Emergency management leaders at hospitals and medical centers are grappling with a major rule change from the Centers for Medicare and Medicaid Services (CMS).
CMS finalized a rule it says is intended to establish consistent emergency preparedness requirements for health-care providers participating in Medicare and Medicaid.
In announcing the rule, CMS specifically mentioned this summer’s flooding in Louisiana, where hospitals struggled to cope with the enormous scope of the emergency. “Situations like the recent flooding in Baton Rouge, La., remind us that in the event of an emergency, the first priority of health-care providers and suppliers is to protect the health and safety of their patients,” CMS Deputy Administrator and Chief Medical Officer Dr. Patrick Conway said in a news release. “Preparation, planning and one comprehensive approach for emergency preparedness is key. One life lost is one too many.”
Officially titled “Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers,” the new regulations must be implemented by November 2017. While CMS has yet to release specific guidelines around many of the new requirements, some in the hospital world believe big changes are coming.
“We have always had emergency plans, but now they are asking for really specific policies and procedures,” said Ruth Ragusa, senior vice president for quality and care management at the 455-bed South Nassau Communities Hospital in Long Island, N.Y.
“Plans in the past were fairly detailed, but we expect that even further detail will be required. There will be more depth in the communications area and also in training and testing,” she said.
The new rule applies not just to hospitals but also to long-term care facilities as well as to outpatient providers such as ambulatory surgical centers (ASCs) and end-stage renal disease facilities.
While that may seem like painting with a broad brush, some commend CMS for differentiating in the requirements for different types of facilities. For example, the communications component of the rule tasks hospitals with having very specific procedures in place to track patients during a crisis, whereas ASCs carry less of a burden in this area.
“We can cancel appointments or send patients home, and CMS acknowledged that, very appropriately. They recognized that ASCs would not need to keep track of patients in the same way as hospitals,” said David Shapiro, a board member with the Accreditation Association for Ambulatory Health Care (AAAHC) and an anesthesiologist at Red Hills Surgical Center in Tallahassee, Fla.
CMS officials tailored a number of requirements to reflect the diverse types of providers covered under the rule. Outpatient providers don’t have to have policies and procedures for provision of subsistence needs, for example, while hospitals and long-term care facilities do need to install emergency and standby power systems.
Nonetheless, providers of all stripes will likely feel the impact of the new rules. Even in the absence of specific guidance from CMS, the revised regulations “do seem to go a little further, a little deeper,” Shapiro said. While AMCs have long coordinated their emergency plans with state and local authorities, for example, “now they are asking us to step up our game in terms of making sure that we specifically document those efforts.”
For emergency managers outside the medical community, meanwhile, the new requirements could be a boon. “State and local emergency managers are always happy when the people who are their customers in a crisis have got a good plan,” said Michael Anderson, a director at public safety consulting and managed services IXP Corp. in Princeton, N.J.
“This is an opportunity for emergency managers to be a resource to the medical community, to evaluate their plans and help make them stronger,” he said. “Knowing who your counterpart is in that hospital, knowing how to get hold of people in a crisis, those are going to be key benefits for emergency management.”
CMS lays out four areas that medical providers need to address as part of their overall preparedness efforts:
Emergency plan: Perform a risk assessment and build a plan using an all-hazards approach to address the full spectrum of location-specific emergencies or disasters.
This is the tip of the iceberg: The full rule runs to almost 190 pages, and CMS still is expected to issue a range of more detailed documents laying out its expectations for exactly how providers will fulfill the new requirements.
CMS offers a number of pointers to help emergency planners begin to address the new requirements. It identifies FEMA documents for risk assessment, communication and training as potentially helpful tools.
The intention, overall, seems to be to turn up the heat on emergency planners. While most medical facilities have emergency plans in place, CMS insists a more rigorous, comprehensive approach is needed.
Upon reviewing providers’ present readiness efforts, “we concluded that the current requirements are not comprehensive enough to address the complexities of actual emergencies,” the rule states. In the event of a disaster, “health-care facilities across the nation will not have the necessary emergency planning and preparation in place to adequately protect the health and safety of their patients.”
It’s not the lack of planning per se, so much as it is the fragmented nature of the rules that has CMS most concerned. “[T]he current regulatory patchwork of federal, state and local laws and guidelines, combined with various accrediting organizations’ emergency preparedness standards, falls far short” of what is needed, CMS writes.
To ensure facilities get up to speed, CMS is calling for a higher degree of practical exercise. In addition to training and testing, “you also need to drill your staff,” noted Andrew Randazzo, CEO of Prime Medical Training in Knoxville, Tenn. Among other things, the new rules call for hospitals to participate in a community mock disaster drill at least annually, along with tabletop exercises.
This will likely require some financial investment. At South Nassau Communities Hospital, Ragusa voiced a common concern: that the new requirements may come with a steep price tag. “It may mean additional supplies, resources, systems,” she said. “We are going to have to revisit communications and training, all these areas. Will it require 10 percent or 20 percent more? Without the specifics it’s hard to say.”