About that High Emergency Preparedness Rating…

by James A. Bacon

It is entirely appropriate during a crisis like the COVID-19 epidemic for elected officials to urge calm. Panic often leads to counter-productive behavior. At the same time, it is important not to instill a sense of false confidence, which could engender complacency. Finding the right balance is difficult.

Governor Ralph Northam assured the public that the Commonwealth is well prepared for health emergencies. Virginia’s emergency preparedness, said the Governor last week in comments that Virginia Hospital and Healthcare Association chairman Michael P. McDermott echoed yesterday, is ranked in the “high performance tier,” according to the Trust for for America’s Health.

“The Virginia Department of Health has some of the country’s leading public health experts on his team, with deep experience guiding public health emergency responses, and I have great confidence in their ability to guide Virginia in this situation,” Northam said.

It is true that the Trust for America’s Health gave Virginia high overall scores for public preparedness. But what does that mean? There are many kinds of public health emergencies — hurricanes, floods, terrorist attacks, breakdown of the electric grid… and the list goes on. How well is Virginia prepared to handle pandemics?

Go read for yourself the Trust for America’s Health Report, “Ready or Not 2020: Protecting the Public’s Health from Diseases, Disasters and Bioterrorism,” 1As it turns out, the “high performance tier” is not exactly an elite group. Twenty-five states and Washington, D.C. qualify for that rating.

Here are then 10 criteria used to compile the rating, along with the relevant Virginia metric:

Nurse licensure compact. State participated in N.C. compact (2019). (This compact permits registered nurses and licensed practical nurses to practice with a single multistate license in any state that has joined the compact.)

Hospital preparedness: 100% of hospitals participated in health care coalitions (2017).

Public Health Accreditation Board accreditation: Virginia is accredited.

Emergency Management Accreditation Program: Virginia participates.

Public health funding: 4% increase in FY 2018-19.

Water security: 2% of population who used a community water system in violation of health-based standards (2018).

Paid time off: 58% of employed population with paid time off (2018). Paid time off allows sick workers to continue getting paid if they stay home.

Seasonal flu vaccination: 54.7% vaccination rate for people 6 months and older (2018-19).

Patient safety: 56% of hospitals with an “A” grade (fall of 2019).

Public health lab capacity: Yes, public health laboratories had a plan for a six- to eight-week surge in testing capacity (2019).

So, how relevant are these criteria? A high rate of seasonal flu vaccination doesn’t do anything to protect against COVID-19. On the other hand, a high percentage of workers with paid time off is a plus in containing the coronavirus spread. In theory, sick workers are more likely to stay at home if they know they will be paid, thus avoiding infecting co-workers. Also reassuring is that fact that Virginia hospitals get a high rating for “patient safety,” which entails, among other factors, preventing secondary infections.

As for public health labs having plans for a six- to eight-week surge in testing capacity, Virginia still lacks that capacity. The latest wrinkle, according to The Virginia Mercury, is that Virginia health authorities are urging patients who don’t meet the state’s risk assessment to pursue testing through private labs.

“Currently there are limited numbers of tests available, but we have more today than we did yesterday,” said Dr. Lilian Peake, Virginia’s state epidemiologist, at a news conference Wednesday.

The Trust for America’s Health does not give any consideration to a critical issue that I have highlighted in other posts: the capacity of hospitals to handle a surge in patients.

Perhaps I am being unfair — and I would love to get other viewpoints — but the Trust for America’s Health rating does not seem to be terribly relevant to the crisis at hand.

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9 responses to “About that High Emergency Preparedness Rating…”

  1. sherlockj Avatar

    Jim Bacon asked if it is unfair to question the readiness of Virginia’s hospitals. Of course it is. There is reason to hope because of the programmatic and inspection requirements of the Centers for Medicare/Medicaid Services. We will find out how human frailty enters into it after this is over, but the baseline rules are there and medical facilities are inspected to ensure compliance.

    The CMS Emergency Preparedness Rule is available at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule
    “Purpose: To establish national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters, and coordination with federal, state, tribal, regional and local emergency preparedness systems. The following information will apply upon publication of the final rule:
    – Requirements will apply to all 17 provider and supplier types.
    – Each provider and supplier will have its own set of Emergency
    Preparedness regulations incorporated into its set of conditions or requirements for certification.
    – Must be in compliance with Emergency Preparedness regulations to participate in the Medicare or Medicaid program.

