The CMS Preparedness Rule: Opportunity is Knocking – Will Healthcare Coalitions Answer the Call?

The CMS Preparedness Rule: Opportunity is Knocking – Will Healthcare Coalitions Answer the Call?

October 17, 2016

October 17, 2016 - On September 8th, the Centers for Medicare and Medicaid Services made official what many in the emergency preparedness industry had anticipated for some time: emergency preparedness (as defined by CMS) is now a condition of participation in the Medicare/Medicaid program.

While various stakeholders contemplate just how they will be affected by the new rule, one thing is abundantly clear: These new regulations represent a golden opportunity for the well-established healthcare coalition to enhance its reach, its influence, and perhaps even its outlook as a sustainable business model.

The most important aspect of this new regulation is that it is inclusive of several healthcare facility types for whom emergency preparedness has not been a requirement in the past. Certainly, most well prepared hospitals have been dealing with similar requirements from Joint Commission for years. Home health, hospice, long term care and others, however, have had little in the way of industry-wide EP regulation.

What’s more? Many of these provider types are not even aware that the rule has been released! In fact, during a recent training session in Virginia, where I serve as the Executive Director of a healthcare coalition called the Near Southwest Preparedness Alliance only about 1/3 of the people in the room were aware of the new rule two weeks after its release!

Therein lies the opportunity for a high-functioning healthcare coalition.

Established over the past decade through the Hospital Preparedness Program under the Department of Health and Human Services, healthcare coalitions span the country with the mission of assisting healthcare interests to prepare for and respond to medical surge and threats to continuity of operations. They are therefore uniquely positioned to assist these groups in their compliance efforts.

Many of the non-hospital healthcare entities included by CMS are unfamiliar with the basic principles of emergency management. Margins are thin and too often the emergency management role is but a second (or third) hat worn by a busy administrator, practice manager or facilities director.

In many of these facilities, the “Emergency Plan” is little more than a list of phone numbers and an evacuation map used for fire drills. The notion of preparedness as an ongoing, continuous cycle simply doesn’t exist in the many of the facility types included in the new rule.

 The savvy coalition will see this challenge to the healthcare industry as an opportunity to demonstrate the immense value of the coalition model.

Coalitions must take advantage of the following opportunities:

  • Educate and inform on the rule – as mentioned above, many nursing homes, home care organizations, hospice organizations and others don’t currently know that future Medicare payments will be tied to their preparedness efforts. Strategic outreach in these areas, backed by industry-specific literature on the new rule, will allow the coalition to help educate groups that have not had to demonstrate preparedness in the past.
  • Establish the coalition as the expert –the coalition must continually stay up to date on the rule’s survey methods and implementation. The coalition must understand the rule and convey that information to their healthcare members. To assist in this effort, coalitions should look to partner with other agencies and non-profits (like Healthcare Ready) to collect and co-locate the most up to date resources for their members.
  • Leverage collaborative efforts to accomplish rule requirements –, the intent of the rule is to improve the preparedness efforts of these healthcare entities. Coalitions exist for this very purpose! Coordinating drills, exercises and after-action reviews for healthcare partners beyond hospitals extends the reach (and thus the strength) of the coalition and provides much needed expertise to these critical healthcare partners.

Without a doubt, the rule represents a serious challenge for many healthcare providers, systems, and organizations.

Perhaps more importantly, it also represents an opportunity for the high-functioning healthcare coalition to prove its value by assisting and supporting its members in meeting the new requirements.

In a program where future federal funding is all but certain, demonstrating value to one’s customers should be a top priority for every coalition.

Opportunity is knocking…will your coalition answer?

Craig Camidge

Craig Camidge is the Regional Healthcare Coordinator and Executive Director for the Near Southwest Preparedness Alliance in Southwest Virginia.

In this role, he works at the nexus of the healthcare, private business, local and state government, and public health industries to further the coalition model of disaster preparedness.

Prior to his emergency management work, Mr. Camidge worked for six years in private sector, portal of entry healthcare service. He understands the concerns of the healthcare provider in both day-to-day patient care and emergency management.

In his short tenure as an emergency management professional, Craig has been a sought-after speaker on topics ranging from regional preparedness, patient tracking, and the business of healthcare coalitions both within Virginia and across the country.