The Joint Commission Has a Close Relationship with JCR through Their Governance Structure and Operations

The mission statements of the Joint Commission and JCR both share the  same phrase of seeking “to continuously improve the safety and quality of  care.” While each organization differs in the activities it engages in to  achieve that mission, they maintain a close relationship through both their  governance structure and operations. This committee is charged with  monitoring compliance with the firewall and related policies. The Joint Commission and JCR Provide Operational Assistance to One Another

The structure of the Joint Commission and JCR allows the two  organizations to provide certain operational assistance to one another. The Joint Commission provides support and management services to JCR. The Joint Commission and JCR Have Taken Steps to Prevent the Improper Exchange of Facility-Specific Information

The Joint Commission and JCR have taken steps, primarily since 2003,  designed to strengthen the firewall guidance initially developed in 1987,  shortly after the creation of JCR. The stated purpose of both organizations’ firewall policies is “to eliminate  any real or perceived conflict of interest” between the Joint Commission’s  accreditation activities and JCR’s consulting services. The Joint Commission’s role in accrediting the majority of  hospitals participating in Medicare makes the issue of ensuring the  independence of the Joint Commission’s accreditation process vitally  important. V.) CMS did not comment on our findings or concluding  observations. Both the Joint Commission and CMS provided us with  technical comments, which we incorporated as appropriate. Appendix I: Scope and Methodology

We examined the relationship between the Joint Commission on  Accreditation of Healthcare Organizations (Joint Commission) and Joint  Commission Resources, Inc. (JCR) as it relates to the independence of the  Joint Commissions’ hospital accreditation process from JCR’s hospital  consulting services. To describe the policies the Joint Commission and JCR have developed to  prevent the improper sharing of facility-specific information, we reviewed  Joint Commission and JCR documents, including current and past policies  and guidance related, either directly or indirectly, to the firewall. As part of our work, we also interviewed staff at the Department of Health  and Human Services’ Centers for Medicare & Medicaid Services to obtain  information on their oversight of the Joint Commission and other  accreditation organizations.
Why GAO Did This Study

Hospitals must meet certain conditions of participation established by the Centers for Medicare & Medicaid Services (CMS) in order to receive Medicare payments. In 2003, most hospitals--over 80 percent--demonstrated compliance with most of these conditions through accreditation from the Joint Commission on Accreditation of Healthcare Organizations (Joint Commission). Established in 1986, Joint Commission Resources, Inc. (JCR), a nonprofit affiliate of the Joint Commission, provides consultative technical assistance services to hospitals. Both organizations acknowledge the need to ensure that JCR's services do not--and are not perceived to--affect the independence of the Joint Commission's accreditation process. GAO was asked to provide information on the relationship between the Joint Commission and JCR. This report describes (1) their organizational relationship, and (2) the significant steps they have taken to prevent the improper sharing of information, obtained through their accreditation and consulting activities, respectively, since JCR was established. GAO reviewed pertinent documents, including conflict-of-interest policies and information about the organizations' financial relationship, and interviewed staff and board members from both organizations, JCR clients, and CMS officials.

What GAO Found

The Joint Commission and JCR have a close relationship as demonstrated through their governance structure and operations. The Joint Commission has substantial control over JCR and the two organizations provide operational services to one another. For example, JCR manages all Joint Commission publications, while the Joint Commission provides support services to JCR. Despite the Joint Commission's control over JCR, the two organizations have taken steps designed to protect facility-specific information. In 1987, the organizations created a firewall--policies designed to establish a barrier between the organizations to prevent improper sharing of this information. For example, the firewall is intended to prevent JCR from sharing the names of hospital clients with the Joint Commission. Beginning in 2003, both organizations began taking steps intended to strengthen this firewall, such as enhancing monitoring of compliance. Ensuring the independence of the Joint Commission's accreditation process is vitally important. To prevent the improper sharing of facility-specific information, it would be prudent for the Joint Commission and JCR to continue to assess the firewall and other related mechanisms. The Joint Commission agreed with GAO's concluding observations. CMS did not comment on GAO's findings or concluding observations. Both provided technical comments, which we incorporated as appropriate.