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Is your organization surveyed under The Joint Commission’s Behavioral Health Care standards? If so, be aware of new requirements effective July 1, 2019 related to pain assessment and pain management. First, let’s review the current requirements and then take a look at the new ones coming in July.

Pain Assessment & Pain Management: Current Requirements

The current standard for pain screening is in the Care, Treatment, and Services chapter of the Behavioral Health Care manual:

CTS.02.01.09 The organization screens all individuals served for physical pain.

Element of Performance # 1: The organization screens all individuals served to identify those for whom a physical pain assessment is indicated. 

Element of Performance # 2: Individuals for whom a physical pain assessment is indicated are either assessed and treated by the organization or referred for assessment or treatment.

So, under the current requirements, the organization must conduct a pain screening for all clients. If the screening determines the client needs a full pain assessment, the organization has a choice. It can conduct that pain assessment itself and treat the client’s pain. Or, it can refer the client for pain assessment and treatment.

Pain Assessment & Pain Management: New Requirements

Effective July 1, 2019, TJC is adding a new Element of Performance # 3 to this standard:

CTS.02.01.09 EP 3: For acute 24-hour settings: The organization assesses pain, then treats or refers individuals served for treatment. 

Note 1: Acute 24-hour settings includes inpatient crisis stabilization or medical detoxification. 

Note 2: Treatment strategies for pain include nonpharmacologic, pharmacologic, or a combination of approaches

Impact of the New Pain Assessment Requirements

If you’re a behavioral healthcare acute 24 hour setting, you’ll need to conduct not just a pain screening but, rather, a pain assessment for all clients. If, based on the results of the assessment, the client needs pain treatment, you can either provide that treatment yourself or refer the patient to another provider for treatment. Note that TJC’s definition of an acute 24 hour setting includes inpatient crisis stabilization and medical detox programs.

Pain Screening, Assessment, & Management: Education and Training

There are also new requirements for education and training related to pain screening, pain assessment, and pain management. In the Human Resources Management chapter, there are two new elements of performance for standard HRM.01.05.01: Staff participate in education and training.

There is a new EP 11. It requires that staff who conduct pain screening participate in education and training on screening clients for pain. The change here is that education and training on pain screening has never been explicitly required by the standards. Effective July 1, it will be.

There is also a new EP 12. It requires that practitioners in acute 24 hour settings participate in education and training on pain assessment and pain management. This is consistent with the new requirement for a full pain assessment at this level of care.

Pain Assessment & Management: Survey Findings

Based on your setting, the expanded requirements may not apply to your program. However, be aware that survey findings regarding pain screening and assessment are common for behavioral healthcare organizations. And also for PHP/IOP programs within psychiatric hospitals. The most common issues we see cited on TJC surveys are the following:

  • Pain screenings not completed. Either no pain screening included in the initial assessment process or the pain screening was left blank.
  • No follow-up on pain rating scores. For example, client rates pain as a 6 on a 0 – 10 scale but there is no further assessment of the pain.
  • Pain screening done but no definition of the criteria for when to refer for a full pain assessment.
  • Staff unaware of the procedure for referring a client for further assessment and treatment of their pain.
  • Pain issues identified and being treated but not included on the treatment plan.

Survey Readiness: What to Do Now

If you’re an acute 24 hour setting, determine how you’ll proceed to conduct pain assessments on all clients. And develop a training module for your staff on how to conduct those assessments.

If you’re not an acute 24 hour setting, develop a training module for pain screening. Also, take the following steps to ensure you’re in full compliance with the current standards:

  • Review your current procedure for conducting pain screenings and referring clients for further pain assessment and treatment.
  • If you don’t have a written policy on pain screening, develop one. Make sure it includes the criteria for when clients should be referred for a full pain assessment.
  • Train your staff on your pain screening policy. Make sure they understand when clients need to be referred for a full pain assessment.
  • Audit your clinical records to make sure staff are conducting and documenting the pain screening according to your policy.
  • Re-educate staff as needed.

When doing tracers, surveyors consistently look for documentation of pain screenings and follow-up on pain issues. We include this on all our mock surveys during our tracers. It’s an area that’s ripe for non-compliance. So, be sure to get ahead of the curve on this one!


For background and resources on pain management, see TJC’s R3 Report Issue 20: Pain Assessment and Management Standards for Behavioral Health Care.

For the full text of the standards revisions, see TJC’s Prepublication Requirements: Standards Revisions for Pain Assessment and Management in Behavioral Health Care (12/17/18).