Mississippi Rural Health Association

By Ryan Kelly –

With the recent hurricane hitting the East coast of Texas and another heading straight for Florida this weekend, it is a sober reminder of why we need some measure of emergency preparedness guidelines and procedures.

The MRHA recently sent tools and resource for members to access and a summary of the guidelines that will be enforced for RHCs and FQHCs beginning November 15, 2017.

The following represents these new guidelines.  Resources available to you to help meet these needs is located below.  Remember that regardless of guidelines or requirements, it’s always a good idea to know how your facility can / should be part of a holistic plan of disaster management and recovery in your community!

Emergency Plan §491.12 (a)

The first step to creating an emergency preparedness plan is to create what CMS calls an “all hazards approach” to emergency preparedness. An “all-hazards approach” to emergency planning focuses on the preparedness of providers for a full range of emergencies. This could mean preparing for natural disasters or considering risks around the area of a RHCs. CMS leaves it up to RHCs to develop their own process for creating a risk assessment. However, CMS does expect that the participation of all staff including an administrator, physician, a nurse practitioner or physician assistance and a registered nurse to be involved in assessing the risk of the RHC.

The plan must include strategies for addressing emergency events identified by the risk assessments and identify what services the RHC would be able to provide during an emergency.

Finally, the emergency plan should include a process for cooperation with local, state and federal emergency preparedness officials in a case of an emergency. The regulations specify that the RHC should document attempts to contact such officials for certification purposes.

It is important to note, that unlike hospitals CMS did not require RHCs to have a system to track the location of staff and patients in the facility’s care during and after emergency (although the regulations do seem to contradict themselves a bit in §491.12(c)(4). Furthermore, RHCs do not have to provide for basic subsistence needs for staff and patients.

Policies and Procedures §491.12 (b)

After an RHC creates an emergency plan, RHCs must then develop policies and procedures to address possible emergencies. RHCs must plan for safe evacuation from the RHC which includes the appropriate placement of exit signs and responsibilities of staff members.

There must be a way to shelter in place for people who remain in the facility. RHCs must also preserve their medical documentation. Finally RHCs must have a plan to use volunteers and other emergency personnel during an emergency.

Communication Plan §491.12 (c)

RHCs must develop and maintain an emergency preparedness communication plan. The plan should comply with federal and state laws and must be updated at least annually. The communication plan must include all relevant contact information and alternative means of communicating with staff and local emergency agencies.

The RHC must also have a way to provide information about the condition and location of the patients in the clinic at the time of the emergency. Finally, an RHC must have a way to indicate their needs and ability to provide assistance to the emergency authority.

Training and Testing §491.12 (d)

RHCs must develop and maintain a training and testing program based on the risk assessment, emergency plan and communication plan. This training program must include a documented initial training with all new and existing staff which is performed annually.

Furthermore, RHCs must test their emergency plan at least annually. CMS will consider a plan properly tested if the RHC performs and analyzes either two full scale community based exercises or one full scale community based exercise and a tabletop exercise.

Integrated healthcare systems §491.12 (e)

It is important to note that under this regulation there is an option to develop an emergency preparedness plan as an entire health system or independently as an RHC. If an RHC is part of a healthcare system it may elect to participate in the healthcare system’s coordinated emergency preparedness program instead of creating their own.

Resources Available to You

The Mississippi Rural Health Association has been working with clinics to help them meet these new demands.

MSDH Emergency Management Contacts

We encourage you to contact your respective emergency management contact in the Mississippi State Department of Health.  These contacts may be found on the Association resource page by clicking here.  This map will show each individual contact per public health area, and these contacts may assist you in navigating many of the direct contacts needed for policy implementation.

Two Rivers Emergency Management

Second, the Association has negotiated a service with Two Rivers Emergency Management.  They are a professional consulting firm that can assist you in developing and sustaining and emergency preparedness plan.  The following is the direct contact information for Two Rivers:

Two Rivers Emergency Management

Mr. Michael Morlan, CEO

866-755-8736

http://www.tworiversem.com

On-Demand Webinar

The Association hosted a webinar recently on the topic of emergency preparedness. Presented by the afore mentioned Michael Morlan, this webinar covers the basic requirements of the new plan and a basic understanding of how to meet those demands.  Click here to register for this on-demand webinar, free for Association members.

