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October 07, 2008

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:

Per DNV's press release,

NIAHO [i.e., DNV's National Integrated Accreditation for Healthcare Organizations] encourages innovation within individual hospitals while helping them take advantage of system-wide best practices. It is the first hospital accreditation program in the United States that integrates the internationally recognized ISO 9001 Quality Management System with the Medicare Conditions of Participation, making it the first and only hospital accreditation program that requires continual quality improvement. 

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


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Yesterday I had the opportunity to chat with several members of the executive leadership team from DNV Healthcare, the "new kid on the block" for hospital accreditation. DNV was recently granted deeming authority by CMS -- the first time the... [Read More]


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Mr. Harlow:

Please permit me to clarify a few issues for your readers:

1. Hospitals currently accredited to our NIAHO program are not reporting any problems in having insurance companies, managed care companies or other organizations recognizing accreditation by DNVHC. The key to the organizations contracting with the hospital would be that the hospital is accredited by a national accreditation organization approved by CMS which we are.

2. Hospital transition to ISO 9001- our standards require hospitals to be ISO-compliant within two years of their first accreditation effective date. Most of our hospitals are meeting this goal well ahead of schedule usually within 6-8 months with minimal cost and little or no use of outside consultants. Hospital staff DO NOT need to be ISO certified.

Our NIAHO program is transparent and involves a collaborative, non-confrontational survey process.

Interested organizations are invited to visit our web site at and download our standards and process.

Darrel --

Thank you for weighing in.

1. My point regarding contracts is not that payors would not recognize DNV's accreditation, but that some contracts are written to incorporate by reference specific JC standards. In the absence of JC accreditation, those standards are potentially irrelevant, and the references to them in other documents will need to be cleaned up.

2. Thanks for the clarification re: hospital staff not needing to be ISO certified. My misunderstanding re ISO, based on some materials I've seen out there.

Many folks will be interested in reviewing the accreditation standards and other info. Thanks for the link.

October 28, 2008

HealthBlawg readers should know that an October 7 post about accreditation was wrong in a number of important respects about The Joint Commission. Specifically:

• Joint Commission accreditation surveys are unannounced -- that means no advance notice. These evaluations take place every 18-39 months. One of the main reasons for the 2006 switch to unannounced surveys was to encourage organizations to use Joint Commission standards to constantly improve patient care rather than just prepare for a survey.
• All Joint Commission-accredited organizations must comply with the Sentinel Event Policy that requires a thorough analysis of each sentinel event and action to prevent similar events in the future.
• Information about Joint Commission-accredited organizations is available free and online at or (see Quality Check).
• Organizations pay for an accreditation survey, but not the outcome. This is true for all accrediting bodies, not just The Joint Commission.
• The Joint Commission does not offer consulting services; its not-for-profit affiliate Joint Commission Resources does. A 2006 General Accounting Office report found that both organizations have taken steps to prevent the improper sharing of accreditation and consulting information with each other.

Cathy Barry-Ipema
The Joint Commission

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