DOS 516 - Week 1 Discussion
Initial Post: Patient Indentification - Double, Triple, Quadruple Check
As with all things legal, the laws surrounding requirements for patient identification are complex and vary from place to place. Some regulations operate at a national scope, while some are left to states to decide. In some cases, states adopt the guidelines of national organizations. For instance, the state of Washington has adopted the policies of The Joint Commission to form the basis of its quality metrics program.1
As far as I can tell, double-checking the identity of a patient is not required by law. The Nuclear Regulatory Commission DOES require the verification of patient identity for any radiation therapy procedures requiring a written directive, such as in brachytherapy and teletherapy, but 10 CFR Part 35 only says "the licensee shall develop, implement, and maintain written procedures to provide high confidence that... [the] patient's or human subject's identity is verified before each administration."2 This does not specify a particular procedure such as double-checking; it specifies the need for a facility to develop and follow a procedure.
On the other hand, certification organizations such as The Joint Commission do have specific guidelines. As part of TJC's National Patient Safety Goals document, they specify "Use at least two patient identifiers when administering medications, blood, or blood components; when collecting blood samples and other specimens for clinical testing; and when providing treatments or procedures."3 This is a guideline for safe practice, and it is expected to be followed in order to maintain accreditation, but it is not a legal requirement in the sense of being a law.
Since we perform neither brachytherapy nor teletherapy (teletherapy specifically describes the use of sealed sources at a distance) at SCCA Proton Therapy, we are not governed by the NRC because they only cover reactor byproducts, not machine-generated radiation.4 We are, however, governed by the state of Washington because some of our patient-specific treatment devices like apertures and compensators become low-level radioactive and must be disposed of in carefully regulated ways. This last point has nothing to do with patient identification.
We follow The Joint Commission's recommendations for using two patient identifiers. Each patient is given a coded badge on their first visit which includes their name, ID photo, a barcode that can be scanned, and an RFID chip with a unique identifier. When patients arrive, they scan their badge, and their information pops up in Mosaiq so that the concierge can greet them and verify their identity. When their appointment time comes around, the appropriate staff member can check the photo of the patient prior to going to the lobby to greet them. They are called by name and then they go back to the appropriate part of the facility. Depending on where they go and what they are doing, they will be asked to state their name and date of birth, and staff members can check that against their records and the patient's photo ID badge.
As the patients enter a treatment room, a therapist will scan their badge while asking for name and date of birth. An RFID reader scans the patient's badge as the patient walks into the room, providing another check, and that patient's records appear on the Mosaiq console, which is visible to the therapists in the room. They can check the patient photo to once again make sure they have the right person. If there is any doubt, they can always ask for name and date of birth again. Before treatment begins, a timeout is called, during which time two therapists will verbally confirm the patient details such as name, site to be treated, plan to be used, and dose to be delivered. This verifies that the plan in Mosaiq is the same as the plan loaded on the treatment delivery console, and it is yet another chance to verify the identity of the patient.
Pediatric patients get many more checks because of the need for anesthesia. The nurse and anesthesiologist will verbally confirm every detail of anesthesia delivery, and a special "boarding pass" is kept with the patient. This card has patient identification details such as patient ID for SCCA Proton Therapy and their corresponding patient ID from Seattle Children's Hospital. These are cross-checked multiple times.
This may almost be overkill, but it is much better to be safe than to leave an opportunity for a mistake.
- State recognition details. The Joint Commission Website. http://www.jointcommission.org/state_recognition/state_recognition_details.aspx?ps=100&s=WA&b=1. Accessed October 15, 2014.
- 10 CFR Part 35
- NPSG.01.01.01. The Joint Commission Website. http://www.jointcommission.org/assets/1/6/AHC_NPSG_Chapter_2014.pdf. Published 2013. Accessed October 15, 2014.
- Regulation and radiation medicine. In: Radiation in Medicine: A Need for Regulatory Reform. Washington, DC: The National Academies Press, 1996.