Medicare Emergency Preparedness Rules Appear Prescient

Every few years, America’s state of unpreparedness is made plain.
 
Rules are changed, money flows, and things improve a bit. After September 11, 2011, we included terror events in our emergency plans. After Katrina, Rita, and others storms in 2005, we revisited our hurricane and flooding plans. After Superstorm Sandy in 2012, we recognized that hospitals could no longer be “separate but equal” in preparedness. Now, in 2017, Hurricanes Harvey and Irma make us realize that preparedness must apply across the healthcare spectrum.
 
When the Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Conditions of Participation were made law last September, many were taken by surprise. Now, just weeks from taking full effect, they appear prescient. Along with hospitals, most of whom have practiced preparedness for years, every long-term care facility, ambulatory surgical center, home health agency, and even hospice that accepts Medicare will have to have a substantive emergency management plan, including training and exercises.

It won’t stop with Medicare/Medicaid.

Community Health Accreditation Partner(CHAP), an accreditation agency focusing on home health, hospice, public health, and other agencies, has incorporated CMS’s emergency preparedness into its accreditation standards. Now the state of Florida is stepping up its preparedness requirements across the board. Eight elderly residents of a Hollywood Hills, Florida, long-term care center died from heat-stress-related causes. Hurricane Irma rendered the facility without air conditioning long enough that the inside temperature elevated to unsurvivable temperatures. The state’s licensing agency, the Agency for Health Care Administration, issued a rule that all licensees will submit a plan to have sufficient auxiliary power to maintain an indoor ambient temperature of 80F for up to 96 hours after a power loss. This applies to all licensed facilities in the state of Florida, whether they accept Medicare or not.

The media is a relentless advocate for the elderly residents of long-term care.

An article in the Tampa Bay Times decried the lax enforcement of existing preparedness rules. “Florida’s emergency planning system for long-term care facilities is the government equivalent of a take-home exam: Providers administer the exercise themselves, drill themselves and are expected to honestly report on their shortcomings and correct them,” said the article. There is a point to that: an independent review will not only be free from direct pressure, but it is also free from the built-in bias that says the exercise scenario “won’t be that bad” and that overlooks gaps in plans that can be disastrous when the real thing comes along.

The public wants to know Grandma will be O.K.

The administrator of a long-term care facility explained why she called me recently for help with their emergency plan. “It was the hurricane,” she said. “When people like you called, asking what we were going to do with their mom if the storm came, and we realized we really didn’t have a good plan, we knew we needed to improve.”
 
Are you ready to take the next step in preparedness for your facility? Contact us today to get started.
Categories: CMS Compliance | Healthcare

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