In this regard, CMS regulations would certainly bring a level of consistency to all Medicare and Medicaid-participating agencies in their emergency management efforts. They would have to comply in order to participate. Instead of the carrot (an incentives-based program, like the Hospital Preparedness Program), you would now be relying on the stick (a regulatory program).
Without going into too much detail (I will leave you to peruse the 120 page article at your own leisure), the regulations proposed by CMS would ensure that all hospitals and healthcare facilities participating in Medicare or Medicaid programs adequately plan for both natural and man-made disasters, and coordinate with federal, state, tribal, regional, and local emergency preparedness systems.
The proposed rule would require four essential elements of emergency preparedness programs for healthcare providers:
- Risk Assessment and Planning (using an “all-hazards” approach)
- Policies and Procedures
- Communication Plans
- Training and Testing (including an annual training and exercise/drill requirement)
In reality, most of the proposed requirements overlap with current grant or accreditation requirements, so many hospitals and healthcare facilities are already doing this work or have some semblance of a program already. The concern, as always, is with the additional costs and workforce burden placed on an already overtaxed hospital and healthcare system. Hospital staff will no longer be “striving” to meet guidelines, but instead “required” to meet guidelines.
The potential of this program is admirable, but I remain skeptical until I see what kinds of additional support will be available for participating agencies as they transition into meeting requirements, especially for those at the resource-light end of the spectrum. Word is that these proposed requirements are still on hold for now, so healthcare facilities don’t have to worry yet. I am optimistically hopeful, and will dutifully keep you all posted as CMS continues to figure out how to shrink the ever-widening preparedness spectrum.