How can the Center for Medicare and Medicaid Services (CMS) possibly expect 17 provider and supplier types to meet the requirements of its proposed emergency preparedness rule when the National Healthcare Preparedness Program (NHPP) has been cut by 50% over the past decade? Well, it's a fair expectation if healthcare coalitions – the ultimate force-multiplier – are successfully implemented.
Yes, the successful – and affordable – implementation of the Proposed CMS Emergency Preparedness Rule (the Rule) is invariably linked to the development of effective regional healthcare coalitions.
Without healthcare coalitions, preparedness can be a heavy burden, both economically and by way of staff workload; without healthcare coalitions, preparedness will be done in isolation, one facility at a time; without healthcare coalitions there will be redundant expenses and duplication of effort; without healthcare coalitions, the Rule will likely yield little more than a basket of paper victories.
Maybe the arguments being made against the CMS' projected implementation cost at the White House Office of Management and Budget (OMB) are misguided? Maybe the projections made by CMS assumed regional healthcare coalitions would be there to help the smaller providers and those new to the preparedness table?
Some Washington insiders say that Congress is not a fan of the Hospital Preparedness Program (Now the NHPP). The story goes that on ‘the Hill’ there is a feeling that hospitals and other healthcare providers should not need federal funding to maintain continuity of care when disaster strikes – that preparedness is an ethical and moral responsibility which should be a business priority for healthcare providers.
Hence, the 50% cut in healthcare preparedness funding over the past decade? Despite Congress' reported ideation about healthcare preparedness – and my recent article, 3 Reasons Congress Will Kill the Hospital Preparedness Program in 2017 – most in Washington are confident that the NHPP will be reauthorized with the Pandemic and All Hazards Preparedness Act (PAHPA), and that it will continue to be funded at some level going forward.
That said, most also believe that funding will be dependent upon the Assistant Secretary for Preparedness and Response (ASPR) showing that healthcare coalitions are effectively uniting providers and building a more resilient healthcare system. Metrics will matter.
So, Congress is reluctant to fund a program most believe is a clear provider responsibility. But, simultaneously, there is a sense in Congress that government needs to reduce regulation and get out of the private sector’s way.
Yes, the healthcare sector is predominantly in the private sector and is the subject of much regulation, but there's a valid reason for it. Healthcare facilities are not quite the same as a Chilis Bar and Grill, an AMC Movie Theatre, a Target store, or Bob’s Country Bunker. The difference is that when the healthcare system fails, people suffer, people die. Further, the healthcare system is economically dependent upon the Nation’s largest insurance company, CMS.
And, absent regulatory requirement to do so, few healthcare providers are investing in preparedness. Hence, the necessity for emergency preparedness regulatory requirements.
As I wrote about recently, the Proposed CMS Emergency Preparedness Rule is On the Clock. The Proposed Rule was published in December of 2013 and must be published final in December of 2016 – or the rule-making process starts all again.
Is the Rule In Trouble?
It was Sheri Fink who first reported that the Proposed Rule may be in trouble. In her February 13, 2015 New York Times article, Can Health Care Providers Afford to Be Ready for Disaster, Fink wrote, “[t]he proposed rule, however, appears stalled. Since Nov. 3, it has been parked at the Office of Management and Budget (OMB), undergoing a legally required review.”
She went on to elaborate that an OMB spokeswoman stated that the 90-day review period had been ‘extended.’ Had there been no opposition, the Rule would have been released from OMB and published in the Federal Register the first week of February.
So, is the Rule really in trouble? It depends whom you ask.
When asked about the Rule's status at the Preparedness Summit in Dallas last week, ASPR representatives were somewhat cautious, stating only that they were not hearing it was in trouble, only that it needed to be “tweaked” to accommodate numerous stakeholders. Representatives from the American Hospital Association (AHA) and the Joint Commission have not been as confident that it will make it out of OMB by the deadline, but are admittedly not ‘in the know.’
That said, the AHA has been on the record stating that they are “generally supportive” of the Rule.
There is a general sense that Hospitals – particularly those accredited by the Joint Commission, which has an Emergency Management Chapter in its standards – will have little difficulty meeting the new requirements. It is the hospitals not accredited by the Joint Commission, the little guys, and those new to the preparedness table that will struggle most. And it is the organizations representing these providers that are most at odds with the Rule.
Fink’s reporting unearthed many comments from stakeholders that “feared that the rules would be particularly burdensome for smaller facilities that have traditionally not been involved in emergency preparedness.”
Many of those smaller facilities care for the elderly and disabled and are represented by the American Health Care Association (AHCA). AHCA did not challenge the intent of the rule and has also been ‘generally supportive,’ but has taken issue with CMS’ cost estimates to meet the requirements.
“Medicare’s calculations suggested a relatively modest impact: $8,000 on average for hospitals the year the rule takes effect and about $1,262 each year for skilled nursing facilities,” noted Fink. “But the association said that those figures were unrealistic because of factors like emergency overtime.”
If only there were a way for the smaller providers and those new to the preparedness table to meet the new requirements without breaking the bank? If only there were a way for these providers to be part of a local organization where they could be mentored by those who've been at the table for over a decade?
If only there were a way for them to share cost, effort, and resources?
If only there were a way?
Healthcare Coalitions: The Force-Multiplier
A force-multiplier, when used in the context of healthcare system preparedness, is an attribute or a combination of attributes which make a given provider more efficient and effective than that same provider would be without it. For example, a mechanical ventilator is a force-multiplier because it frees a caretaker from squeezing a bag valve mask to take on additional tasks. One person can now do more in the same time period.
ASPR defines a healthcare coalition as "a collaborative network of healthcare organizations and their respective public and private sector response partners that serve as a multiagency coordinating group to assist with preparedness, response, recovery, and mitigation activities related to healthcare organization disaster operations.”
Yes, a coalition is a collaborative network of healthcare organizations that serve as a multiagency group to assist with preparedness... You know, a healthcare coalition sounds like it could be a force-multiplier. It sounds like it could be an organization that provides a combination of attributes – shared cost, shared effort, and shared resources – that will allow smaller providers and those new to the table to be more efficient and effective than they would be without it. An organization like that could really empower a single person to get far more done in less time than they would without it.
Huh! If there were a national network of of highly effective healthcare coalitions in place, the cost estimates might just be on target?
It almost seems like ASPR’s vision of regional healthcare coalitions is designed to dovetail with the CMS' Proposed Rule? Or is the Rule designed to dovetail with healthcare coalitions? When asked about the synergy, ASPR took the 5th and CMS provided the following statement.
"While we did not propose to require that providers participate in coalitions, we do recognize and support their value in the emergency response system and encourage providers of all types and sizes to engage in such collaborations to ensure better coordination surrounding an emergency event. The primary goal of health care coalitions is to foster collaboration amongst provider types in order to strengthen the overall health system by leveraging expertise, sharing resources, and increasing capacity to respond; thus reducing potential administrative burden for providers."
Either way, it's time for all healthcare coalitions 'set the table' for these new partners. And it all starts with inclusive governance.
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About Karl Schmitt
Karl is the passionate Founder of bParati.com. He is on a mission to align the disaster preparedness programs of healthcare institutions with those of emergency management, public health, and others in the public, private, and not-for-profit sectors who care for the physical, mental, and spiritual health of people each day. Learn more about him here.
He can be reached at firstname.lastname@example.org