Healthcare is increasingly being delivered outside of hospitals in widely diverse settings. However, the level of preparedness for disasters and emergencies varies — even though disasters stress the entire system.
The latest Centers for Medicare & Medicaid Services (CMS) final rule establishes consistency with requirements for all who participate in Medicare and Medicaid. The regulations will lead to increased patient safety during emergencies and more coordinated responses to natural and man-made disasters.
Over the past several years — most recently in Louisiana — disasters have put the health and safety of Medicare and Medicaid beneficiaries, and the public at large, at risk. These new requirements require participating providers and suppliers to plan for disasters and coordinate with federal, state tribal, regional and local emergency preparedness systems. This will help them adequately prepare to meet the needs of their patients, residents, clients and participants during disasters and emergency situations.
The first priority of healthcare providers and suppliers is to protect the health and safety of their patients. Preparation, planning and a comprehensive approach for emergency preparedness is key.
Whether it's trauma care or long-term nursing care or a home health service, patients' needs for healthcare don't stop when disasters strike — in fact, their needs often increase in the immediate aftermath of a disaster. All parts of the healthcare system must be able to keep providing care through a disaster, both to save lives and to ensure that people can continue to function in their usual setting.
After reviewing the current Medicare emergency preparedness regulations for both providers and suppliers, CMS found that regulatory requirements were not comprehensive enough to address the complexities of emergency preparedness. For example, the requirements did not address the need for: (1) communication to coordinate with other systems of care within cities or states, (2) contingency planning and (3) training of personnel.
After careful consideration of stakeholder comments on the proposed rule, this final rule requires Medicare and Medicaid participating providers and suppliers to meet the four common and well-known industry best practice standards listed below.
The final rule includes changes based on feedback, such as, removing the requirement for additional hours of generator testing, flexibility to choose the type of exercise a facility conducts for its second annual testing requirement, and allowing a separately certified facility within a healthcare system to take part in the system's unified emergency preparedness program.
1. Emergency plan: Based on a risk assessment, develop an emergency plan using an all-hazards approach focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters specific to the location of a provider or supplier.
2. Policies and procedures: Develop and implement policies and procedures based on the plan and risk assessment.
3. Communication plan: Develop and maintain a communication plan that complies with both federal and state law. Patient care must be well-coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency systems.
4. Training and testing program: Develop and maintain training and testing programs, including initial and annual training, and conduct drills and exercises or participate in an actual incident that tests the plan.
The new standards incorporate these core components across all provider and supplier types, such as hospitals, organ procurement organizations and home health agencies. However, requirements have been tailored for the unique characteristics of each type of provider and supplier, as well as the needs of their patients, residents, clients and participants.
For example, outpatient providers and suppliers — such as ambulatory surgical centers and end-stage renal disease facilities — will not be required to have policies and procedures for provision of subsistence needs. Also, hospitals, critical access hospitals and long-term care facilities will be required to install and maintain emergency and standby power systems based on their emergency plan.
Providers and suppliers may want to consider joining their local healthcare coalitions, which grew out of the Hospital Preparedness Program. They provide an opportunity to share resources and expertise in developing an all-hazard emergency plan and also provide support during an emergency. Additional resources include the CMS blog and Survey & Certification — Emergency Preparedness webpage.
The regulations become effective on Nov. 15, and implementation by all providers and suppliers participating in Medicare and/or Medicaid is set for Nov. 15, 2017.
