Submitted on Wed, 2014-04-23
By Carl Brewer

Citing an urgent public health issue, HHS proposes new and consistent emergency preparedness regulations in over 68,000 healthcare facilities.

New Federal Requirements Aim to Eliminate Healthcare Emergency Response Failure

The U.S. is facing an urgent public health emergency preparedness crisis according to the Department of Health and Human Services (HHS). Even after the hurricanes, tornadoes, and bombings this country has faced in recent years, our local hospitals and healthcare facilities are still not prepared to effectively coordinate an emergency response.

To address this problem, HHS has introduced a sweeping emergency preparedness proposal that will affect more than 68,000 facilities across the country. The proposal is being met with mixed responses from healthcare providers as they are already trying to do more with less in the face of funding reductions. Everyone agrees that there is a strong need for standardized emergency preparedness regulations nationwide, but the costs involved to meet such strict guidelines are prohibitive for most organizations.

Standardizing Emergency Preparedness Nationwide

Rather than simply providing funding for healthcare facilities to meet local preparedness requirements, HHS is taking a new approach to emergency preparedness regulation. The proposal makes emergency preparedness compliance a condition of participation in Medicare and Medicaid programs for healthcare facilities. Non-compliance would have a direct impact on each facility’s funding.

The main reason for the new approach is to standardize emergency preparedness across the country. Traditionally, healthcare facilities have been required to adhere to local regulations for disaster planning. This has created a wide gap in preparedness processes and standardized procedures across the country. Getting all healthcare facilities on the same page will ensure seamless teamwork from a universal playbook regardless of which facilities are working together.

In his essay "A National Strategy: It Is Time for Action", Former Assistant Secretary for Preparedness and Response, RADM Craig Vanderwagen, discussed the need for congress to act upon a national strategy for emergency response. "In the post-9/11 and post-Katrina environment, much attention was paid to the failings of a common operating picture of communication needs and asset movement in the first 48 hours of an event. Our goal is to save lives, reduce the burden of suffering and speed recovery to a new normal after events. Let’s build from the successful efforts of both public and private sector elements to create a comprehensive and actionable information system in medical and public health logistics."

The proposal consistently refers to the aftermath of Hurricane Katrina, where more than 200 people died in hospitals and nursing homes that weren’t sufficiently prepared.

“In New Orleans it seems very likely that dozens of lives could have been saved by competent emergency planning and execution”

Healthcare facilities of virtually every type would be affected by the requirements proposed, from the largest hospitals to organ transplant procurement organizations to home health agencies. Hospitals, nursing homes, and other inpatient facilities will need to be able to maintain emergency lighting, climate control, fire systems, and sewage during a power loss. Not only that, the organizations will need to protect their power sources from floods and other natural disasters. They will also be required to coordinate off-site care and handle volunteers and displaced patients. Home healthcare agencies will need to help each patient create disaster plans and hospices will need to coordinate rescue plans for their patients. The proposal also calls for comprehensive and regular disaster testing.

Proposed Emergency Preparedness Costs

The proposal estimates total costs in excess of $225 million spread across the 68,000 organizations that are expected to participate during the first year, with around $40 million to comply each year after. Hospital will bear the brunt of the costs at an expected sum around $10,000 each during the first year.

Across the board the healthcare facilities are lauding the proposal’s intent, but are wary of the cost. The American Hospital Association said the Department of Health and Human Services“may have significantly underestimated the burden and cost associated with complying with this rule” and the Missouri Hospital Association went so far as to call the costs “draconian”.

The disaster testing in particular is where organizations are worrying about costs. Hospitals in particular are grousing about the high costs of the annual backup generator tests. The yearly four-hour, full-load tests will have much higher costs than the current testing policy of once every three years. Engineering specialists also estimate it could take upwards of a million dollars for a hospital to upgrade its emergency power systems to run air conditioning and other new requirements.

If costs can be contained, this could prove to be a wonderfully effective law. It will help keep the population safer and make it easier for local, state, and federal governments to work seamlessly with every healthcare organization in every nook and cranny of the U.S. A more coordinated and consistent response, is a better response. As Dr. Vanderwagen concludes, “The health and wellbeing of our family, friends and communities demands this effort.”

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