Letter from ANNA to the American Nurses Association regarding the JCAHO Field Review on the National Patient Safety Goals and Requirements for 2007

January 3, 2006

Rita Munley Gallagher, PhD, RN

Senior Policy Fellow

Department of Nursing Practice and Policy

American Nurses Association

8515 Georgia Avenue, Suite 400

Silver Spring, MD  20910-3492

Dear Dr. Gallagher:

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

Thank you for allowing ANNA an opportunity to provide input into the JCAHO Field Review on the National Patient Safety Goals and Requirements for 2007. As the voice of nurses who care specifically for patients with CKD, and as an organization, we had the JCAHO Field Review on the Proposed Revisions reviewed by our Acute Care, Chronic Kidney Disease, and Advanced Practice Special Interest Groups as well as the Professional Practice Committee and ANNA Board of Directors.  Our focus was on the ambulatory and hospital requirements and believe the following:

Ambulatory:

Requirement 3E Anticoagulation Therapy:

We do not agree it should be a goal for the ambulatory setting. Anticoagulation therapy utilized in dialysis has different requirements based the setting. A pharmacist is not involved in anticoagulation for dialysis nor is one available in most ambulatory settings.

Requirement 15C Respiratory Comorbidities:

Is not relevant to our settings and no further risk assessments were identified for goal 15.

Requirement 16A Disruptive Behavior:

We agree this should be added as a goal in 2007.

Requirement 17A Orientation of Temporary or Agency Staff:

We agree that this should be added as a goal in 2007 with modification, the expectations identified are extensive, particularly as the contracted acute dialysis nurses may provide services at multiple hospitals and attendance at each is cost prohibitive.

Requirement 19A Health Care Worker Fatigue:

We agree this should be added as a goal in 2007.

Additional Goals/Comments: No additional goals or comments were identified.

 

Hospital:

Requirement 3E Anticoagulation Therapy:

We agree that this should be added as a goal in 2007 with modification, the expectations of a pharmacist being involved with every in-patient on anticoagulation therapy is excessive, particularly for those patients on maintenance Warfarin therapy. Clarification is also needed in the education process as the expectation states it is to be under the supervision of medical staff prior to discharge.  This is not practical as education is a domain of nursing, as well as a pharmacist, and does not require supervision.

Requirement 15B Pressure Ulcers:

We agree that this should be added as a goal in 2007 with modification, the expectations include specific interventions for care and nor are reflective of evidenced based practice, i.e. massage. Clarification of use of mechanical loading and support surfaces (does this refer to pressure relief surfaces?) is also required as it could be cost prohibitive if is it required for all patients. Protocols on their use could be established so that they are utilized on the patients who do require them.

Requirement 15E Suicides:

We agree this should be added as a goal in 2007.

Additional Risk Assessments for Goal 15: No additional risk assessments were identified.

Requirement 16A Disruptive Behavior:

We agree this should be added as a goal in 2007.

Requirement 17A Orientation of Temporary or Agency Staff:

We agree that this should be added as a goal in 2007 with modification, the expectations identified are extensive and may be time-intensive to implement.  Written tests may also be duplicative with agency orientation and hiring processes.

Requirement 18A Early Recognition and Response Teams:

We do not agree it should be a goal for 2007 due to the barriers in lack of adequate staff required to implement this requirement.

Requirement 19A Health Care Worker Fatigue:

We agree this should be added as a goal in 2007.

Additional Goals/Comments: No additional goals or comments were identified.

 

Thank you again for the opportunity to participate in this review.

Sincerely,

Suzann VanBuskirk, BSN, RN, CNN

President

cc:   Board of Directors