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ASHP had devloped a draft of proposals to Joint Commission.
The Emergency Nurses Association (ENA), American College of Emergency Physicians (ACEP), and American Academy of Emergency Medicine (AAEM) believe that the interim action standards were feasible to implement in the ED because the impact on patients in the ED would be minimal and a retrospective review would require minimal staff additions. These associations wrote letters to the Joint Commission urging that the interim standards be reinstated immediately and be maintained until a full review of the current standard is completed and any required changes are finalized.
Their rationale is based on the following:
In the draft proposals, ASHP "strongly supports" that prospective medication order review by pharmacists is a key component of safe and effective medication use and the best method to ensure that ED patients receive the same level of care as other hospitalized patients. However, for urgent situations in which the resulting delay would harm the patient, ASHP recognizes that a prospective review would not have to be conducted.
ASHP supports allowing hospitals to design an individualized data collection and quality plan as well as eliminating the "within 48 hours" deadline for retrospective review of ED orders. Additionally, in the draft of proposals, ASHP provides examples of alternative strategies that achieve safe and effective medication use, such as electronic clinical decision support and standardization of drug concentrations.
"ASHP supports prospective medication reviews by pharmacists. However, we recognize that every hospital does not have an emergency department pharmacist. These are alternatives for organizations that do not have the resources, but they can also be utilized by pharmacists as supplemental sources," stated Benjamin.
In June, the Joint Commission issued an urgent bulletin notifying hospitals that, until an interdisciplinary task force proposes revisions that will then be field-reviewed, liberal interpretations of MM 4.10 would apply during the survey process. ASHP stated in the draft proposals that Joint Commission surveyors should proactively offer assistance to organizations attempting to meet the challenges of complying with MM 4.10 in their EDs. Surveyors should focus on measurable outcomes that are supported by data rather than the letter of the standard. According to Benjamin, ASHP will continue to work proactively with the Joint Commission and its partners in nursing, medicine, and other professions to develop quality standards that prevent patient harm and improve medication therapy outcomes.
THE AUTHOR is a writer based in New Jersey.