    Pandemic response preparedness is on the list of inspection criteria. Compliance is required for participation in Medicare.”

    The 17 categories of facilities impacted by CMS emergency preparedness rules and subject to inspection on these rules are:
    1. Hospitals
    2. Religious Nonmedical Health Care Institutions (RNHCIs)
    3. Ambulatory Surgical Centers (ASCs)
    4. Hospices
    5. Psychiatric Residential Treatment Facilities (PRTFs)
    6. All-Inclusive Care for the Elderly (PACE)
    7. Transplant Centers
    8. Long-Term Care (LTC) Facilities
    9. Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)
    10. Home Health Agencies (HHAs)
    11. Comprehensive Outpatient Rehabilitation Facilities (CORFs)
    12. Critical Access Hospitals (CAHs)
    13. Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services
    14. Community Mental Health Centers (CMHCs)
    15. Organ Procurement Organizations (OPOs)
    16. Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
    17. End-Stage Renal Disease (ESRD) Facilities.

    If you wish to see what the rules require go to https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107ap_z_emergprep.pdf

    It is also fair to point out that the National Strategy for Pandemic Influenza Implementation Plan for other than healthcare organizations was signed by President Bush in 2006 was perfectly predictive and perfectly prescriptive of and for the COVID-19 issue. It was developed for the avian flu. If federal, state and local institutions have followed those guidelines, we are in good shape. If they did not, we may find out. My point is that the steps to take are not new and they are not rocket science.

    1. djrippert Avatar

      If this is all true then why did Seattle have to buy a motel to treat infected people?

  2. sherlockj Avatar

    It’s all true. The after action report will have to sort out what went wrong in Seattle. Lead a horse to water type of thing.

  3. LarrytheG Avatar

    This is good Jim. It makes one realize that there already is a significant structure that has been in place all along and most of us know little about it.

    but it’s one thing to have backup / alternative facilities – and having the staff to staff them.

    This is going to be a time when nurses and other para-medical folks and perhaps even willing volunteers are going to become indispensable heroes.

    1. djrippert Avatar

      I’ve been thinking about the volunteer situation. It’s tricky. I’d guess that you wouldn’t want young people volunteering because … well they’re young and have long lives ahead of them. You can’t have older people because, after 40, they get much more likely to die from the disease. The “sweet spot” might be 25 – 40. But most people of that age are working. So, what I’ve been thinking about is a job swap. Theoretically, someone like me could drive a garbage truck so that the 35 year old garbage truck driver could volunteer in a hospital. The garbage removal company would still pay the original driver so I’d be the volunteer. Thoughts?

      1. sherlockj Avatar

        One thing we can do is take care of our elderly and infirm neighbors. Make the calls and make sure they have enough food and provisions. Pick up their meds for them. Use your computer to do things for them like order online that they may not have the skills to do for themselves. Those sorts of thing. We can do all that and maintain social distancing so that we don’t put them or ourselves at risk.

      2. LarrytheG Avatar

        well maybe not. Some people will be out of work during a pandemic.

        All those sports service people will be “free” … right?

  4. sherlockj Avatar

    You are right. Re-Read my column about the doctor and nurse shortages in Virginia. I hope we don’t need more than we have, but we’ll see. I am as much as a skeptic as anyone about the healthcare system in Virginia, but I am only trying to improve it. I pray for its success. Foxhole buddies.

  5. LarrytheG Avatar

    I think a good part of the question – “do we have enough” is to add “for what”?

    Normal day to day operations ?

    emergencies and disasters?

    they’re really two different things.

    the former needs to have some sort of metrics that tell us that we do not have “enough”. what are those metrics? How do we know what the “right” number of hospital staff are ?

    ‘the second is how do we add more staff when emergencies and disasters occur?’ And part of that is whether the event is local or regional or national.

    Power Companies like Dominion will send workers to other areas that have had disasters and other regional electric providers will send workers here if we have a disaster.

    That ought to work for local/regional disasters but what happens if it is a national emergency beyond having existing staff work longer hours?

    We just can’t have trained and paid staff sitting by in “standby” mode – although that’s exactly what we do with fire and rescue.

    So what’s the answer? Is there one – for national-scope emergencies?

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