May 10, 2021 | | Comments 0
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You better? You bet!

It would seem that while the rest of the world has been busy responding to a pandemic, the folks behind the scenes have been working on identifying the lessons learned and memorializing them in an update to Appendix Z. At first glance, it seemed that this was more a codification of past updates, but as a I looked through the thing in its entirety, it does seem like the changes are more significant/substantive than I thought. That said, I do think that much of the updated material is aimed at helping surveyors to understand what is (and what is not) actually required and that, as with everything in our world, customization of approaches, etc., is not only desirable, but is really the only way to “roll” when it comes to appropriately preparing to respond to an(y) emergency. I suppose one could make the case that, after all of this hoo-hah of the past year-plus, if we’ve not managed to improve our preparedness, then what exactly have we been doing?

Part of the dynamic I keep coming back to with all this is if it were “business as usual,” then it wouldn’t be an emergency. And one of the defining aspects of an emergency is that it tends to push the normal limits of an organization. I remember the hue and cry that went out immediately following Superstorm Sandy’s trek up the East Coast regarding the level of hospital preparedness—because people struggled at the outset. But when the final report from CMS was issued, it turned out that hospitals generally did what they had to do to keep patients and staff safe.

As we look back at the past 18 months or so, I suspect that each organization within the sound of my voice is better prepared than previously for managing the impact of a long-term pandemic event. I also suspect that there have been any number of improvement opportunities identified and I am hopeful that, among other things, your organizational leadership has gained a greater appreciation for emergency preparedness as a proactive undertaking (recognizing that response is typically characterized by reactivity). The truth of the matter is this: while emergency preparedness does not, in and of itself, generate revenue. Effective emergency preparedness allows an organization to continue generating revenue while the feces is striking the rapidly rotating blades—and that makes all the difference in the world.

I suspect that this is going to take a couple of sessions to work through some of the subtleties of the updates, so I would encourage you to start chipping away at this as wander through the very merry month of May. There is a lot of material to digest and while I don’t see anything that’s making me crazy from a survey prep standpoint, I’ll let you be the judge of how that shakes out—at least for the moment.

Before I close out this week’s chat, I did want to tip you to one resource that I think will be really helpful. One of the more painful aspects of the Emergency Preparedness Final Rule has been that the official document that is Appendix Z is designed to include the requirements for all provider types, which makes an already complex set of rules that much more confusing. But someone (bless them, whoever they are) worked to peel out the requirements for each provider type, so if you’re not a “regular” hospital or you have operational responsibilities for more than one provider type, you can find the specifics for each here. There are other resources as well, but just having the requirements by provider type is (at least to me) crazy wonderful—and I hope you think so too.

Next week, we’ll chat about some of the ways in which organizational leaders are going to be looped into this on an ongoing basis—if that doesn’t sound like fun…

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Steve MacArthur About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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