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Archive for the ‘OSHA’ Category

You Won’t Believe This One! (Yes this is a true story) In an outpatient-therapy center that will remain nameless, I was working with a physical therapy manager who was waxing eloquently about how clean he kept his center (this was my first clue that in the words of Miss Clavell – from Madeline fame – “something was just not right”). We were standing in his main gym area where I observed a generally acceptable center. Until…I happened to look over his shoulder and noticed a bright pink fly swatter hanging on the hydrocollator pad drying rack. Intrigued by what new clinical outcomes fly swatters where producing in the latest professional and peer-reviewed journals, I just had to ask why they had a fly swatter hanging in such a conspicuous and unconventional place. Neither the manager, the PT, the tech, nor the scheduling secretary had any idea as to why the lovely wire handled – pink plastic weapon of fly death was hanging on the rack (with pads brushing against it). Now you may ask of this potential safety issue, “how could something like this happen?”

My last blog, “Rehab Agency Certification: Comply or Not Comply 4/28/10,” provided an overall review of the Medicare compliance program for OPT/Rehab Agencies. So what if you are not Medicare certified, why should you have a safety program in your outpatient-therapy center?

In my professional career I have worked with hundreds of outpatient-therapy centers preparing for, and responding to, various levels of on-site audits, surveys and reviews. I’ve heard the arguments time and time again that outpatient-therapy centers are so low risk in terms of hazardous work places, why should they take time to do the “stuff that hospitals have to do?”

Why bother with policies, procedures, safety checks or chart reviews? Well for one it’s the right thing to do. Second, many managed care payors are requiring on-site reviews as part of their own credentialing process to keep providers in their networks. Moreover, as an employer you have a duty to comply with the OSHA. OSHA has even noted the outpatient-therapy work environment on its website and provides excellent reminders of what you may face in your center.

Understandably, independent physical, occupational and speech therapy practitioners wear many hats in their practices therefore the last thing you think about is performing many of the mundane tasks. Your day is typically focused on scheduling, caring for your patients and driving revenue through your center.

Those “last” things need to be some of the first things you do. If not, the time will come when you will regret not taking a few minutes to do that safety check. Whether or not your clinical practice is Medicare certified, it really doesn’t matter. I have seen many therapy practices (large and small) that haven’t performed a fire drill in years!

You as a practice owner or center manager, you have the responsibility to provide for the safety of your patients, but also you and your employees. The APTA provides a great outline of what you need to have in place from an administrative standpoint to ensure safe clinical operations.

Here are some other practical tips you can use:

1. Start by taking a safety inventory of your center. Ask a friend to be “new eyes” and look for things you may miss in your normal day (like the pink fly swatter). You don’t need a prescribed form yet, just do a “walk thru” and look for the obvious. Start in the parking lot and work your way through the center to the back door. It’s amazing what you will see – blocked exits, improper lifting techniques by your other therapists (yes, they get in a hurry and forget too!), and clean towels touching the floor just to name a few. Make sure to keep a list of everything you find.

2. Now categorize your findings and address the obvious: You don’t need a committee to move boxes from the hallway and from in front of the emergency exits. Take care of the things you can control and do it today. Don’t wait.

3. Some things may have to be corrected by trained professionals. Lighted exit signs that don’t work, installing panic bars on your emergency egress, and other big jobs that need to be scheduled and budgeted. Don’t put these off. Develop a plan and execute it.

4. Meet with your staff regardless of size. Inform them to always ask “why” something is where it is or isn’t. Never take an expiration date, frayed wire or laundry procedure for granted. If it can be done better, well it probably can.

5. Last, schedule monthly safety inspections. Feel free to use my complimentary healthcare facility inspection checklist. It is a basic overview of what you’ll need to look for each and every month. Don’t be afraid to mark something as being out of compliance, but just remember to address it and act on it! Keep it in a binder or file for documentation purposes.

Good luck as you continue to work to be the best center you can be. And stay on the lookout for those pink fly swatters!

Jeff has participated in more than 2,000 Medicare surveys and has more than 20 years experience consulting with organizations to develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare. Jeff is also a certified deemed status surveyor with the AAAASF/RA” Division.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC. Phone: 205-612-1750 or email jdance@keysyshealth.com .

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