In the aftermath of two major hurricanes, home health agencies across the U.S. are racing to comply with the new emergency preparedness rule from the Centers for Medicare & Medicaid Services (CMS) before November’s deadline. But many are finding that the associated costs aren’t so easy to nail down.
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 by Nov. 15.
Since the rule’s finalization one year ago, many agencies, such as Baton Rouge, Louisiana-based Amedisys (Nasdaq: AMED), have already done much of the work required for compliance. Additionally, some providers 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 an agency’s control, and some that are not.
Providers already 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 Home Health Care 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.”
Providers already collaborating with a local health care coalition, or a network of health organizations that cooperate during emergencies, are able to share the financial burden of planning.
By contrast, agencies 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 Home Health Care News. “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 between thousands of dollars and 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 an agency does it alone.
“There are more than 400 health care coalitions in the country that home health agencies can become a part of,” Louissaint says. “That would be the best way to engage.”
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 home health care, skilled nursing and assisted living services throughout the Southeast U.S., much of their emergency preparedness work is already done.
To date, the Norcross, Georgia-based provider has spent thousands of dollars on emergency preparedness, which includes things like making sure there are emergency generators and cots on hand, stockpiling supplies like blankets and toiletries, and paying for employees to travel to and take part in training and exercises.
All of those costs can add up, Natasha Brown, director of policy management at PruittHealth, tells HHCN.
“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 prepare PruittHealth for any emergency that might occur, 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 government 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 home health agencies 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.”
Written by Tim Regan