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CMS To Healthcare Providers: Don't Wait On Us!

CMS To Healthcare Providers: Don't Wait On Us!

The Center for Medicare and Medicaid Services (CMS) is warning healthcare providers and suppliers subject to the new Emergency Preparedness Rule that they must meet the requirements of the training and testing program by the implementation date, November 15, 2017. And hiring a consultant cannot alone address the challenges of meeting the requirements.

You see, no a paper victory developed by a consultant can engage a region's healthcare, emergency management, public health, and EMS systems. The affordable, effective path forward requires providers and suppliers to get help from multi-disciplinary regional healthcare coalitions to share the cost of hiring the right consultants to help all efficiently and effectively come into compliance. Yes, healthcare coalitions can deliver shared cost, shared effort preparedness opportunities.

Bottom line: preparedness done one facility at a time will bury providers and suppliers beneath an unbearable administrative burden and excessive cost. Not to mention, if a provider or supplier goes it alone, how would they connect with the broader community to participate in regional risk assessments, full-scale community-based exercises, and shared training opportunities? They can't.

CMS Rule Needs Healthcare Coalitions

Here's a few resources to help you better understand healthcare colaitions:

The Memorandum

CMS' Director of the Survey and Certification Group issued the memorandum March 24th, Information to Assist Providers and Suppliers in Meeting the New Training and Testing Requirements of the Emergency Preparedness Requirements for Medicare & Medicaid Participating Providers and Suppliers Final Rule, in response to repeated questions from providers asking whether they will be expected to have completed the "exercises" per the training and testing requirements in each standard (d) of the Final Rule, by the implementation date.

The answer is yes, and CMS is not just referring to the training and testing requirements. The memo makes it clear that beginning November 15, 2017, all affected providers and suppliers must meet all applicable requirements of the rule, and that waiting for interpretive guidance is not a good strategy. "We realize that some providers and suppliers are waiting for the release of the interpretive guidance to begin planning these exercises, but that is not necessary nor is it advised," states the memo. "Providers and suppliers that are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance."

Ouch! Tough talk. But, when it comes to exercises, what constitutes non-compliance?

The Exercise Question

The memo specifically targets one of the more challenging requirements of the rule – full-scale, community-based exercises. You see, unlike facility based exercises, which can be met by adapting the run-of-the-mill fire drill, full-scale, community-based exercises require providers and suppliers to get "off campus" to work with emergency management, public health, EMS, and the region’s other healthcare providers and suppliers. And that's a lot more work – unless the regional healthcare coalition is out front delivering shared cost, shared effort training and exercise opportunities.

That said, CMS recognizes that such exercises require others to play, which is not always possible. "While providers and suppliers are encouraged to partner with local and state emergency agencies and health care coalitions to conduct full-scale community exercises, not all agencies and coalitions will have the ability or resources to engage with all providers and suppliers,” states the memo. "Therefore, we understand that a full-scale, community-based exercise may not always be possible for some providers and suppliers.”

Simple enough, right? It's just "strongly encouraged," right?

"In such cases, we expect those who have been unable to complete a full-scale exercise by November 15, 2017 to complete an individual facility-based exercise and document the circumstances as to why a full-scale, community-based exercise was not completed." And when they say documented, they do not mean jotting down, "We tried." CMS requires that “[t]he documentation should include what emergency agencies and or health care coalitions the provider or supplier contacted to partner in a full-scale community exercise and the specific reason(s) why a full-scale exercise was not possible."

So, what does this mean? Well, right or wrong, it depends on which assessor shows up at the door. Maybe they’re one of those detail folks that will eat you alive, maybe not. Maybe they're in a good mood, because they’re leaving the next day for a week-long vacation at the beach. Then again, maybe they're a bit ornery, because they had a fight with their spouse that morning, their dog ran away, and they dinged their car in the parking lot. Human nature is what it is.

So, to be safe, maybe it'd be best to consider "strongly recommended" and "should" to be “must,” and act with a sense of urgency. Then, if all falls through with the regional healthcare coalition and the local emergency manager – document, document, document. Due dilligence and documentation may go a long way toward overcoming the ornery assessor.

Here's a few resources on bParati.com to help you better understand the requirments of the new CMS Emergency Preparedness Rule and the supporting programs an capabilities:

Find Help

So, where's you healthcare coalition? With approximately 400 coalitions across the Nation, all providers and suppliers should have one available to them. If you are unsure how to connect with your healthcare coalition, give me a call. If I don’t know who leads yours, I’ll find out and put you in touch.

Number of Healthcare Coalitions By State

And if you are a healthcare coalition leader who has providers and suppliers suddenly coming out of the woodwork and know your organization's not ready to engage them and meet their needs, join us at the Tampa Healthcare Coalition Development Workshop. It's a great shared cost, shared effort opportunity for coalition leaders. Can't make it to Tampa? Give me a call and I'll come to you.

Karl Schmitt, MPA

Karl Schmitt, MPA


Karl is the Passionate Founder & CEO of bParati. He is on a mission to build a national network of effective, sustainable healthcare coalitions. More...

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In all we do, we seek to reduce human suffering and loss of life caused by disasters.

We get it done by connecting the preparedness efforts of healthcare organizations, emergency management agencies, and public health departments through effective, financially self-sustaining healthcare coalitions.

Yes, we believe healthcare coalitions are the path forward.

Karl Schmitt, Passionate Founder & CEO, bParati

Karl SchmittPassionate Founder & CEO

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