As the floodwaters left by two major hurricanes recede in Texas and Florida, skilled nursing operators across the U.S. are battening down the hatches before the emergency preparedness rule from the Centers for Medicare & Medicaid Services (CMS) hits in November. And although the end goal is clear, the total costs aren’t always so easy to determine.
The rule mandates that heath care providers across 17 settings must have an all-hazards emergency plan with related policies and procedures; follow a communication strategy that adheres to federal and state laws and includes other area providers; and implement adequate training programs and drills, all by Nov. 15.
Since the rule’s finalization one year ago, many providers have already done much of the work required for compliance. Additionally, some operators in Texas and Florida have even had their emergency plans tested in real conditions with hurricanes Harvey and Irma.
The price of preparedness
The financial cost of preparing for the current November deadline depends on many factors—some that are in a provider’s control, and some that are not.
Providers have less work to do—and therefore less to pay for—if they reside in a state that already requires emergency planning, Sharon Harder, president of management services firm C3 Advisors, tells Skilled Nursing News.
“For those organizations, it will be easier, and a bit less time consuming, to come into compliance with the federal rule because they are likely to already have some of the emergency preparedness planning elements in place,” Harder says. “Cost will vary depending on location, the types and volume of risks that must be assessed, and the degree to which an agency has access to local emergency preparedness resources.”
Partnerships are key: For instance, providers that connect with local health care coalitions that cooperate during emergencies can share the financial burden of planning.
By contrast, operators that didn’t already get a head start or are going it alone likely have more they need to do, says Nicolette Louissaint, executive director of Healthcare Ready, an organization that supports access to health care during emergencies or disasters through public and private collaboration.
“The price tag of the preparedness activities will be higher if you are doing it in a silo,” Louissaint tells SNN. “It’s hard to put a dollar amount on it because personnel rates can be different, available resources can be different.”
Emergency preparedness compliance could cost thousands of dollars or tens of thousands of dollars, depending on how much work a provider needs to do, Louissaint says.
The most expensive part of the process is testing and going through exercises, which only gets pricier if a health care provider does it alone.
But the biggest cost might not lie in planning at all, according to Harder. Instead, the greatest risk lies in the fines that CMS might levy if it determines a health care provider is non-compliant.
“In my view, the most significant financial pitfall associated with this requirement is the potential fallout of ignoring the need to implement an emergency preparedness program that meets the conditions of participation,” Harder says. “Agencies will be surveyed on the degree to which they have complied and those that are not able to demonstrate compliance during a survey could face significant financial penalties and sanctions.”
Not a burden for some
For PruittHealth — a provider that offers skilled nursing, home health care and assisted living services throughout the Southeast U.S. — much of their emergency preparedness work is already done.
To date, the Norcross, Ga.-based provider has spent thousands of dollars on emergency preparedness, which includes things like distributing emergency generators and cots, stockpiling supplies like blankets and toiletries, and paying for employees to travel to training exercises.
All of those costs can add up, Natasha Brown, director of policy management at PruittHealth, tells SNN.
“I think it is expensive to do this. I would be fooling myself if I said it’s not,” Brown says.
Still, for Brown, who was hired several years ago to oversee PruittHealth’s emergency planning, the costs weren’t unreasonable or too much to handle.
“I think, as with anything, it could be burdensome depending what the situation is,” Brown says. “However, we have not encountered any of that as of yet.”
PruittHealth has conducted its own hazard vulnerability assessments and worked within a health coalition for about five years now.
“By the time CMS came out with these regulations…I feel like we were well-prepared,” Brown says.
The provider has also been tested with a real crisis before—and it came out on top. When Hurricane Matthew hit the Southeast U.S. last September, Pruitt was successfully able to supply its own transportation without having to rely on public emergency resources.
“That’s how we moved all of our residents to receiving facilities,” Brown says. “We were able to send staff with them…to stay within the PruittHealth family.”
Like PruittHealth, other skilled nursing providers shouldn’t look at emergency preparedness as a financial burden. Instead, they should focus on the rule’s purpose, which is vitally important, Louissaint says.
“The rule’s genesis is to make sure that, in the situations like we’re in—where we are seeing with unprecedented, back-to-back monster hurricanes—we’re…prepared and able to protect patients,” she says.
Written by Tim Regan