Change to BH Health Screening Requirements Effective January 2012

Does your organization operate a non-24 hour program surveyed under the Joint Commission's Behavioral Health standards? If so, there are some important new requirements for the health screening process that go into effect January 1, 2012. These new requirements will most likely require changes to your existing process for conducting health screenings in your non-24 hour settings. The following is a summary of the 2012 requirements with notes regarding changes from the 2011 standards:

2012 Care, Treatment, and Services Chapter

CTS.02.01.05: "The organization implements a written process requiring a physical health screening to determine the individual's need for a medical history and physical examination."

Change from 2011? Minor wording change; intent the same.

EP 1 requires a written physical health screening process to determine the need for a history and physical (H&P). The health screening process must include, at a minimum:

Change from 2011? The requirements are essentially the same as 2011 but the terminology "screening triggers that indicate the need for a medical history and physical examination" is new and a bit more specific. It replaces the previous wording "decision criteria for determining the need for a physical examination."

EP 2 requires that a qualified practitioner be involved in indentifying the data to be collected and developing the health screening process.

Change from 2011? The requirement is similar but the 2012 wording of "practitioner qualified by the scope of his or her license" broadens the type of professional who can be involved in developing the health screening. The 2011 wording was "a qualified licensed independent practitioner" which was a narrower definition.

EP 3 (NEW) requires the organization to determine whether the date of the individual's most recent physical exam exceeds one year. If the date exceeds one year, an H&P is to be performed.

Change from 2011? Yes. This is a new requirement not included in the previous standard. It essentially requires the organization to take the following three steps:

• Include as one of the screening triggers for your health screening "individual's most recent physical exam exceeds one year."
• Determine the date of each individual's last physical exam when conducting the health screening.
• If the date of the last physical exam exceeds one year, "a medical history and physical examination is performed."

There are two important points that are included with this element of performance:

1. Securing the individual's agreement to obtain a physical exam may be undertaken as a "process" and may be incorporated into the treatment plan.
2. If performing a physical exam is not within the organization's scope of service, it may refer the individual to another organization.

In addition, the following points were clarified by TJC at the BH Conference this month:

• This standard does not apply to organizations that provide physical exams to all clients based on their own policy and/or applicable law and regulation. (Essentially, performing a physical exam supersedes the requirement for conducting a health screening.)
• A medical professional does not need to review the health screening. The determination of whether the individual needs to have an H&P can be made based on the screening triggers that have been established.
• If the individual refuses to have a physical exam done (despite the recommendation of the organization), this should be documented in the record.

We recommend that, as part of your continuous readiness program, you review these new requirements and determine if you need to make changes to your existing process for conducting health screenings in your non-24 hour settings. Compliance with these new requirements is sure to be high on the radar screen for surveys coming up in 2012!