The Massachusetts Health & Hospital Association, on behalf of its member hospitals, health systems, physician organizations, and allied healthcare providers, appreciates this opportunity to offer comments in opposition to HB1144/SB1167.
The hospital community has long recognized the importance of developing internal surveillance programs to evaluate injuries and security risks to healthcare professionals and the overall healthcare workforce. As a result of such internal reviews, many hospitals already have established programs addressing elements highlighted in HB1144/SB1167, including: implementing safe patient handling programs and policies; developing processes that include employees and others in reviewing and assessing organizational and operational needs based on patient populations served; conducting Safe Patient Handling (SPH) training programs for appropriate staff; and, carrying out routine or ongoing injury surveillance programs.
Such site-specific safe patient handling efforts are more responsive and appropriate than the one-size-fits-all approach outlined in HB1144/SB1167. One reason this bill fails to meet the mark is that it does not take into account the inherent differences in the sizes and types of healthcare organizations, their patient populations, needs, and treatment practices. For example, patients with disabilities, bariatric patients, and patients with certain psychiatric conditions are among the many patients who present unique handling challenges that warrant special equipment and techniques for healthcare providers – needs that can differ across the wide spectrum of providers. HB1144/SB1167 requires the adoption of various new technology and services that may not be needed in specific facilities and only adds to the overall cost of maintaining a facility.
Several national organizations have, similar to the Massachusetts hospital sector, developed general guidance for the adoption of a safe patient handling program that takes into account the specific needs and resources of a facility. These national organizations have not required or mandated a specific set of requirements for all facilities, but provide guidance for staff to consider in determining what works best for the specific staff and facility. For example, the Facilities Guidelines Institute, the American Nurses Association, the Veterans Administration, the Association of Occupational Health Professionals (AOHP), and the federal Occupational Safety and Health Administration (OSHA) all worked with the provider community to develop guidance materials. These materials were specifically issued as guidance and not requirements as the groups understood that any process must take into consideration current patient populations, the availability of new technology and strategies, and new staff training.
If enacted, HB1144/SB1167 would mandate that all licensed facilities (hospitals, nursing homes, skilled nursing facilities, and assisted living facilities) must purchase costly equipment and require the expenditure of significant resources – potentially even requiring building re-design, service re-location or service closures – in order to ensure SPH compliance, regardless if such equipment is needed in a specific area or unit. Such a blanket mandate poses conflicts with existing standards and limits the ability of organizations to be appropriately responsive to evolving patient populations and the realities of their existing structures.
The Massachusetts Department of Public Health (DPH) conducted a survey of acute care hospitals and has reported that most hospitals have taken steps to improve patient handling to protect worker and patient safety. In fact, almost all of the surveyed hospitals had a protocol for the assessment of patient functional mobility and transfer needs on admission, and also had systems for tracking injuries to their employees associated with patient handling.
MHA, working within a joint stakeholder group that includes DPH, the Organization of Nurse Leaders, and others (including occupational injury surveillance experts) are developing continued education and guidance materials to help providers review and improve current policies and practices. The overall healthcare community is working together in a collaborative manner to find reasonable and appropriate methods to best meet the needs of healthcare professionals and patients. Such current efforts should be supported and fostered in a manner that will result in the safest possible environment for patients and workforce alike. For all of the reasons highlighted above, we urge the Committee to reject HB1144/SB1167and instead work with DPH and healthcare providers on advancing flexible, responsive policies that will prevent injuries to healthcare professionals and improve the quality of patient care in healthcare facilities.
Thank you for the opportunity to offer testimony on this important matter. If you have any questions regarding this testimony or require further information, please contact Michael Sroczynski, MHA’s Vice President of Government Advocacy, at (781) 262-6055 or firstname.lastname@example.org.