Health-Care Providers May Need to Step up Emergency Preparedness

The Centers for Medicare and Medicaid Services (CMS) proposed new preparedness requirements for hospitals and 16 other types of health-care providers to mitigate disasters like the Boston Marathon bombings and natural hazards like hurricanes Katrina and Sandy.

Along with hospitals, long-term care facilities, home health agencies, nursing homes, hospices, transplant centers and community mental health facilities would have to meet the four core elements of the preparedness plan. Several of the requirements are tailored to the needs of the provider, because of the differing nature of each provider.

The proposal revolves around four components of emergency preparedness: risk assessment and planning; policies and procedures; communication plans; and training and testing. Those by themselves are fairly innocuous, but some of the details have health-care providers concerned about the overall cost. For instance, updating old emergency power systems to keep air conditioning and heating units working, and maintaining sewage and waste disposal during a power outage as per the new requirements, could prove costly.

CMS has projected the costs to be about $225 million for the first year and $41 million for each subsequent year. CMS said the average cost for a hospital would be about $8,000 a year. The American Hospital Association objected to those figures, saying CMS has underestimated the cost and burden that it would take for hospitals to comply.

Elements of the proposal include:

• All providers accepting federal and state funds would have to develop a plan incorporating the four components mentioned above.
• All providers must use an all-hazards approach that covers a range of both man-made and natural disasters.
• Hospitals would be required to: maintain food and drink on hand for staff and patients; identify alternative sources of energy; address how sewage and waste would be disposed of; and create a policy to track patients and staff during a disaster.
• Hospitals would have to identify alternative hospitals or sites in case of emergency or evacuation.

The Joint Commission, a nonprofit that accredits and certifies more than 20,000 health-care organizations, changed standards in response to Hurricane Katrina and others during 2005 to create emergency management guidelines. But not all providers are accredited and have the comprehensive emergency management standards set forth by the Joint Commission. Also, the various state, local and federal laws and guidelines fall short of what’s necessary to prepare health-care providers for a disaster. As a result, health-care providers and suppliers across the country don’t all have the necessary planning and preparation to respond adequately to disasters.

In a letter to CMS, the American Hospital Association articulated that it supports guidelines for preparedness but that most hospitals already meet existing Joint Commission standards. It urged CMS to ensure that new guidelines enhance readiness without adding confusion or administrative burden by aligning any new standards with current ones. It also advocated for:

• Defining leadership roles for community planning, saying that local emergency management and public health authorities are best equipped to coordinate preparedness and response.
• An integrated approach to emergency planning. Integrated health systems should have the option to maintain one coordinated emergency plan in cases where a single plan improves preparedness.
• Collaboration with stakeholders.

The letter also urged that hospitals and other providers be able to articulate a time frame to make significant structural changes. CMS is still reviewing comments and questions from a 60-day comment period. After the review period, CMS will issue a final ruling in the Federal Register and the rule could then go into effect, or the federal agency could decide to allow some lag time before the rule goes into effect.