On December 27, 2013, the Centers for Medicare & Medicaid Services released a proposed rule that would add emergency preparedness requirements to the conditions of participation for various program participants, particularly hospitals, long term care facilities, and ambulatory surgical centers.
One requirement of the disaster planning described in the proposed rule particularly caught my eye: risk assessment and planning. It sounds almost self-evident that, first, each facility should assess its risk and identify the most likely threats to operational integrity.
After Katrina, the failure of a number of health care facilities to assess the risk of a flood whose high water mark would likely render ill-situated basement emergency generators inoperable has been made manifest. In hindsight, the story of New Orleans' Memorial Medical Center's 101 page bioterrorism plan and 11 page hurricane plan is being told all over our nation via Sheri Fink's Five Days at Memorial.
Interestingly, Fink's book probed the disaster preparedness committee at New Orleans' Memorial Medical Center about its work. From what she recounts, it seems likely they misunderstood their assignment unless, of course, they understood it all too well. They measured present preparedness against recent past performance, apparently unconcerned with looking at the likelihood of floods at or near historic levels or, even, at or near levels outside the living memory of anyone currently on staff. Instead, they dutifully prepared for a bio-terrorism attack and checked off their self-assessed very highest level of readiness for a major hurricane.
Fink does a reasonably good job of considering why the disaster preparedness work at Memorial and elsewhere could be both so strangely truncated and oddly self-re-enforcing. Along the way she teaches the reader a few things about hospital accreditation in the United States.
Hospitals are licensed by the government but such licensing regimes are typically an exercise in governmental deferrence to what was then called the Joint Commission on Accreditation of Healthcare Organizations (now known simply as the Joint Commission). JCAHO's new to the time emergency standards emphasized just what the Memorial disaster preparedness committee did.
Hospital accreditation is a story of regulatory capture writ large. CMS's current attempt to use the conditions of participation requirements to turn the tide in this one way should be interesting to watch.
Oh, and the disaster preparedness committee also indicated they were completely ready for volcanic activity at Memorial. Good to know.
x-posted at Prawfsblawg: http://prawfsblawg.blogs.com/