The New CMS Rule: for the Sake of the PATIENT!

James Buttleman, December 28, 2017

Naturally, helping and protecting patients is the very foundation of healthcare.  In fact, providers routinely assist patients who are in dire circumstances.  But when an especially bad situation unfolds at a much larger scale, it can transcend a case-by-case patient medical emergency into a full-blown community disaster.  This requires a whole new level of crisis management.  For this reason, healthcare organizations must take special measures to be ready for the worst-case scenario.

To compel such action, the Center for Medicare and Medicaid (CMS) unveiled its new Emergency Preparedness requirements in November of 2016.  Healthcare facilities regulated by CMS are now required to demonstrate their ability to meet these new requirements during their regular site surveys.  It’s a tall order for many, since the activities required by the new rule are somewhat foreign to many organizations.  The requirements also vary by provider type.  How can we make sense of it all?  To begin, we might sum up the new requirements by turning our attention back to what healthcare is rooted in, at the most fundamental level: the PATIENT.

 P | Preparedness.  This involves a variety of different elements and activities, including development of plans, organizing teams and equipping them appropriately, providing staff training, conducting drill and exercise, and making continuous improvements.  Preparedness is a regular, ongoing process – not a one-time effort!

 A | Accountability.  The new requirements include measures that organizations must take to maintain accountability of all patients, visitors, and records under their care during and after a disaster.  This is a challenge that requires careful planning and preparation.

 T | Training.  An essential element of any preparedness program, staff members must regularly participate in training to build and maintain their knowledge and skills.  Team members need to be understand what the organization’s emergency plan entails, how to activate an internal command center, their roles as members of the facility’s incident management team, and much more.

 I | Incident.  In emergency management, a crisis that rises to the level of posing a significant impact on the organization is called an incident.  An incident could be the result of severe weather, a utility failure, an attack by an active shooter, a major outbreak of disease, or any of various other threats and hazards.  Organizations must prepare for a multitude of types of incidents, under the “all-hazards” approach.

 E | Exercises.  Drills and exercises enable organizations to periodically test their state of preparedness, to see if they are optimally ready for real-world emergencies.  CMS requires that organizations participate in at least two exercises per year.  This is essential, because the lessons learned from these efforts drive the process of continuously enhancing an organization’s state of preparedness.

 N | National Incident Management System.  NIMS is the foundation for all emergency preparedness programs.  This is the nationwide platform that outlines how an organization should respond to a critical event to, including how the organization will work together most effectively with other entities in the community and beyond.

 T | Time.  For preparedness, as it is for so many other pursuits, time is of the essence.  Costly disasters occur every day, taking a toll on life, property, and the environment.  This is why CMS has green-lighted this important new rule.  Now that these requirements are in place, it is crucial for healthcare organizations to invest the time necessary to become prepared.

 Indeed, with the new rule now in effect and surveyors carefully scrutinizing adherence to these requirements, the time has come for healthcare organizations to be more prepared than ever.  For the sake of the facility.  For the sake of staff members.  And certainly, for the sake of the PATIENT.

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