By Binseng Wang, ScD, CCE, fAIMBE, fACCE
If the word “mock” is typically not well received by most people, mock surveyors (MS) are probably perceived even worse by the clinical engineering (CE) professionals and accreditation organization officials who deal with them. While the substandard performance of some MS justifies this unfavorable reputation, it would be a mistake to dismiss mock surveys altogether.
Please allow me to share my perspective: For more than 10 years, I’ve had the “privilege” of dealing with an average of three real surveys per week, as well as countless mock surveys; plus, I’ve performed dozens of mock surveys that have helped my former colleagues avoid requests for improvement (RFIs).
The Rationale Behind Mock Surveys
First, let us look from the MS perspective. As consultants, their primary goal is to retain business—that is, justify their usefulness in order to be invited back in the future. This reasoning has often lead many MS to be excessively strict—focusing so heavily on the nitty-gritty details that they end up missing the big picture.
By finding numerous “violations,” they try to prove to the organization’s leaders that there are indeed many problems that need to be fixed, thus proving their value. In my opinion, this is similar to the excessive maintenance recommendations some equipment manufacturers have made. These recommendations help to reduce their liability exposure—and sometimes increase their revenue—at the expense of the organization.
Still, if the organization were to implement all of the MS recommendations—justifiable or not—it is very unlikely that the real surveyors will find any problems.
Nevertheless, some MS also don’t have the expertise to cover all the different subject matters. Even when an “expert” in the environment of care is retained, he or she may be very knowledgeable in facilities and life-safety code but not necessarily up-to-date with medical equipment maintenance and management.
This isn’t the MS’s fault, however, but rather the fault of organizational leaders who are unaware of the intricate differences and/or want to avoid hiring multiple MS for different subject matters in an effort to save money.
Now, let’s consider the perspectives of CE leaders. Wouldn’t you like to have someone who can help you identify issues that you have overlooked, find the respective root causes, and suggest cost-effective solutions before the real surveyors show up? Often, we are so used to the “little” problems that have been around for a long time that we forget they even exist.
However, a fresh set of eyes will pick them out easily. An analogy is when you want sell a house, you hire a good real-estate agent who can tell you what needs to be done before putting your property on the market. That way, you can sell it quickly and get what it is worth.
Characteristics of a Good MS
So what makes a MS a good “listing agent?”
First and foremost, the MS needs to be knowledgeable about current laws, regulations, codes, and accreditation standards—preferably with prior CE working experience. After all, with so many changes happening since at least 2011, it is difficult for CE leaders to stay up to date.
Almost as important is the MS’s ability to interpret and correctly apply these rules. Unfortunately, lawyers or bureaucrats with little—if any—healthcare experience write most of the rules, often making them difficult to understand or implement.
A good MS should be able to justify every violation, citing the applicable rule and, more importantly, how to correct the problem and prevent future reoccurrences. This requires an in-depth analysis of the violation to identify the root cause(s) so appropriate corrective and preventive actions can be taken. Unfortunately, few MS’ perform this analysis because it requires expertise and, more importantly, takes time away from other mock surveys, which generate revenue.
Since the cardinal rule of ensuring good survey results is “NOT to invite surveyors to your domain,” a good MS will help you achieve it by doing these two things:
- Searching equipment-intensive areas for devices with missing incoming inspection or schedule maintenance (SM) labels. This includes looking into equipment storage areas and cabinets where clinicians have a tendency of hiding devices for urgent needs. Don’t think that just because The Joint Commission (TJC) eliminated the requirement for EC rounds—formerly EC.04.01.01-EP12[i], you should stop making them.
- Conducting candid interviews with key clinical department leaders (e.g., leaders from imaging, laboratory, surgical services, the ICU, etc.).
If these leaders make bad comments about your team to real surveyors, the latter are more likely to come down to the basement to have a “friendly” conversation with you and your staff. Remember: No perfect CE program exists. If a surveyor starts to scrutinize every detail, he or she will certainly find something and you’ll get an RFI, especially now that TJC is on the “see it, cite it”[ii] mode. But a good MS should help you eliminate small problems visible to the real surveyors.
Finally, the MS should review your medical equipment management plan (MEMP), as well as associated policies, procedures, and work instructions. Remember: If your first two lines of defense failed to keep the true surveyors away, make sure that your MEMP and other documents fully comply with current regulations, codes, and accreditation standards.
Even if they are up-to-date, they often do not reflect the actual practice. For this reason, you should periodically train and update your staff on MEMP revisions, as well as associated documents. For example, too many BMETs still believe that one can use the risk-based criteria to exclude equipment from inventory and exempt low-risk devices from SM without additional justification.
So, what can you do? First and foremost, don’t sit around and complain that your superiors picked the wrong MS. Instead, ask your peers to help you find a good MS based on their experiences and then interview him or her.
Get the resumes of your favorite prospective MS’ and then submit them to your superiors with your recommendations. Such actions increase your likelihood of being surveyed by a good, qualified MS.
By recommending MS’ to your superiors, you also show them that you are not only confident in your own program but also receptive to constructive criticisms. Arguing against mock surveys may be perceived as a sign of lack of confidence and unwillingness to learn and improve.
When the MS shows up, treat him or her respectfully and hospitably—just like you would treat a real surveyor. Do not volunteer information unnecessarily, but ask questions if you’re unsure what the MS wants or why he or she is insistent on a particular issue. Be ready to learn and see things from a different perspective.
As Galileo Galilei once said, “I have never met a man so ignorant that I couldn’t learn something from him.” You could be pleasantly surprised!
If you or your superiors are truly against the use of a MS, you may want to work with your peers to create a cross-audit program in which each CE leader acts as a MS for another and vice-versa. Such a process is used by companies registered with quality management standards (e.g., ISO 9001[iii] and ISO 13485[iv]) in which cross-functional audit is mandatory. Fortunately, large healthcare systems with multiple CE teams can easily organize cross audits.
If you’re in a smaller organization, however, you may want to discuss the possibility of creating such a program with your colleagues from your state or regional biomedical association—including hiring a good MS to train you and your peers to perform such audits.
But be aware that cross audits sometimes are not as good as using a truly independent MS, as some CE professionals may hesitate to point fingers while others may have an axe to grind.
And if you’re still not convinced that mock surveys can be useful or believe no MS could find any deficiencies in your program, please contact me and I will prove my point by performing one at your facility. You just have to promise to never post my picture or name at the post office!
- [i] 2017 Comprehensive Accreditation Manual for Hospitals (CAMH). Joint Commission Resources, Oak Brook IL
- [ii] Mills, G. The Joint Commission Update. ACCE webinar, Feb 10, 2017
- [iii] ISO 9001:2015 – Quality management systems – Requirements, International Organization for Standardization, Geneva. Available at https://www.iso.org/standard/62085.html
- [iv] ISO 13485:2016 – Medical devices — Quality management systems — Requirements for regulatory purposes, International Organization for Standardization, Geneva. Available at https://www.iso.org/standard/59752.html
Binseng Wang, ScD, CCE, fAIMBE, fACCE, is director, quality and regulatory affairs with WRP32 Management, Inc. The views expressed in this article are solely those of the author. For more information, contact chief editor Keri Forsythe-Stephens at firstname.lastname@example.org.