April 24, 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 Proposed Changes to the Leadership Chapter. 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. Our focus was on the ambulatory and hospital requirements and we support the following:
- Standard LD.1.20 states that governance has ultimate responsibility for the safety and quality of care, treatment, and services. We believe none of the standards undermine the role of the governing body within: 2.10 (mission, vision, and goals); 2.20 (conflict resolution); 2.40 (decision-making); or 2.50 (accountability).
- We believe organizations will be able to comply with the proposed leadership standards in the next 12 months with no barriers identified.
- Standard LD.3.60, EP 1 requires leaders to evaluate their organization's culture using valid and reliable tools. Many organizations identified that they currently evaluate their culture of safety and quality through multiple methods including data review, focus groups, formal survey, and informal staff feedback with most being completed at least annually.
- Additional comments included:
- Technology issues/technology support may be a concern for the small facilities as well as large facilities with many departments using different reporting systems.
- Pleased with requiring staff input into operating and capital equipment budgeting process.
- Standards are reasonable and are being done by many facilities, at least on an informal basis.
- Believe these standards ensure the Governing Body takes responsibility for oversight of the institution.
Thank you again for the opportunity to participate in this review.
JoAnne Gilmore, BSN, RN, CNN
cc: ANNA Board of Directors
Mike Cunnigham, Executive Director