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  • Introduced by: Vemuri S. Murthy, MD, Delegate, for Chicago Medical Society

    Subject: Engage and Collaborate with the Joint Commission

    Referred to: Reference Committee C

    Whereas, the Joint Commission's mission is stated "to continuously improve health care for the public in collaboration with other stakeholders, by evaluating health care organizations and inspiring them to excel in providing safe and effective care of the highest quality and value;" and 

    Whereas, this mission requires evidence based medicine, peer review, and physician oversight in an open, collegial environment; and

    Whereas, the Joint Commission does not vet their standards in an open collaborative environment and only three of their 13 officers are physicians; and

    Whereas, the Joint Commission has a near monopoly on accreditation in the United States; and  

    Whereas, the on-site survey process usually involves only one or two physician surveyors who therefore may not necessarily be board certified or experienced in the area they are physically reviewing, thus contradicting the accepted practice of "peer review" (which is the basis of Quality Assurance); and

    Whereas, the Joint Commission is significantly responsible for promulgation and acceleration of the current opioid epidemic by emphasizing and prioritizing inappropriate pain management (including chronic non-cancer pain) guidelines over the root causes of pain in its 2000 standards while ignoring over-medication and never has taken steps to address an epidemic that has progressed for more than 18 years; and 

    Whereas, this paradigm shift transformed pain management into a patients’ rights issue leading to substantially increased opioid use; and 

    Whereas, as a result of the pain standards, pain management became a regulatory issue replacing physicians' clinical judgment; and

    Whereas, Purdue Pharma (the manufacturer of OxyContin) provided funding for the Joint Commission’s pain management educational programs during the time that these standards were developed; and

    Whereas, as a result of these pain standards, narcotics were indirectly encouraged to comply with the guidelines in order to  treat chronic, non-cancer pain in which there was little evidence or validation to support its long-term use; and

    Whereas, organizations seeking accreditation had little option except to comply with these standards; and 

    Whereas, the Joint Commission's accreditation subscription and on-site survey fees revenue was over $160 million, in 2016, which is primarily obtained from medical institutions; and

    Whereas, the proliferation of accreditation, certification, and standards compliance provisions contribute to the financial drain of precious healthcare resources; and 

    Whereas, this cost and its collateral effects (probably in the six figures for most institutions) is fully exorbitant, unnecessarily expensive, and can be better directed for clinical patient care; and

    Whereas, a very recent Cochrane Review concluded that there is a "paucity of high-quality controlled evaluations of the effectiveness and the cost-effectiveness of external inspection systems"; and 

    Whereas, another systematic review came to a similar conclusion stating that their "review did not find evidence to support accreditation and certification of hospitals being linked to measureable changes in quality of care"; and 

    Whereas, in a survey of 299 rural administrators of non-Joint Commission accredited hospitals, 70% of the respondents did not think that the perceived benefits of accreditation were worth its cost or worth the demands on the staff’s time; and 

    Whereas, a recent systematic literature review concluded that "several studies have shown that health care professionals were skeptical about accreditation because of concerns about its impact on the quality of health care services"; and 

    Whereas, the end result of these regulations (which are management centered and not patient driven) is a morass of unintended consequences through heavy handed regulation; and

    Whereas, Joint Commission accreditation practices are redundant when combined with local/state Board of Health guidelines, College of American Pathologists accreditation programs, etc.; and 

    Whereas, the above practices of the Joint Commission have resulted in a high level of dissatisfaction among local physicians; and 

    Whereas, on November 7, 2017, the Chicago Medical Society declared its support for engagement and collaboration with the Joint Commission’s Board and Leadership to provide and survey appropriate medical standards, as per its mission statement; therefore, be it  

    RESOLVED, that the Illinois State Medical Society (ISMS) engage and collaborate with the Joint Commission’s Board and Leadership to provide and survey appropriate medical standards, as per its mission statement; and be it further

    RESOLVED, that ISMS request the American Medical Association to engage and collaborate with the Joint Commission’s Board and Leadership to provide and survey appropriate medical standards, as per its mission statement. 


