In the first installment of this series (O&P Business News, February 2013) I discussed the variables one can encounter in the facility accreditation survey process. One of those variables is the facility itself. Depending on your scope of service, the facility requirements can vary.
I look at site surveys as a two-part process: the first comprises the paperwork, ie, logs, files, manuals and other documentation; the second part concerns the facility itself. If you lack some paperwork, it can be dealt with later. If your facility is on the second floor with no elevator, that is going to be a problem.
Every O&P facility worth its salt should go out of its way to comply with the Americans with Disabilities Act of 1990 (ADA), which states, among many other things, that any commercial or government building must be accessible to individuals with ambulatory impairments. For the most part, this is almost everyone who comes in to see us.
Image: Three Roads Communications
If there are barriers or impediments to the access of our facility, we are, at the very least, losing business. Here are a few things that most surveyors will be looking for as they relate to the ADA:
Handicapped parking. There should be at least one parking space per patient care room. For most facilities this will be a high percentage of the available spaces.
Bathrooms. Bathrooms should be large enough to maneuver a wheelchair in, have accessible handrails at the commode and have a sink positioned at an appropriate height.
Ramps where appropriate. All entry ways should have very low thresholds, if any at all. It pays to also check exterior walkways for gaps and ridges. It is easy and cheap to sand down or fill in uneven spaces of concrete sidewalk.
Wide doors for patient access. Exterior doors are supposed to have an automatic door opener as well but a bell to call for service will sometimes suffice.
Patient contact rooms
Patient contact rooms, or fitting rooms, should have everything required for consulting, casting and fitting patients for everything covered in your scope of practice. Depending on the care you provide, examples may include, but are not limited to, parallel bars, mirror, eyewash station, chair with arms and appropriate supplies (casting material, stockinette, measuring tape, etc). Many patient rooms will also have a sink with running water and more elaborate appointments such as a casting bench and elevated platform with stairs and a ramp. Some will also have copies of certifications, licenses and training certificates but all must have floor plans posted with the fire escape route marked clearly.
Lab and storage areas
To start, the lab should be appropriate to the practice. If you are fabricating your own devices, you will need the lab to do it. A satellite location can get by with surprisingly few tools. All the equipment needs to be safe and compliant with Occupational Safety and Health Administration guidelines, whatever the level of the lab’s capability. All the machines should be safely spaced apart and have all their guards in place. Their power cords should not be frayed and should not be overloading any power outlets. Dust collectors and proper ventilation must also be in place.
How does your surveyor know if all the equipment has been properly maintained? He will ask to see your equipment management log, of course. This is the log you keep with the dates, type of service and servicing personnel for each task performed. Do you have scheduled times to change the oil in the air compressor? Clean and replace oil and air filters? You should regularly document all the things you do to keep the shop running smoothly.
One of the most important things every surveyor will be looking for in the lab is the Materials Safety Data Sheet (MSDS) book. It should be located in an obvious place, usually next to the first aid kit and eyewash station, which should also be displayed prominently. The MSDS book will need to be complete and up to date. I recommend designating a set time at least once a year to make sure it is current and update it if it is not. While you’re at it, this would also be a good time to restock the first aid kit, replace smoke detector batteries and do any other yearly safety maintenance.
Although few facility accreditation surveyors look for HIPAA compliance in the lab, it will probably become an issue in the future. The American Board for Certification in Orthotics, Prosthetics and Pedorthics (ABC) has already laid down accreditation standards for fabrication labs and now offers that option. Although CMS does not yet require fabrication facilities to be accredited, you can expect that to change. Inconsistencies in how the standards are applied have already surfaced and I believe that fab-lab accreditation will be one of the solutions. ABC has already gotten in front of this trend and I expect the Board of Certification/Accreditation, International to follow suit as soon as CMS requires it. Welcome to the future.
O&P facilities are graced with a couple of exceptions written into the CMS Facility Accreditation Standards. One of these exceptions deals most specifically with durable medical equipment (DME). The standards require the facility to be capable of cleaning and repairing things like wheelchairs, powerchairs and hospital beds, or whatever DME items are in the scope of practice. This means there needs to be a clear and distinct separation between clean and dirty items and a well stocked area for cleaning and disinfecting said items. Although O&P facilities are required to have the ability to clean and disinfect items that come in for repair, the space requirements are vastly different. A KAFO isn’t nearly as big as an electric hospital bed.
Another thing O&P providers don’t need to have is a proper delivery vehicle. We sometimes find ourselves making home deliveries, but the things we carry are not subject to the same restrictive requirements needed to control larger or more dangerous items such as beds and oxygen tanks. O&P professionals can use their own personal or company vehicle so long as it is maintained and the proper care and ownership records are kept.
Keep it clean
A lot can be said for a place that is clean and tidy. I’ve seen many facilities during the past 30-plus years and I’ve seen some things you would not believe, on both ends of the cleanliness spectrum. We can debate all day whether the devices and care provided in a filthy facility are better or worse than those provided in a clean facility. What isn’t debatable is the perception such facilities give to the patient and to everyone else who walks through the doors. When a surveyor sees the public spaces are not clean, he might wonder what it is like when you aren’t expecting him. If new, undelivered items are lying on a bench next to an old, filthy item in for repair, the surveyor might wonder if the policies and practices for infection control are being followed when he is not around.
We all realize that a busy practice will have devices in the works taking up bench space. But that doesn’t excuse an inch of dust on top of everything else. As a dog trainer once explained to me, a clean lab is a happy lab. I’m pretty sure he was talking about O&P facilities.