Experts believe 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. Long-term care and hospice facilities, as well as ambulatory surgical sites, home health agencies and dialysis centers, would face "a much heavier lift," she 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 healthcare emergency management consultancy.
The CMS estimates the total cost for providers to adhere to the rule would be more than $370 million annually.
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-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 located in states with frequent earthquakes or violent storms are already mandated to have emergency plans in place that call for coordination with first responders. Most other long-term care providers have focused on being self-sufficient.
Montgomery also wonders whether emergency response agencies could even help or coordinate with long-term care facilities given their number. The U.S. has more than four times as many nursing homes as hospitals.
Calls to several emergency response agencies were not returned.
Montgomery 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."