RESTRAINTS AND DEBRIEFING
Question: Now that Joint Commission (TJC) has incorporated more of the Medicare (CMS) requirements into the standards, is debriefing required after the use of restraints or seclusion in hospitals using the survey process for deemed status and not for deemed status?
Response: CMS does not have a requirement for a debriefing following the use of restraints or seclusion. This is addressed in TJC’s FAQ dated 10/6/09. One of the questions is as follows:
Q. Do the new standards require a debriefing process after an episode during which a patient has been placed in restraints for violent or self-destructive behavior?
A. No, the Hospital Accreditation restraint/seclusion standards for deemed status purposes do not require a debriefing process to be completed. This does not prohibit the organization from requiring a debriefing process as they see fit. The debriefing process is often used when the patient has a behavioral health issue and is part of the process.
The debriefing is required for non-deemed status surveys. The requirement is stated in standard PC.03.03.03 and PC.03.03.29. The first standard states the requirement that policies be developed. The second states the actions to be undertaken. That includes the content of the debriefing included in EP 3.
• Identification of what led to the use of restraint or seclusion and what could have been done differently
• Ascertainment that the patient’s physical well-being, psychological comfort, and the right to privacy were maintained
• Counseling of the patient for any physical or psychological trauma that may have resulted from the use of restraint or seclusion
• Modification of the patient’s plan for care, treatment, and services, if such modification is indicated
Question: Does The Joint Commission require that a debriefing with staff is to be performed after the use of behavioral health care restraints, in a hospital that does not have a behavioral health/psychiatric unit?
Response: Performing a debriefing is an excellent idea whether the patient who has had behavioral health care restraints is in a behavioral health care setting or in a medical-surgical health care setting. However, it is not a requirement to perform a debriefing after behavioral health restraints are used on a patient in a medical-surgical health care setting. The Introduction to the Behavioral Health Care Restraint and Seclusion standards for a non-deemed status survey in the CAMH specifies the standards that are applicable in that circumstance:
Selected standards, PC.03.03.11 through PC.03.03.19, PC.03.03.23, and PC.03.03.25 apply to non-behavioral health settings in which restraint or seclusion are used for behavioral health reasons—to protect the patient against injury to self or others because of an emotional or behavioral disorder.
As noted above, standards PC. 03.03.03 and PC.03.03.29 contain the debriefing requirements, and are not included in the list of standards applicable for behavioral health restraints in a non-behavioral health setting.