficiencies as well as sustain performance improvement.

It is a tad ironic that in promoting a key differentiator between historic, traditional quality assurance – now being coupled with performance improvement – that while quality assurance is to be viewed as a requirement and reactive, performance improvement should be viewed as discretionary and proactive. Never mind that performance improvement is being mandated as part of the QAPI program. Sort of like being able to choose any whole number between zero and two, right?

Anyway, I really fear that for a lot of nursing facilities – particularly smaller and/or single site organizations – this requirement is going to sneak up on them. And the true impact of that reality will not just be the regulatory and economic consequences but the lost opportunity to utilize the QAPI process to drive better quality, higher safety and better outcomes – while lowering the overall cost of care.

There are two ways to view the new QAPI requirement: another onerous regulation designed to burden caregivers with unnecessary compliance requirements at additional cost; or an opportunity to sponsor and embrace a process that – if done strategically and conscientiously – should improve productivity and efficiency while strengthening market position based on quality and outcome characteristics.

So my counsel is don’t wait for the regulation to be promulgated. Start now to learn and understand the tools that have already been made available. CMS has stated that, once provided, the QAPI formal regulation will not contradict the materials that have already been developed and provided.

And for those organizations that are truly interested in taking a strategic approach to developing a continuous quality improvement system that has the complimentary advantage of combining regulatory compliance with value-driven financial performance, please review the white paper that I drafted with colleague Nathan Ives of StraegyDriven Consulting, Aligning Healthcare Organizations: Lessons in Improved Quality and Efficiency from the Nuclear Power Industry.

Cheers,
  Sparky

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