Oct 06 2017

Contractors During a Survey

Category: BlogBKeyes @ 12:00 am
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In preparation for a survey hospitals frequently train their staff to only answer the questions of the surveyors without providing any more information. This has proven to be good advice over the years because many deficiencies are discovered by surveyors based on information provided by the staff after they have answered the surveyor’s questions.

An example of this may be when a surveyor asks a hospital worker what they would do in the event of a fire, and the worker correctly replies by describing the actions suggested by the acronym RACE – Rescue, Alarm, Confine, and Extinguish (or Evacuate). But when the surveyor simply does not respond and the awkward silence builds, the hospital worker gets a bit nervous and continues to speak, eventually revealing some errant activity that is not part of the fire safety plan. That often opens the door for disaster.

Nowhere is this more dangerous than when surveyors are permitted to talk with contractors in the hospital. It has always been my belief that as the survey team walks in the front door of the hospital on the first day of the survey all of the contractors should be walking out the back door. For the most part (and I do understand that there are exceptions), contractors should be sent away once you know there are surveyors in the house. Why? Because they will get you in trouble one way or another.

I recently received an email from a reader who shared this story:

During our triennial survey the life safety surveyor asked me how we knew that the fire alarm system signal was received by our monitoring company. I could not immediately answer the question, but we were lucky to have the service contractor in the building doing his quarterly testing and I suggested we ask him.

 The service technician explained that the software in the fire alarm control system will indicate if the alarm is received by the monitoring company within the designated amount of time. I was quite happy with the service technician’s explanation until the surveyor said “Prove that it happened at least quarterly for the past 12 months”. [This was back when the signal was required to be tested quarterly… today it is only required to be tested annually.]

 The service technician said nobody could prove it; we just have to take his word for it. [Wrong answer.] The surveyor asked “Don’t you call them by telephone to confirm they received the signal?” The service technician replied, saying “Well, would you trust me if I said I did call?”

The surveyor was correct to ask the questions that he/she did. The service technician was probably answering them to the best of his ability, but the real problem is the facility manager allowed the surveyor to enter into a conversation with a contractor. During a survey, the hospital staff should try and control the process as much as possible. By allowing a surveyor to ask questions of a contractor, the facility manager lost control of the situation and will suffer any consequences of what a contractor may say.

Contractors are not trained and educated in the regulatory requirements the same way the hospital staff are (or should be). The contractors may not even know or understand the significance of an accreditation survey, or even a CMS certification survey. Service technicians have a tendency to take an attitude that they know more about the system they are working on than the hospital does, and for the most part they do; otherwise, the hospital would not hire them. But the service technician may not know what specific regulations that the hospital must comply with and therefore may say something to a surveyor that may get you in trouble.

I’m not saying you should not be transparent in your processes, but during a survey, you need to control as much as you can of the survey process. This is not unethical or wrong; it is just smart business. Let the surveyor go where he/she wants; let the surveyor ask questions all they want; but eliminate the potential “loose cannons” that are not very well educated on the survey process by sending them home during the survey.

Another reader sent me an email earlier this year explaining that on a day during the accreditation survey a roofing contractor set a pallet of roofing material right in the middle of the exit discharge of a staff entrance/exit to the hospital. Nobody from the hospital was aware that the roofing contractor was about to do that, but the surveyor noticed it as soon as it happened and it went into the survey deficiency report.

When I was a surveyor for The Joint Commission, I would purposely seek out contractors and ask them what training the hospital provided them on fire safety procedures. Ultimately, contractors are expected to know the same fire response procedures as the staff. Invariably they could not answer the question satisfactory and it would be cited in the survey deficiency report.

I know that in some situations you cannot send the contractors home for the duration of the survey, but it seems that a large percentage of them could. At the hospital where I worked as the Safety Officer, I asked the project management team to send the contractors away during the week of the survey (this was when the surveys were announced). The project managers thought that was a good idea, but we were over-ruled by the COO of the hospital, because he did not want the opening of the new renovated unit to be delayed. That ended up being a costly mistake.

The hospital had a policy that every contractor had to receive basic safety orientation before they begin their work on the campus of the organization. Unbeknownst to the hospital, the general contractor brought in a sub-contractor to install flooring in one area, and they did not go through the safety training because the general thought it would be “okay” since the sub was only going to be there for one day. Sure enough, the surveyor found that one sub who had not received the safety training which led to a finding on the survey deficiency report.

You need to control what you can, and sending the contractors away is the smart thing to do during a survey.

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Jun 19 2014

Consultants Present During Survey

Category: BlogBKeyes @ 5:00 am
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images7E1G3SXKWhen I was a surveyor for Joint Commission, I had a few surveys where the hospital invited their consultant to join in on the building tour.  Back then surveys were scheduled with the hospital and were not unannounced, which allowed them time to have their consultants at the facility. The consultants were typically architects or engineers who had expertise in the Life Safety Code and wanted to observe the survey process. For the most part, they were very polite and respectful of the survey process and did not cause any problems.

But there was one survey where the hospital had their consultant stalking me. He found out what hotel I was staying at and showed up at the breakfast table and introduced himself, and announced that he would be joining me at the hospital. I thought that was odd, because the survey hadn’t even started yet. Back then surveyors typically stayed at hotels recommended by the hospital, so finding out where we stayed wasn’t that difficult.

Sure enough, when I arrived at the hospital there was Mr. Consultant with a sly grin on his face that implied “I told you so”. I had the sneaky feeling I was going to have a bad day. During the building tour, Mr. Consultant seemed to contradict everything I said, and before too long it was apparent to me that he was grand-standing in front of his client. I suspect he thought if he could discredit what I was finding deficient during the survey, it would put him in a favorable light with his client. After an hour of his constant interruptions and disagreements with my observation, I told him he needs to remain quiet and if he couldn’t I would ask the hospital to remove him.

That didn’t work and only seemed to pour gasoline on the fire. I then went to the survey team leader and explained the problem to her, and together we approached the CEO and explained the situation. Shortly after that meeting, Mr. Consultant was gone and out the door.

Why do I tell you this story? Because, at times hospitals want their consultant(s) present during the survey in order to provide answers that the facility manager may not know. That’s okay and permitted by most accreditation organizations, but when the consultant becomes disruptive, then it is a problem that must be dealt with.

Here are some basic ‘unwritten’ rules concerning consultants present during the survey, that I have developed. These are not based on any particular accreditation organization’s policy or procedures:

  • The surveyor’s questions and comments should be directed towards the hospital staff, such as the facility manager, safety officer or other such employee, and not to the consultant.
  • If the surveyor asks a question, the answer should come from the hospital staff.
  • Avoid the situation where the consultant tries to debate or argue with the surveyor about an observation.
  • Use the consultant as a resource only when the hospital staff is unable to answer a surveyor’s question.
  • Remember, the hospital staff can always share the report with the consultant after the survey.

Whatever happened to Mr. Consultant? I ran into him a couple of years ago at the annual ASHE conference and he remembered me (and I him). He picked up where he left off and continued to tell me I was wrong in my observations. Perhaps I was… I don’t remember the issues, but some things never change. Mr. Consultant was still grandstanding only this time there was no one there to observe him.

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