Regulatory fatigue

Last week, I was a visiting professor in the Department of Anesthesiology at Vanderbilt University. I must admit that I had some trepidation regarding spending a few days with anesthesiologists. I'm an internist, and like most internists, we stay clear of the OR. However, it turned out to be a great visit. I met with very creative, highly engaged physicians and scientists with whom I share a basic desire to improve the quality and safety of health care. We spoke the same language.

During a lively dinner conversation, the topic turned to The Joint Commission. And I learned that one of the dinner guests had just published a paper in Anesthesia and Analgesia on the The Joint Commission and regulatory fatigue. The paper focuses on accreditation "standards" that lack supporting evidence (some of which may actually lead to patient harm), and the cover art from the issue illustrates in a farcical way what most of us know all too well.

The authors and the journal should be commended, as it's rare to see individuals or organizations take on the almighty Joint Commission. In a previous job I was asked not to point out blatantly inaccurate statements about infection control made by on-site JC surveyors. Those of you who know me would probably guess that I did it anyway.

It's unfortunate that we are forced to play a cat and mouse game where the rules are never really articulated but violation of these invisible rules results in the infliction of great pain. There is an alternative to TJC, and 500 US hospitals are now being accredited by DNV. While I have no personal experience with DNV, I have discussed the DNV accreditation process with several individuals at hospitals using DNV. All were exuberant in their praise for the organization and its processes, which focus in a collaborative way on helping hospitals improve performance. The DNV website states that on-site surveys are "more of a routine check up on your success, not an epic investigation of your faults." Wow! What's not to like about that?


  1. Thanks for the post Mike.
    What was the conversation on topics such as hand hygiene requirements for anesthesia providers or OR disinfection between cases?

  2. Hi Silvia!
    They're interested and on it. Also talked about contamination of the anesthesia work space.


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