November 29, 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, 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 Proposed Revisions to the Medical Staff Credentialing and Privileging. 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 ANNA Board of Directors. We are in support of the proposed changes to the existing standards. Based on the requested information from the Field Review, we are also in support of the following:
- The Performance Monitoring concept presented in standard 4.0.
- Not changing the performance monitoring for practitioners that complete their residency at the same organization where they are seeking privileges.
- The concepts are clear as presented in Maintaining Privileges (standards 7.0 and 8.0).
We did not identify any alternative process to Performance Monitoring that would demonstrate practitioner competence and support patient safety and high quality care or concerns related to resources required to meet the requirements. We also did not identify an alternative process to Continuous Professional Practice Evaluation that would demonstrate practitioner competence and support patient safety and high quality care. The proposed standards track well to the ACGME/ABMS six general competencies and the overview and introductions clearly explain the purpose and content of the standards. Our additional comment is related to line 114 as it does not include designated equivalent sources for mid-level practitioners.
Thank you again for the opportunity to participate in this review.
Suzann VanBuskirk, BSN, RN, CNN
cc: Board of Directors