Federal Healthcare Regulations and … Oil Changes

A Parable of Recommendations and Decisions

So, how often do you really change the oil in your car, truck, or SUV?  Do you follow manufacturers’ recommendations?

You know, the last three cars I owned had completely different advice: one owner’s manual said every 6,000 miles, one said every 7,500 miles, and one has a snazzy computer that analyzes how I drive and tells me when an oil change is due.  Those are car manufacturers’ recommendations, right?  But wait!  Do you heed the oil manufacturers’ advice to change every 3,000 miles?  Or, do you follow your daddy’s advice and change every so-and-so miles?  Do you replace the oil filter every time (some recommendations) or every other time (other recommendations)?  One repair shop told me that not replacing the oil filter every time was like taking a shower without taking off your socks … But, I was always told the filter should be on an every-other oil change cycle.

Now, MIPRO is in the computerized maintenance management business.  We are the North American experts on implementing, tuning, upgrading, and optimizing PeopleSoft Asset Lifecycle Management (ALM) systems, especially PeopleSoft Maintenance Management.  You might think, “…If it’s computerized, it should be easy to follow proper procedures, right?”

Related: How to choose good knee walker?

Oh, if only life were that easy.  Those of you in the healthcare business know that Daddy Warbucks and the IRS (those who giveth and those who taketh away) are really the same organization: CMS (Centers for Medicare and Medicaid Services), within HHS (Department of Health & Human Services), the most important federal agency in your financial life.  If you don’t follow CMS regulations, you risk being adjudged non-compliant, potentially fail your Joint Commission accreditation check, and might not receive reimbursement. (What proportion of your revenues comes from CMS?  40%, 50%, more?)

So, what does CMS say about maintenance?

In December 2011, CMS’ Office of Clinical Standards and Quality/Survey & Certification Group issued new regulations that said healthcare providers must follow manufacturers’ advice:

“…alternative equipment maintenance schedules {are} permitted in some instances….” but “…alternative equipment maintenance methods are not permitted….”

Hmmm, some instances. What might those be?

CMS “clarified” what some instances meant by stating:

frequencies may be adjusted based on assessment by qualified personnel unless 1) the equipment was “…critical to patient health & safety….” or 2) the equipment was “new” and a sufficient amount of maintenance history hadn’t yet been acquired.

When I’m drivin’ down the freeway, I think that darn near every part of that car is critical to my health and safety.

But, you’re the maintenance supervisor in a modern hospital.  Or, of course, you’re the Administrator, where the buck truly stops.  Tell me, what equipment is critical to patient health and safety?  That’s an exact quote from the Feds.  Because, you had better be following the manufacturers’ maintenance procedures and frequency for these pieces of equipment.  Are there either procedure or frequency conflicts for virtually identical pieces of equipment?  Do you follow the maintenance recommendations and change your oil every 3,000, 6,000, 7,500 miles or listen to Dad’s advice or confidently (blindly?) follow the magic maintenance computer?

This is serious stuff in the healthcare business.  Non-compliance can be fiscally fatal.  And, if your accreditation is “delayed” or your reimbursements are “denied” or “reduced”, you may have serious problems.

Negotiations between CMS and national hospital providers are under way to define a bit more closely “critical to patient health & safety” and whether local procedures that exceed manufacturers’ methods are acceptable (and, of course, the corollary discussion of alternative methods that are superior to manufacturers’ methods; currently, these are not allowed).  Organizations such as The Joint Commission (TJC), the American Society for Healthcare Engineering (ASHE), and the Association for the Advancement of Medical Instrumentation (AAMI) are among the interested parties participating in the negotiations, not to mention regional and local providers who have just as much skin in the game.

Where’s MIPRO in all this?  Well, we are the best at implementing PeopleSoft maintenance management systems once the regulators tell our clients what procedures we need to implement.  Right now, what appears to be the safe method is to implement a superset of procedures/frequencies:  at least the manufacturers’ recommendations and your maintenance experience and the most comprehensive/frequent procedures where there are conflicts.

Stay tuned for future blog posts as these critical negotiations continue.  But, don’t expect quick resolution.  Remember the lesson of elephant reproduction:  it’s done at a high level, it’s accompanied by much noise and posturing, and it takes two years for anything to develop.

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