Integrate Immediate Jeopardy Criteria with your Management Process
If you are involved in the administration of a health care facility in the US, you are already familiar with Immediate Jeopardy. These instances of non-compliance which cause, or are likely to cause, harm to patients, are punishable with significant fines of up to $10,000 per day and/or per instance.
A recent article in McKnight’s made an excellent point that the criteria that are used to identify situations that trigger Immediate Jeopardy are also perfect criteria to use as a basis for managing the quality of care for your facility.
Joan Redden, vice president of regulatory and consumer affairs at Skilled Healthcare, said, “Using the triggers can help you figure out things out.” By looking at the baseline definition of quality care by reviewing the specific situations that would result in sanctions, day-to-day processes and procedures can be carefully aligned to ensure that expectations are being met.
An example is defining documentation procedures based on the requirements to defend an accusation of Immediate Jeopardy, especially in cases of alleged abuse or neglect. Clear documentation can clarify the level of care given and explain extenuating circumstances, but only if it is proactively completed in a way that meets all of the required criteria.
Facilities that define quality of care in a way that aligns with regulations and is supported by appropriate processes will face significantly less risk of noncompliance issues. This is definitely a case where planning ahead is far better than attempting to make retroactive adjustments.