In The Checklist Manifesto, Atul Gawande writes: “One essential characteristic of modern life is that we all depend on systems – on assemblages of people or technologies or both – and among our most profound difficulties is making them work.”
When it comes to preventive and predictive maintenance, the additional challenge is keeping things working. And in a hospital environment, where functional failure can mean injury or even death, anything less than full diligence and compliance is not an option.
What is preventive and predictive maintenance?
Periodic or continuous? Manufacturer’s specs or data-driven? These are just two of the differences between preventive and predictive maintenance. For most hospitals, the definitions that matter most come from the Centers for Medicare & Medicaid Services (CMS), which deems hospitals eligible to participate in and receive federal Medicare and Medicaid funds based on surveys conducted by state agencies or national accrediting agencies, most commonly The Joint Commission (TJC). It’s critical that hospitals – and all healthcare providers – understand and follow the latest CMS, State, and TJC equipment maintenance requirements.
Preventive Maintenance: Interval-Based, Manufacturer-Driven
The following summarizes CMS’s basic definition of preventive maintenance and provides a use case and basic checklist for equipment that best fits an interval-based schedule.
- Definition: Maintenance occurs, required or not, at specific intervals based on time (e.g., semi-annually) or usage (e.g., number of hours operated). Generally based on original equipment manufacturer (OEM) recommendations.
- Use Cases: Replacing batteries annually or after a set number of equipment uses per OEM standards, whether required or not.
- Checklist: The following summarizes CMS’s high-level standards for preventive maintenance:
- Inventory all equipment with flags for critical/high-risk and life-support equipment
- Obtain OEM recommendations for all equipment and document request
- Ensure corrective maintenance records categorize equipment failure types (e.g., wear and tear, non-preventable, user-related) and degrees (major vs. minor)
- Inspect and test all equipment before initial use and after major repairs/upgrades
- Maintain records of all personnel responsible for equipment oversight
Until 2014, preventive maintenance was CMS’s abiding standard for hospital equipment. That year, resource-strapped hospitals (i.e., hospitals) breathed a sigh of relief when the agency updated its maintenance regulations, allowing providers to establish Alternate Equipment Maintenance (AEM) protocols for non-high-risk equipment. Translation? If an equipment’s malfunction or failure would not be life-threatening or cause serious injury, hospitals can deviate from OEM recommendations and establish their own guidelines.
Predictive Maintenance: Need-Based, Data-Driven
The CMS update essentially codified a predictive maintenance option for hospitals. TJC followed suit to align with the federal agency’s new standards. CMS’s definition uses cases, and predictive maintenance checklist is summarized below. Exceptions to CMS’s AEM standard include imaging/radiologic equipment, medical laser devices, new equipment without an established maintenance history, and any other equipment defined in Federal and/or State law that requires OEM-based maintenance.
- Definition: Maintenance occurs as needed. Requires periodic and continuous monitoring to generate data for decision-making.
- Use Case: Replacing equipment batteries every two years, based on historical monitoring of continued battery effectiveness and capacity.
- Checklist: 24X7 provides an excellent summary for meeting CMS AEM standards, which include:
- Flag AEM equipment in inventories
- Create policies and procedures that justify AEM program choices
- Maintain source material used to establish AEM standards
- Identify personnel who conduct AEM risk assessment, including their experience and credentials
- Create service contracts that hold vendors accountable
- Designate staff to ensure compliance with CMS and TJC standards
- Evaluate the safety and effectiveness of the AEM program to ensure a predictive maintenance approach is best based on collected data
Opportunities and Challenges
Just as it “loosened” certain standards, CMS and TJC tightened others. A little over three years after introducing the AEM revision, the agencies collaborated to amp up AEP maintenance completion rates.To account for the risk associated with deviating from manufacturer’s standards, the agencies now require a 100% maintenance completion rate – versus 90% – for both high-risk and non-high-risk equipment in an AEM program. By using CMMS tools and Business Intelligence (BI) software, hospitals can set reliable maintenance schedules based on their past data, improving compliance and ensuring compliance. By connecting these tools to a Human Resources software, hospitals can schedule technicians to work on assets when it poses low interruption to daily activity.
AEM creates opportunities and challenges for hospitals. On the opportunity side, facilities catch a break by being able to establish their own standards which, in some cases, will reduce maintenance frequency and promote cost-effectiveness. The challenge comes from correctly classifying equipment as AEM eligible, providing ample justification for AEM determinations, ensuring documentation supports all facets of a predictive-maintenance-based approach, and being compliant. And CMS and TJC will be watching.