Response to comments from Dennis Ernst of the Center for Phlebotomy Education

Recently Dark Daily alerted clinical laboratory readers to a decision by The Joint Commission to change their requirements for patient identification. Included was the opinion of Dennis Ernst,  MT(ASCP), long time Director of the Center for Phlebotomy Education, that The Joint Commission’s decision to change patient identification requirements was a step backwards in patient safety. (See Dark Daily, “Joint Commission Changes Requirement for Patient ID during Blood Draws” ).

In particular, Ernst was troubled that the new patient identification protocols no longer require a healthcare worker to have the patient state his or her name before blood is drawn. He contacted The Joint Commission to inquire about this change. He related to Dark Daily that officials at TJC had informed him that, in their surveys of clients, there was a feeling that this specific requirement was “burdensome and unnecessary.”

Denis Ernst

Denis Ernst

In response to publication of Ernst’s comments in that Dark Daily e-briefing, we received a letter on the matter from The Joint Commission. That letter can be viewed here. That spurred us to contact The Joint Commission to get further comment on how and why these changes were made to the requirements for patient identification.

“First of all, we certainly support the Center for Phlebotomy Education’s position that active patient involvement is the best practice when collecting a specimen,” stated Megan Sawchuk, Associate Director in Standards Interpretation at of the Joint Commission. “It is good practice to ask a patient to state his or her name in an active way.”

“And The Joint Commission does not think asking a patient for their name is ‘burdensome and unnecessary’,” she continued. “It was actually the second part of the requirement that was difficult for our accredited organizations to implement. Specifically, a healthcare worker collecting a specimen or administering medications was required to get another individual to identify the patient when the patient was unable to respond or identify themselves. This step was in addition to confirming two identifiers on the patient’s armband or using a barcode system.”

“This situation can happen frequently in a hospital setting,” she explained. “It was this added identification requirement that caused concerns among our accredited organizations and generated comments that—not only would this step prove ‘burdensome and unnecessary’ in practice—but that a healthcare organization can find itself open to error if its healthcare worker is dependent on a third party to confirm the identify of the patient from whom a specimen is about to be collected.”

Sawchuk stated that The Joint Commission’s decision to drop EP 1—the title of the rule outlining patient identification requirements—was an effort to cut down on the subjectivity of the identification process in situations where patients are not fully coherent.

“Further, each standard issued by The Joint Commission must be objective and concrete,” she continued. “As an example, it is less than ideal to write a requirement that says, ‘Use active patient involvement when possible.’ The term ‘when possible’ is vague, which makes it difficult to enforce on survey. Because the organization determines their own policies about what is considered ‘when possible’, it can become very subjective.”

Sawchuk does not think this particular change to patient identification rules will have a detrimental effect on patient safety. “It is my opinion that EP 1, as it was written, didn’t add anything beyond what organizations already do today with proactive communication,” she commented. “If anything, the change in the goal may actually serve to encourage more dialog about how to improve active patient communication.”

Sawchuk added that the feedback from Ernst and his group was appreciated by The Joint Commission and further input would be welcome. “The Joint Commission values the Center’s input and we would welcome their participation in strengthening the requirements for patient identification when specimens are collected,” noted Sawchuk. “We like to work collaboratively with organizations affected by changes to our standards. Working together helps insure we come up with the best possible solutions for patients along with reasonable expectations for our organizations.”

Related Information:

The Joint Commission’s New Patient Identification Requirements Positive Patient ID: Bar Coding Success at the Bedside

Phlebotomist Rewarded For Proactive Patient Communication