• One of the largest AOs says that over 85 OSHA standards are related to its standards.
• TJC says compliance with applicable OSHA regulations is expected under its Leadership chapter standards.

To participate in Medicare, a healthcare organization must first be certified by a state survey agency, and the state must find compliance with the minimum conditions of participation (CoPs) required by the Centers for Medicare & Medicaid Services (CMS). After that, a healthcare organization is subject to regular surveys by the state to determine continued compliance.

Alternatively, however, a healthcare organization may demonstrate continued compliance through accreditation by a CMS-approved, national accrediting organization (AO). All AOs must reapply for continued approval of their accreditation programs at least every 6 years. CMS explains that an approved, national AO has shown that its program meets requirements that are at least as stringent as minimum CoPs under the Medicare program.

One of the largest AOs, The Joint Commission (TJC), says that over 85 Occupational Safety and Health Administration (OSHA) standards are related to its TJC standards. Examples are found in TJC's Emergency Management (EM), Human Resources (HR), Infection Prevention and Control (IC), Leadership (LD), National Performance Goals™ (NPG™), and Physical Environment (PE) standards chapters. This makes sense because TJC and its standards focus not only on patient safety and the protection of property but also worker safety and health.

TJC standards are performance-oriented, whereas OSHA is often more prescriptive. That means to protect your healthcare workers, it’s important to meet not only applicable accreditation standards but OSHA standards too. In fact, TJC says compliance with applicable OSHA regulations is expected under its Leadership chapter standards, no matter if the OSHA regulations are referenced by the TJC standards. Your leadership team is accountable for OSHA compliance whether or not a regulation is referenced by TJC standards.

In addition, TJC points to the data collected under OSHA 29 CFR 1904 as one method to monitor facility conditions for TJC compliance. Part 1904 records will help a facility identify opportunities, reduce hazards, and solve issues.

What about Accreditation 360?

It’s worth noting that the overhauled Accreditation 360 TJC standards took effect January 1, 2026. These revamped standards are not only fewer in number but less prescriptive. The danger is that covered healthcare organizations may think the old TJC requirements have fallen away. However, the broadly worded standards may still encompass all the same “old” TJC requirements, even though they’re no longer explicitly found in the text.

Because TJC removed granularity from the standard text, the historical, one-to-one cross-walk between TJC standards and many OSHA regulations no longer exists. Yet, the TJC expectations have not really disappeared, so, as healthcare organizations comply with streamlined TJC standards, they may find it helpful to also turn to OSHA regulations for more prescriptive language needed to ensure full compliance.

Regardless, healthcare organizations must comply directly with applicable OSHA regulations to meet their obligations under the Occupational Safety and Health Act.