ASCs Must Be Ready for CMS Emergency Preparedness Regs
EXECUTIVE SUMMARY
Ambulatory surgery centers (ASCs) must revise their emergency preparedness policies and processes to reflect new rules by Nov. 15, 2017.
- The Centers for Medicare & Medicaid Services requires all healthcare organizations with Medicare/Medicaid patients to meet the new requirements as part of their conditions for coverage.
- One new rule is for ASCs to check in with their local emergency preparedness officials to ask what they could do to help in the event of a local disaster.
- Another rule requires ASCs to conduct a risk assessment and hold regular disaster drills.
Ambulatory surgery centers (ASCs) might not like facing yet another unfunded burden. The regulations, at least as they apply to ASCs, might not even provide significant benefit to their communities. But the fact is that on Nov. 15, 2017, ASCs that receive Medicare and/or Medicaid patients must have in place emergency preparedness plans that meet all the requirements of new regulations. These are required as part of the conditions for coverage from the Centers for Medicare & Medicaid Services (CMS).
“One of the primary goals of the requirement is to push ASCs to conduct a thorough risk assessment, and that risk assessment doesn’t just span internal emergencies that may occur or external emergencies that affect only the ASC,” says Mary Wei, assistant director of accreditation services at the Accreditation Association for Ambulatory Health Care (AAAHC) in Skokie, IL.
The new rules require ASC administrators to study their communities and check in with local leaders to see what they can do to participate in addressing local disasters, she adds.
“For example, the ASC might be called upon to be a triage center, or to help with providing medical supplies, or they might be able to store equipment,” Wei says. “It depends on the makeup of the community and resources available, and it will differ around the country.”
It is possible surgery centers will be called on for help during an emergency, so it makes sense to be prepared and in close communication with community first responders.
“You should be involved in planning in a community because you may be the one accepting people,” says Patricia Howell, RN, BSN, clinical support manager at McKesson Medical-Surgical in Richmond, VA.
“If there is a disaster, the hospitals, emergency rooms, urgent care centers are a part of it, and we’re maybe number three or four on the list to accept patients,” Howell says. (See story about strategies to improve emergency preparedness in this issue.)
ASCs that do not treat Medicare/Medicaid patients should check state laws to see what type of emergency preparedness is required. For instance, New Jersey requires ASCs to comply with department regulations for ambulatory care centers, says Brendan McCluskey, JD, MPA, CEM, CBCP, director of emergency preparedness and operations at the New Jersey Department of Health in Trenton, NJ.
“There is a subchapter on emergency services and disaster plans,” McCluskey notes.
It is possible ASCs could provide community assistance during an emergency, so long as state and federal regulations are followed, McCluskey says.
“What CMS did with the new conditions of coverage is really outline, ‘Here are our expectations for facilities,’” Wei says. “A lot of the requirements are written such that they’re more or less umbrella requirements.”
But for the latest emergency preparedness regulations, CMS has provided specifics on the type of emergency preparedness plan the agency expects facilities to create, she notes.
According to CMS, the new regulations are necessary because many providers and suppliers have emergency preparedness requirements that do not go far enough in ensuring they are equipped and prepared to protect the people they serve during disasters.
“Over the past several years, the United States has been challenged by several natural and man-made disasters,” CMS wrote in its executive summary. “This final rule issues emergency preparedness requirements that establish a comprehensive, consistent, flexible, and dynamic regulatory approach to emergency preparedness and response that incorporates the lessons learned from the past, combined with the proven best practices of the present.”
One city that has seen more than its share of natural disasters is New Orleans. Hurricane Katrina devastated the area after striking the Gulf Coast on Aug. 29, 2005, bringing with it damaging winds, levee breaches, and catastrophic flooding. In 2007, tornadoes damaged more than 500 houses in the New Orleans area. In February 2017, hail and four tornadoes struck Louisiana, including one that hit New Orleans, upending cars and destroying buildings.
“Living in New Orleans, we have an ongoing disaster plan for hurricanes. That is the reality of our life, and it happens every year,” says Stephanie Danielson, RN, MSN, CNOR, administrator of Crescent View Surgery Center in Metairie, LA.
The four-year-old Crescent View Surgery Center has disaster preparedness plans for tornadoes, thunderstorms, electrical outages, floods, fires, and hurricanes.
Hurricane Katrina changed the way healthcare providers handle disasters, Danielson says. Speaking from her experience working in a hospital at that time, Danielson says hospitals and other healthcare organizations have improved their communication with local first responders.
“Before, we were an island. There wasn’t a lot of communication between hospitals and the sheriff’s office or police, and now we’re all in contact,” Danielson says.
Communication between providers, municipalities, and first responders is a major goal of the new CMS regulations, which require all facilities to institute an emergency preparedness communication plan.
“If ASCs are participating in Medicare, they have to reach out to the community under the new conditions and work with the community to determine if they can be used,” Wei says. “To me, that sounds a whole lot like checking in to say, ‘Hey, this is the kind of facility we have. These are the services we provide. This is the equipment we have. Will you be able to use us in terms of an emergency or community disaster, and how will that happen?’”
Community leaders might answer this by saying there’s no need for an ASC to be part of a disaster plan. “If they turn them down, then they don’t have to participate in the community-wide disaster planning, but they still should conduct their risk assessment,” Wei says.
During the risk assessment, a surgery center might learn that it has a resource that could be of great use to the community, such as a powerful generator. In this case, it would be helpful to contact the local emergency preparedness coordinators and offer this resource to be used for the next disaster, she says.
“I’m not saying they would be required to do that, but certainly a facility could determine through their own risk assessment that this is the kind of thing they’d like to do,” she says.
One of the key changes is the CMS requirement that ASCs set up training and testing for their now-revised or new comprehensive emergency and disaster plan that is based on a risk assessment analysis.
“Testing means drills, and AAAHC standards have required them to do that for a while, with scenario-based drills,” Wei says. “The requirement is for training staff members and testing the process through drills so they know if it works, and there are also requirements for a communication plan.”
Each facility must create a plan for contacting patients, staff, and key local and state emergency preparedness officials.
ASCs that are accredited by AAAHC likely have solid risk assessment policies and procedures.
“We are AAAHC-accredited, and they have a ton of resources for how to get your risk assessment in order,” Danielson says. “We have a template for a risk assessment that we adapted to what made the most sense to us.” CMS also has technical resources to help organizations find a risk assessment format that works for them, Wei says.
“There is a lot of information on the CMS website about training staff, risk assessment, and hazard vulnerability analyses,” she says. “They show the things that have worked for other facilities.”
For example, CMS developed a six-page emergency preparedness checklist to assist healthcare organizations with emergency preparedness planning. These are some of the task headings: Develop emergency plan; All hazards continuity of operations plan; Collaborate with local emergency management agency; Analyze each hazard; Collaborate with suppliers/providers; Decision criteria for executing plan; Communication infrastructure contingency; Develop shelter-in-place plan; and Develop evacuation plan. (The checklist can be found at: http://go.cms.gov/2rIFIxN.)
With these public resources available, ASCs could conduct their own risk assessments and write their own emergency preparedness plans. They also could hire professionals for this job, but it’s their choice, Wei adds.
Ambulatory surgery centers might not like facing yet another unfunded burden -- but the fact is that on Nov. 15, 2017, ASCs that receive Medicare and/or Medicaid patients must have in place emergency preparedness plans that meet all the requirements of new regulations.
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