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CMS and JCAHO Healthcare Security Requirements Summary

Every healthcare organization/hospital hospital, and who maintain custody and
accepting payment for Medicare and direct supervision of their prisoner are
Medicaid patients is required to meet not governed by §482.13(f)(l-3). The
certain Federal standards called individual may be the law enforcement
"Conditions of Participation" (CoPs). officer's prisoner but he/she is also the
These Federal requirements are hospital's patient. The hospital is still
promulgated by the Centers for Medicare responsible for providing safe and
and Medicaid to improve quality and appropriate care to their patient. The
protect the health and safety of condition of the patient must be
patients. Compliance is based on surveys continually assessed, monitored and
conducted by state agencies on behalf of reevaluate.
the CMS. Conditions of Participation are JCAHO - 2006
regulatory standards hospitals agree to (Healthcare Security)
follow as a condition for receiving ________________________________________
federal funding through the Medicare ___
program. The Joint Commission on Accreditation of
Under an agreement with CMS, State Healthcare Organizations evaluates and
healthcare licensure agencies conduct accredits more than 18,000 healthcare
surveys of hospitals and enforce organizations and programs throughout the
compliance with CoPs and ensure that United States. Hospitals aggressively
Conditions of Participation are being seek Joint Commission accreditation to
practiced. Hospitals and other healthcare meet Medicare certification and licensure
facilities are subject to random onsite requirements. Accreditation is also a
reviews. Unannounced surveys can result condition of reimbursement for many
from patient or public complaints or insurers and other payers. In addition,
inquiries. Healthcare Security is an JCAHO Accreditation reduces the
important element for the new 2006 hospital's liability insurance premiums.
Conditions of Participation. Beginning in 2006 JCAHO will conduct all
CONDITIONS of PARTICIPATION surveys without prior notice.
Department of Health & Human Services The Joint Commission has accredited
Centers for Medicare & Medicaid Services hospitals for more than 50 years and
(Healthcare Security) today accredits over 80 percent of the
________________________________________ nation's hospitals. The Centers for
___ Medicaid & Medicare Services (CMS) have
A-0038 required JCAHO accreditation by US
Title 42CFR, Volume 3 - §482.13 hospitals since 1965 as a 'Condition of
Condition of Participation: Patients' Participation' requirement in order for
Rights them to receive Medicaid and Medicare
A hospital must protect and promote each reimbursements.
patient's rights The Joint Commission and Healthcare
Interpretive Guidelines §482.13 Security
These requirements apply to all Medicare The Joint Commission's Standards address
or Medicaid participating hospitals the hospital's performance in specific
including short-term, acute care, areas, and specify requirements to insure
surgical, specialty, psychiatric, that patients are provided a safe and
rehabilitation, long-term, childrens' and secure environment. 2006 Environment of
cancer, whether or not they are Care© requirements include, but are
accredited. This rule does not apply to not limited to the following:
critical access hospitals. (See Social - Development and maintenance of a
Security Act (the Act) §1861(e)). written Security Management Plan to
These requirements, as well as the other include an Emergency Management Plan.
Conditions of Participation in 42 CFR - Conduct an annual Risk Assessment that
§482, apply to all parts and locations evaluates the potential adverse impact of
(outpatient services, provider-based the external environment on the security
entities, inpatient services) of the of patients, staff, and others coming to
Medicare participating hospital. the facility.
________________________________________ - Use the risks identified to select and
___ implement procedures and controls to
A-0057 achieve the lowest potential for adverse
Title 42, Volume 3 CFR - §482.13(c)(2) impact on security.
The patient has the right to receive care - Identify, as appropriate, patients,
in a safe setting. staff and other people entering the
Interpretive Guidelines for facility.
§482.13(c)(2) - Access Control / Physical Protection -
The intention of this requirement is to control access to and egress from
specify that each patient receives care security sensitive areas, as determined
in an environment that a reasonable by the organization.
person would consider to be safe. For - Mitigate Violence in the Emergency
example, hospital staff should follow Department and other locations.
current standards of practice for patient - Education and Training - staff,
environmental safety, infection control licensed practitioners, and volunteers
and security. The hospital must protect have the knowledge and skills necessary
vulnerable patients, including newborns to perform their responsibilities within
and children. Additionally, this standard the environment.
is intended to provide protection for the - Develop and implement a proactive
patient's emotional health and safety as infant abduction prevention plan.
well as his/her physical safety. Respect, - Include information on visitor/provider
dignity and comfort would be components identification as well as identification
of an emotionally safe environment. of potential abductors/abduction
Survey Procedures §482.13(c)(2) situations (during staff orientation and
- Review and analyze patient and staff in-service curriculum programs).
incident and accident reports to identify - Enhance parent education concerning
any incidents or patterns of incidents abduction risks and parent responsibility
concerning a safe environment. Expand for reducing risk and then assess the
your review if you suspect a problem with parents' level of understanding.
safe environment in the hospitals. - Attach secure identically numbered
- Review QAPI, safety, infection control bands to the baby (wrist and ankle
and security (or the committee that deals bands), mother, and father or significant
with security issues) committee minutes other immediately after birth.
and reports to determine if the hospital - Footprint the baby, take a color
is identifying problems, evaluating those photograph of the baby and record the
problems and taking steps to ensure a baby's physical examination within two
safe patient environment. hours of birth.
- Observe the environment where care and - Require staff to wear up-to-date,
treatment are provided. conspicuous, color photograph
- Observe and interview staff at units identification badges.
where infants and children are - Discontinue publication of birth
inpatients. Are appropriate security notices in local newspapers.
protections (such as alarms, arm banding - Consider options for controlling access
systems, etc.) in place? Are they to nursery/postpartum unit such as
functioning? swipe-card locks, keypad locks, entry
- Review policy and procedures on what point alarms or video surveillance (any
the facility does to curtail unwanted locking systems must comply with fire
visitors or contaminated materials. codes).
- Access the hospital's security efforts - Consider implementing an infant
to protect vulnerable patients including security tag or abduction alarm system.
newborns and children. Is the hospital Material in this brochure provided to
providing appropriate security to protect Accutech-ICS ( by Security Assessments
patients? Are appropriate security International, Inc.,
mechanisms in place and being followed to Disclaimer
protect patients? The information provided by and SAI is in
Exceptions: accordance with our understanding of
The use of handcuffs or other restrictive current JCAHO and CMS Regulations. It is
devices applied by law enforcement intended for educational purposes only
officials who are not employed by or and should not be considered 'legal'
contracted by the hospital is for advice. Please consult with your legal
custody, detention, and public safety counsel or Compliance Officer for
reasons, and is not involved in the clarification of laws and rules related
provision of health care. Therefore, the to your State when applicable.
use of restrictive devices applied by and and SAI are not affiliated with the Joint
monitored by law enforcement officers who Commission on Accreditation of Healthcare
are not employed or contracted by the Organizations.




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