    1. Baker DW. History of the Joint Commission’s pain standards lessons for today’s prescription opioid epidemic. JAMA. 2017 Mar 21; 317(11):1117-8.
    2. United States General Accounting Office: Report to Congressional Requestors: Prescription Drugs: Oxycontin Abuse and Diversion and Efforts to Address the Problem. GAO-04-110; December 2003, page 23.
    3. Phillips DM. JCAHO pain management standards are unveiled. JAMA.2000;284(4):428-9.
    4. Manchikanti L, Helm S, Fellows B, et al. Opioid epidemic in the United States. Pain Physician. 2012 Jul;15(3 Suppl):ES9-38.
    5. Chhabra N, Leikin JB.  The Joint Commission and the Opioid Epidemic. JAMA.  2017; 318(1):91-92.
    6. Baker DW. The Joint Commission and the Opioid Epidemic – Reply. JAMA. 2017; 318(1):92.
    7. Phillips DM. JCAHO Pain Management Standards are Unveiled. JAMA. 2000; 284(4):428-429.
    8. Alkhenizan A, Shaw C. The Attitude of Health Care Professionals Towards Accreditation: A Systematic Review of the Literature. J Family Community Med. 2012; 19(2):74-80.
    9. Brasure M, Stensland J, Wellever A. Quality Oversight: Why are Rural Hospitals Less Likely to be JCAHO Accreditied? J Rural Health. 2000; 16: 324-326.
    10. Ahmedani BK, Peterson EL, Wells KE, et al. Policies and Events Affecting Prescription Opioid Use for Non-Cancer Pain Among an Insured Patient Population. Pain Physician. 2014; 17(3):205-216.  
    11. Lucus CE, Vlatos AL, Ledgerwood AM. Kindness Kills: The Negative Impact of Pain as the Fifth Vital Sign. Journal of the American College of Surgeons. 2007; 205 (1): 101-107.
    12. Sibert KS. When the Joint Commission is at the Hospital, Leave. Www.kevinmd.com/blog/2014/07/joint-commission-hospital. July 2, 2014.
    13. Brubakk K, Vist GE, Bukholm G, et al. A systematic review of hospital accreditation: the challenges of measuring complex intervention effects. BMC Health Services Research. 2015; 15:280-290.
    14. Flodgren G, Goncalves-Bradley DC, Pomey MP. External inspection of compliance with standards for improved healthcare outcomes. Cochrane Database Syst Rev. 2016, Dec 2; 12. CD008992; doi:10.1002/14651858.CD008992.pub3.
    15. Armour S. Hospitals keep ‘gold seal’ despite woes. Wall Street Journal. Sept 9/10, 2017. Volume CCLXX; No. 59, pages A1 and A10.

    Existing ISMS policy related to this issue:

    Medical staff of a hospital should cooperate to achieve Joint Commission (TJC, formerly JCAHO) accreditation of their hospital. (HOD 1982 Interim; Last BOT Review 2011)

    Continuing education of members of hospital governing boards should be required as part of the accreditation and/or licensure standards of The Joint Commission (TJC, formerly JCAHO), the National Committee for Quality Assurance (NCQA), and the Illinois Department of Public Health (IDPH) and that this continuing education be developed with the hospital medical staff. (HOD 1998; Last BOT Review 2014)

    A "physician" (doctors of medicine or doctors of osteopathy) is defined as one who by education, training, experience, and licensure is able to practice medicine in all of its branches. ISMS opposes the development of any Joint Commission (TJC, formerly JCAHO) Standard mandating medical staff membership to anyone other than physicians. ISMS encourages TJC to require greater than a majority of fully licensed physician membership on the medical staff executive committees in acute care general hospitals. ISMS urges TJC to recognize the importance of the medical staff in credentialing and in monitoring the quality of care in the hospital and it encourages the development of the appropriate environment within the hospital so that both the medical staff and limited license practitioners may work together for the best interests of the patient. (HOD 1987 Amended; Last BOT Review 2013)


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    Nestor A. Ramirez, M.D. I favor this resolution

    The Joint Commission needs to follow and comply with its mission and vision statements.

    Apr 16, 2018 at 12:16 p.m.

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