Heads up! Does your organization provide treatment to individuals with addictions? If so, the new Joint Commission standards for substance use disorder treatment apply to you.

The new requirements became effective July 1st in the Behavioral Health Care Accreditation Program. They’re applicable to organizations providing care, treatment, or services to individuals with addictions.

We queried the TJC Standards Interpretation Group to determine if these new requirements apply only to individuals with a diagnosis of substance use disorder. They clarified that if an organization identifies on their E-Application that they treat individuals with addictions, these standards apply.

Clearly, these new requirements will be important in upcoming surveys. So, let’s take a look at what TJC now requires in one area that’s closely scrutinized during surveys: the assessment process.

Joint Commission Standards: New Assessment Requirements

The Joint Commission’s Behavioral Health Care manual has contained standards for several years on assessment in substance use treatment programs. The new July 2020 requirements expand on these existing standards. Thus, it’s important to carefully review your current assessment tools and make sure you’re capturing all the information now required effective July 1st.

Substance Use History

Joint Commission standard CTS.02.03.07 EP # 1 requires you to obtain a history of the individual’s use of alcohol, drugs, nicotine and other addictive behaviors. This history must now include the following information. (New language is in boldface type.)

• Age of onset
• Method of acquiring substance
• Duration
• Patterns of use (e.g. continuous, episodic, binge, frequency, amounts, and route for taking the substance)

Thus, there are two expanded elements in this requirement. First, to describe the method the individual uses to acquire the substance. Second, the examples of patterns of use now include frequency, amounts, and route for taking the substance.

CTS.02.03.07 EP # 2 now requires you to obtain the following information.  (New language is in boldface type.)

• The individual’s history of mental, emotional, behavioral, legal, and social consequences of dependence or addiction (e.g. legal problems, divorce, loss of family members or friends, job related incidents, financial difficulties, blackouts, memory impairment.)
• The individual’s history of physical problems associated with substance abuse, dependence, and other addictive behaviors
• History of the use of alcohol and other drugs, and other addictive behaviors by the individual’s family
• If applicable to the belief system of the individual served, the individual’s perception of the role of spirituality or religion in his or her life and recovery
• The individual’s readiness to change
• The individual’s current living arrangements and environment and options for an alternative and supportive living environment

So, now there’s a more nuanced approach to evaluating the role of spirituality or religion in the individual’s life. The revised standard states this information is only required if it’s “applicable to the belief system of the individual served.”

However, it would seem that, pragmatically, the only way to know this is by asking the individual about the role of spirituality or religion in his/her life. So, there’s really no substantive change here in the information gathering process on this topic.

On the other hand, there are two new pieces of information Joint Commission standards now require. First, the individual’s readiness to change. Several studies have shown that readiness to change directly influences treatment outcomes. Many substance use treatment programs already incorporate the Stages of Change model in their assessment and treatment planning process.

The second new requirement is to gather information about the individual’s current living arrangements/environment and options for an alternative and supportive living environment. The rationale here is that a supportive, stable, and safe living environment contributes to improved treatment outcomes.

Assessment of Withdrawal Potential

The previous Joint Commission substance use standards required the assessment to include information about the individual’s previous treatment, response to that treatment, and relapse history. Indeed, this was an area frequently cited on surveys. The common issue was the organization had collected information about the client’s previous treatment but did not address their response to that treatment or their relapse history.

CTS.02.03.07 EP # 7 still requires that the organization collect all of this same information. But, they’ve added an additional piece of information to collect. Specifically, you must collect information about the individual’s potential for acute intoxication and/or withdrawal.

Rationale here is that information about withdrawal potential and related symptoms (for example, seizures) is critical for ensuring the individual’s safety.

Notably, all of the revisions to the previous substance use treatment standards are in keeping with the American Society for Addiction Medicine (ASAM) criteria for multidimensional assessment which include the following:

• Dimension 1: Acute intoxication and/or withdrawal potential
• Dimension 2: Biomedical conditions and complications
• Dimension 3: Emotional, Behavioral, or Cognitive Conditions or Complications
• Dimension 4: Readiness to Change
• Dimension 5: Relapse, Continued Use, or Continued Problem Potential
• Dimension 6: Recovery/Living Environment

Survey Readiness: What to Do Now

If you provide substance use disorder treatment, you should review your current assessment tools and protocols against these new requirements. Be sure to include the additional elements required by the revised standards.

Also, take careful note of the examples that TJC provides in the standards. Consider including those examples as prompts in your clinical record documentation formats.

For instance, CTS.02.03.07 EP # 2 now includes examples of the consequences of addiction. It lists legal problems, divorce, loss of family members or friends, job related incidents, financial difficulties, blackouts, memory impairment.

Although these are only examples and not requirements per se, they provide useful prompt for clinicians to consider when conducting their assessments. Often, we see documentation formats that include broad headings such as Consequences of Addiction with a free text box.

With this documentation approach, the information gathered is often not sufficiently specific and not individualized to the client. As a result, we see surveyors frequently citing these issues on survey.

Barrins & Associates Resources

For more background on the new substance use treatment requirements, see our January post TJC Standards Update: New Requirements for Substance Use Disorder Treatment. As we conduct our Mock Surveys we’re incorporating these new requirements into our tracers and clinical record reviews. As always, Continuous Readiness is the key to success!

In addition, be sure to check out The Joint Commission’s R3 Report Issue 25 Enhanced Substance Use Disorders Standards for Behavioral Health Organizations. It’s an excellent resource and provides the rationale for each of the standards changes. It also contains a wealth of references and best practice resources.