After Hurricane Katrina in 2005, Amedisys decided it needed to upgrade its disaster plan. The national home healthcare and hospice provider began conducting risk analysis and factoring in local potential hazards to develop a plan to ensure staff and residents at its U.S. facilities could weather natural disasters. From this came several changes: greater coordination with first responders, regular drills and closer collaboration with other Medicare providers.
The plan, which calls for sending disaster response teams to check in on patients at home and bringing them food, water and cleaning supplies, was implemented during last year's floods in Louisiana. The plan helped keep Amedisys staff and residents safe.
But now Amedisys and other providers like it are being asked to step up their efforts. Many of the nation's healthcare providers are facing a deadline to implement new federal requirements that standardize how they handle natural disasters and terrorists' threats.
In September, the CMS finalized a rule requiring 17 types of healthcare providers to set new policies that result in better coordination with emergency personnel and frequent tests and adaptations of emergency plans.
While most experts support the regulations, others worry that many facilities, especially small and rural ones, will fall short on meeting the requirements. That could mean providers would be dropped by Medicare and Medicaid.
"I do not see how all facility types can and will be in compliance by Nov. 15," said Denise Braun, senior manager for healthcare solutions at Evans Inc., which is advising healthcare organizations on their emergency preparedness plans.
For some facilities, it means making widescale changes.
And because the CMS didn't offer much clear direction in the requirements, Montgomery said many stakeholders may be non-compliant. The CMS in October said it would publish its guidance on the rule by this spring. But that hasn't yet arrived.
"The beauty of writing the regulations so that they can be interpreted a number of ways is that they let providers be able to work that out for their unique situation," said Jocelyn Montgomery, director of clinical affairs at the California Association of Health Facilities.
Experts feel providers who already meet the Standards of Care for Disaster Preparedness and Response set by the Joint Commission should be well-positioned to meet the new CMS regulations.
"I think hospitals themselves feel like they're in better shape in terms of coming into compliance because of that leg up," said Nancy Foster, vice president of quality and patient safety for the American Hospital Association.
But long-term care and hospice facilities, as well as ambulatory surgical sites, home health agencies and dialysis centers, would face "a much heavier lift," Foster said.
"They are the ones that are absolutely in a uphill battle to be in compliance," said Scott Aronson, a principal with Russell Phillips and Associates, a leading emergency management consultant for healthcare providers.
Costs vary, but the CMS estimated the total cost for providers to adhere to the rule would be more than $370 million for the first year and $370 million every subsequent year.
The preparation requires input from local public health departments, acute-care hospitals, and police and fire departments. By Nov. 15, nursing homes must conduct a multi-agency, multi-jurisdictional disaster exercise that includes drills with multiple emergency response agencies .
"For some hospice providers, that's going to be a challenge in forming those relationships," said Jennifer Kennedy, senior regulatory and quality director for the National Hospice and Palliative Care Organization.
Facilities in states with frequent violent storms and earthquakes are already mandated to have emergency plans in place that call for coordination with first responders. But most other long-term care providers have focused on being self-sufficient.
"Our charge has always been to make sure our residents are safe, sustain our services through the event, and to not put an extra burden on the local healthcare resources," Montgomery said.
She also wonders whether emergency response agencies could even help or coordinate with long-term care facilities given how many there are. There are more than four times the number of nursing homes in the U.S. than hospitals.
Calls to several emergency response agencies were not returned.
"This is not something that the response community is prepared to really do for us," Montgomery said.
She adds that some facilities are waiting for the CMS' guidance to start crafting plans. Other providers hope the agency will extend its deadline.
But the CMS said one year of preparation was more than enough.
"Some thought Medicare was not going to take this too seriously," Braun said. "I think that's a dangerous attitude to take."