DNV: New kid on the (deeming) bløck

The organization formerly known as JCAHO finally has a little competition, after a 30-year-plus lock on the deeming business.  While the Joint Commission has changed with the times (looking more at process, not just at outcomes), its hospital survey process — which is recognized by CMS so that passing a JC survey means that a hospital is "deemed" to be in compliance with Medicare Conditions of Participation (aka Medicare certified) and can forego a government survey — has been the only game in town.  (Only about 5% of hospitals ever face a "validation" survey with government surveyors.)  The JC accreditation system has come under criticism on a number of fronts (I'm just framing the criticisms, not endorsing them):

• Surveys only take place every three years, resulting in a rush to come into compliance before survey time, with less attention paid to standards in the years in between

• Even surprise visits come with advance notice

• Survey reports are not made public

• Sentinel event reporting is recommended, rather than required

• JC surveys are paid for directly by the surveyed hospitals

• JC sells consulting services to hospitals to help them prepare for surveys

A while back, CMS formally opened up the deeming process, so that the Joint Commission (and the American Osteopathic Association, the other deeming authority out there) had to reapply, and the application process was open to others as well.  The new kid on the block is the US health care division of a Norwegian company, DNV — Det Norske Veritas Healthcare, Inc.  The CMS approval of the DNV accreditation program was issued September 26 and published on September 29.  It's good for four years.

A couple dozen US hospitals hold dual certification (JC and DNV), and it will be very interesting to see how many hospitals move to DNV accreditation in the future.  Some of the advantages touted by DNV:

• Annual surveys, promoting continuous quality improvement

• Surveyors cross-trained as ISO 9001 lead auditors, promoting a more collaborative relationship with hospital staff (see ISO website and an interesting "plain English" take on ISO 9001.) 

Per DNV's press release,

A few other observations: Other coverage notes that a shift to DNV from JC will require a comprehensive revierw of policies and procedures and contracts that may incorporate references to JC or its standards. One early adopter quoted in the DNV press release noted that the shift of emphasis in the accreditation process eased her institution's transition to an EHR system.  In order to be certified under ISO 9001, not only surveyors need to be ISO certified — hospital staff need to be certified as well. 

Bottom line, it seems like this may be a disruptive innovation that could help hospitals in the long run — particularly those that have been itching to opt out of the JC monopoly for years — but may have some not-insignificant transition costs.  In addition, the greater transparency sought by some critics of the JC monopoly is not guaranteed simply by opening up the process to another player.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting