The Next Big Moment in Healthcare Preparedness? What the Proposed CMS Rule Could Achieve

March 29, 2016

March 29, 2016 - There have been a few key moments in the world of healthcare and disaster preparedness over the past 15 years.  The Pandemic and All Hazards Preparedness Act (PAHPA), which led to the creation of the Office of the Assistant Secretary for Preparedness and Response (ASPR), and its reauthorization PAHPRA, which created the Hospital Preparedness Program (HPP), are some of the most significant shifts that have institutionalized healthcare preparedness (and emergency response).  The currently proposed Centers for Medicare and Medicaid Services (CMS) rule on healthcare preparedness may well be another. 

CMS’s draft emergency preparedness rule is expected to establish emergency preparedness requirements for providers and health systems across 17 types of healthcare settings to ensure they are prepared for wide array of disasters.  Under the proposed rule, institutions that do not meet the requirements would not be reimbursed by CMS.

It’s long been recognized that health systems need to be prepared when disaster strikes, but previous capacity building efforts have either been grant funded through HPP or only required by those facilities which are accredited by the Joint Commission.  The bulk of those accredited are hospitals.  The proposed rule would change all of that – resulting in what would be a seismic shift in how healthcare settings prepare for disasters and emergency situations.  Suddenly, community mental health centers, inpatient psychiatric services, home health agencies, transplant centers, elderly care facilities, and many other healthcare provider types will have to demonstrate significant emergency preparedness.

There’s no doubt that building resilience in healthcare delivery, and anticipating problems before they occur, is critical to creating resilient and thriving communities.  If a final rule is issued, the challenge for healthcare providers will be figuring out how to navigate the new requirements--which are not expected to come with new resources--to support that level of planning and preparation.  

The rule is currently sitting at the Office of Management and Budget (OMB), which has extended its typical 90 day review.  And, as noted by the recent New York Times article, it will have to be finalized by this fall or declared dead.

Why do we at Healthcare Ready care?  Because this rule would fundamentally change how we view healthcare preparedness in the United States.  And while some providers are already making great progress in preparedness, many smaller and independent healthcare companies are not.  How many community providers or therapists do you think have a business continuity or emergency response plan?  Our role at the intersection of public and private health offers us a unique view of this rule and its impact.  Ultimately, we want ensure that healthcare is ready to undertake these changes, if and when it is released. 

We’d love to hear your thoughts on what you think the impact of the rule will be and how you think your organization can be ready to meet the coming requirements.  We’ll be sharing our thoughts over the next few months while we work to make sure that healthcare has the necessary resources to meet the rule head-on and become more resilient organizations. 

Emily Lord

Emily Lord serves as the Executive Director of Healthcare Ready. She provides strategic guidance and oversight to programs that build community health resilience in times of disaster or pandemic outbreaks. This includes creating partnerships with the private-sector medical supply chain, as well as public health NGOs and local, state and federal government agencies.

As the ten-year anniversary of Katrina approached, Emily led the expansion of Healthcare Ready’s mission to address healthcare supply chain-wide resiliency and response by focusing on public policy and advocating for the adoption of best and promising disaster preparedness and response practices by government and industry.

Emily has also led Healthcare Ready’s response to multiple natural disasters including Hurricane Sandy, during which the organization coordinates and works to solve barriers to patient access to healthcare. Emily holds a Master of Public Administration from The George Washington University and a B.A. from the University of Wisconsin-Madison. Emily resides in Northern Virginia with her husband and daughter.