Kyle Havens
BMET 44000
Prof. Rachel Meyer
10/5/2014
Assignment #2
CMS and the Controversial Preventative Maintenance Mandate

When I first opened up assignment #2, I noticed the topic was CMS and that was a good thing because I currently work for a medical delivery company that deals with the CMS on a daily basis. This research into their organization would allow me to understand them a little further than what I already know. CMS stand for the Centers for Medicare and Medicaid Services which covers a very large portion of the United States. It covers not only people, but organizations, businesses, etc. Through Medicare, Medicaid, the Children’s Health Insurance Program and the Health Insurance Marketplace, it covers approximately 100 million people! (CMS, 2014) The CMS is a federal agency that lies within the Department of Health and Human Services and their main focus is to administer the Medicare program as well as work with state agencies to administer the Medicaid and State Children’s Health Insurance Program. Considering the magnitude of what CMS covers, almost every healthcare facility in the country falls under the CMS wing if they accept Medicare or Medicaid as a payment for their services. Because of this, CMS has the “right” to pass any mandate o requirements as they see fit. Because the CMS is responsible for over 100 million people’s Medicare, Medicaid, etc. accounts, they can provide mandates and memos to various departments within healthcare organizations to follow a new order if they think it is necessary. CMS deems health care facilities qualified for such government reimbursement, so it’s in the best interest for departments inside healthcare facilities to follow their orders. In the case of the clinical engineering (CE) departments for healthcare facilities, one major mandate was brought to their attention which involved the PM process for medical equipment. They essentially wanted to have one set way of performing PM, so that everyone could be covered to the fullest extent. From my experience in a biomed shop, many of the preventative maintenance (PM) procedures on devices were sometimes unnecessary and carried out in a manner that wasn’t in line with the manufactures directions. This different way of completing the PM was both good and bad and ill explain that in further detail later in the report. Some devices didn’t need the rigorous manufactured PM schedule because some devices either worked or didn’t work. Some biomed shops agreed with their own PM schedules and other followed the manufactures PM schedule very thoroughly. CMS noticed this trend and decided to do something about it.
Because CMS noticed that some of the standard manufacturing PM schedules were not being followed, they issued a directive in December 2012 saying that a biomed shop is to follow the manufactures’ suggested preventative maintenance schedules. (Norville, 2012) That schedule from a manufacturer must be maintained “until a sufficient amount of maintenance history has been acquired to safely adjust the maintenance frequency below that recommended”. (Norville, 2012) Behind the update, CMS stated that, “Equipment that is critical to patient health and safety is not a candidate for an alternative less frequent maintenance activity schedule.” They also included an outline to what devices should be included and in paraphrasing their list it was life-support devices, critical monitoring devices, imaging equipment and anything in which if a device would fail it could result in a serious injury or death for either patients or staff. (Norville, 2012) Essentially, any piece of equipment that could directly affect a patient by injuring or killing them, must follow their specific manufactures orders on their respective PM. The Joint Commission (TJC), which is an organization that accredits and certifies more than 20,500 health care organizations and programs, (The Joint Commission, 2014) had a belief (prior to the mandate) that departments should be able to make their own decisions on PM for non-life support equipment based on their own internal workings. TJC’s stand on this belief contradicted with the CMS, but CMS eventually agreed to recognize TJC’s methods at TJC-accredited organizations. (Jesse & Hyman, 2012) This is where the December mandate came into play and created a standard for all CMS facilities to use the manufactures PM orders on all critical devices.
With the new mandate in place, many aspects of the clinical engineering side of the health care facility have changed. Those impacts can be felt in both the CE department in time management, which also affects the financials because time is money. With the mandates requiring manufacturer standard PM, the general overview is being replaced by a step by step process that will usually take much more time and effort than the “norm”. People often side with both views on PM in a hospital setting, one being for the new standard of manufactures based PM and others, the majority, are doing maintenance checks on the devices which can be considered an evidence-based approach. Most BMET’s considering following the exact manufactures guidelines as unnecessary work, which in the end has a big impact on workload. The people who agree with the manufacture based PM think of the mandate as job security because they believe a careful and thorough equipment maintenance schedule has become essential in keeping facilities in business. (Norville, 2012) For this new requirement, hospitals have to figure out where the CE department is behind and what areas need to be fixed in order to comply.
In a report that compares CMS PM Regulations, there is a section that explains research that was done in regards to PM frequencies and the different strategies of PM. The first
With this new requirement from the CMS coming down to CE departments, many of them needed a way to organize and figure out where they were behind at. To figure out how well a facility is doing with this new requirement, a self-assessment tool was provided to see exactly where a department stood. It was comprised of an exact rule, a column to score the department’s compliance level and then a column for the current practice if there was a compliance gap in their procedures. This tool helps a CE department come up to “code” with the new CMS mandate.
Since 2012 there have been updates to the mandate, usually in accordance with hardships faced by providers and suppliers. One change in detail was that of a categorical waiver that allowed the use of power strips in health care facilities. As long as the power strip is in compliance with the applicable 2012 LSC power strip requirements and all other 2000 LSC electrical system and equipment provisions, they are allowed in those areas. (CMS, 2014)

Overall, after my short experience working in the CE department for a small-medium sized hospital, I believe this mandate is both good a bad. With the growing fear of CE departments being shrunk due to dwindling budgets, these mandates give BMETs a chance for the necessity for their trade. Because of the impact CMS has on hospital finances, following their exact orders is essentially for a health care facilities financial standing. On the other hand, with these new requirements, it can take a lot of precious time out of a BMETs hands when it comes to interacting with the clinical staff out in the facility as well as completing work orders that come in on a daily basis. With these manufacture PM schedules that would be in place, a BMET would spend much more time in the shop away from the staff and outside world of the facility where it is beneficial to make and grow working relationships with the people who use the equipment they are working on. Everything has its ups and downs, but if there has to be a rule set in place for equipment we work on, it might as well be tied to the facilities finances to keep BMETs in a growing and lasting career. In regards to the CMS and their mandates, it’s kind of hard to understand their thinking and decisions when it comes to certain mandates that effect a wide range of people in the healthcare industry. I’m a person who likes to have facts and figures when choosing a side and in this case, I don’t. If they have done their research and believe their decisions are beneficial to those affected by it and simply not an un-researched way to cover the backsides of the people in charge, then I believe their decision makings can be justified.

is responsible for the money that comes into healthcare facilities