ANNA's Response to JCAHO’s CKD certification program draft requirements

Background Information:

The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) has requested comments on its Chronic Kidney Disease (CKD) Certification program draft requirements. The objective of Chronic Kidney Disease (CKD) Certification Program is to create a set of standards that will by used as part of the evaluation of programs applying for Disease SpecificCertification for the care of CKD. The Joint Commission’s Disease Specific Care Certification is designed to evaluation disease management and chroniccare services. The evaluation and resulting certification decisions are based on an assessment of

  • Compliance with evidence-based national standards
  • Effective use of established clinical practice guidelines to manage and optimize care
  • An organized approach to performance measurement and improvement activities

The NKF Kidney Disease Outcome Quality Initiative (K/DOQI) has developed a set of clinical practice guidelines that focus on the evaluation, classification and stratification of CKD. These guidelines recommend the use of a standard terminology for the evaluation and classification of kidney disease; propose strategies for monitoring kidney function from initial to end stage; and suggest a methodology for the stratification of kidney disease based on risk factors and co-morbid conditions.

A panel of experts recognized for their ongoing dedication to research, education, advocacy and care for renal patients assembled in August 2005, to advise the Joint Commission staff on the identification and modification, as appropriate, of select requirements from the Kidney Disease Outcome Quality Initiative (K/DOQI) guidelines. The resultants from this endeavor are proposed for use as part of the evaluation of programs applying for Disease Specific Certification for the care of chronic kidney disease.

ANNA was asked by the American Nurses' Association to respond to these draft guidelines. Below is ANNA's response to ANA.


October 11, 2005

Rita Munley Gallagher, PhD, RN
Senior Policy Fellow
Department of Nursing Practice and Policy
American Nurses Association
8515 Georgia Avenue, Suite 400
Silver Spring, Maryland 20910-3492

Dear Rita,

The American Nephrology Nurses’ Association (ANNA) represents more than 12,000 registered and advanced practice nurses who care for patients with chronic kidney disease. Our members practice in a variety of roles including direct care to patients on dialysis, patient education, staff training and development, and home dialysis training and support.

As an organizational affiliate of ANA, ANNA supports ANA's responsibility to speak for nursing practice and we appreciate your role in soliciting comments from the nursing community in response to JCAHO’s Draft Requirements for Chronic Kidney Disease (CKD) Certification. ANNA will contribute to your response by sharing our comments with you by the deadline requested. However, since the subject matter of this topic is CKD, ANNA intends to continue “owning” this issue and we will respond directly to JCAHO as well.


JCAHO has recognized ANNA as a partner in this process. In July 2005, JCAHO sought out representation from ANNA to participate in a panel of experts and to advise the Joint Commission on the development of these < BR>standards. ANNA's appointed representative, Donna Bednarski, MSN, APRN, BC, CNN, CNP, has been an active participant on that JCAHO panel.

All nurses share the responsibility to identify individuals at risk for CKD. ANNA's members represent those healthcare professionals in the closest and most frequent contact with individuals with Chronic Kidney Disease (CKD) and as such, are heavily invested in JCAHO’s Draft Requirements for CKD Certification and the issues it suggests in how our patients will receive care and how the standards will be created, implemented, and evaluated.

ANNA wholeheartedly supports JCAHO’s initiative to create a specialty certification for CKD programs because we believe it will prevent the development and progression of CKD. And, since JCAHO's certification requirements are based upon the Kidney Disease Outcomes Quality Initiative (K/DOQI) Clinical Practice Guidelines for Chronic Kidney Disease: Evaluation, Classification and Stratification (guidelines that are well-known to our association, especially since many of our members have been active contributors toward their development), ANNA is uniquely qualified to review, analyze, and address JCAHO’s Draft Requirements for CKD Certification.

Therefore, as the voice of nurses who care specifically for patients with chronic kidney disease, ANNA intends to prepare its own response to JCAHO. We invite all stakeholders within the nursing community to provide us with comments about the proposed requirements so that we may develop a thoughtful and comprehensive response. Please send your comments to Donna Bednarski, by October 25, 2005. Thank you.


Suzann VanBuskirk, BSN, RN, CNN
President - American Nephrology Nurses Association