– By Ryan Kelly

The National Rural Health Association reported to all state associations this afternoon that the Senate is considering a budget that will include a $160.6M budget for rural health.  Although it is not clear at this moment what constitutes “rural health” in the budget, this would be a $4.5M increase over the previous year’s allocation.

This funding increase matches the rhetoric that has been coming from the Senate, the House, and the White House regarding their focus on rural America.  Our elected officials recognize that rural health is vital to the infrastructure of our nation, and this budget reflects this recognition.

Also important to note in the budget is an $816M budget for opioid treatment, which is a 440% increase over the previous year.  Efforts have been underway in Mississippi between the Department of Mental Health and the Department of Corrections on training and education on best practices for handling opioid-addicted patients.

There are also several bills upcoming which are important to watch, including 340(b) regulations and new funding for outpatient PPS hospitals, extenders for the CHIP program, and a variety of Medicare extenders.

We are beginning to see a series of bi-partisan discussions on the Senate Public Health Committee, which is a welcome change from the many years of partisan politics.  Is this is a shift in the paradigm of DC?  We shall see…

Respective to the budget, we would like to thank Sen. Thad Cochran and his team for keeping rural health a primary focus as per their promises to us over the years.

By Ryan Kelly –

It was announced recently that leadership in the US Senate would not pursue a vote on the recently proposed healthcare bill, the Better Care Reconciliation Act of 2017,  to match the American Health Care Act passed out of the US House of Representatives last month.

It is reported that the Senate will not take up a vote because the do not have the necessary 51 votes to have the bill pass.  The Senate consists of 52 Republicans (including the Vice President) and 49 Democrats.  It is widely believed that a vote would be made down partisan lines.

So why did the bill fail to gather votes?  Essentially, it’s because we are a divided country that reflects a divided party system.  Far right Republicans do not believe that the bill went far enough to privatize insurance and move away from policies of The Affordable Care Act.  Moderate Republicans believe the legislation went too far at reducing Medicaid funding and punishing states that expanded Medicaid.

So essentially, it modified Medicaid too much and it did not open the markets far enough.  These represent two extreme issues and stances that did not work for both sides of a GOP body that needed it to work for everyone in order to pass.

The insurance marketplace would not have had the freedom needed for insurance plans to openly determine the risk of clients and assign premiums based on this risk.  The marketplace, rather would have been opened more than under the ACA but not enough to significantly reduce individual cost.

Secondly, Medicaid would have been transitioned from an unlimited federal match payment program to either a per capita rate per enrollee or a bundled payment to each state.  The greatest concern of this transition is that states would bear the greatest cost of paying for Medicaid patients, which means that most states would try to find some way to cut programs or services to save cash.  Since Mississippi receives the highest federal match of any state in the union, this would have likely affected Mississippi more than anyone else.  Although the specific impact in Mississippi has yet to be determined due to a lack of information about the specific amount of funding that would be block-granted or supplied per enrollee, the consensus is largely that it would not be good for Mississippi.  This likely would result in reduced payments for services and a reduction of covered services.  It would also likely result in a tax increase to cover the expected state shortfalls.

But, this is not done.  At the time of this writing, legislators are working on a true “repeal bill” that would take away all aspects of the Affordable Care Act.  No details have been released at this time, and many believe that such an effort would fail for the same reason that the afore mentioned legislation failed.  There is also rumor of additional healthcare legislation being crafted that attempt different ways to reform the ACA or replace it with alternative ways to care for patients.

by Ryan Kelly –

The recently released budget from the Oval Office appears to do too much in the way of cutting important programs for rural health.

Taken from an article from ModernHealthcare, several items are targeted.

The Rural Hospital Flexibility Grant, at $42 million, is proposed for elimination. The Obama administration previously had recommended cutting the program, saying it was duplicative.

The new budget also zeroes out grants to state offices of rural health, a $9 million program.

The Rural Hospital Outreach Grant, which helps small rural hospitals get resources to create collaboratives with long-term care facilities or with ambulance services, is slated for a reduction of $13 million, to $51 million annually.

The total savings for eliminating these funds are very minimal…essentially a rounding error in the federal budget.  But the impact on their elimination could be big, cutting out needed training, education, and support services to assist our rural facilities around the country, including Mississippi.

As an Association, we will wait temporarily to see how the president’s budget plays out. It’s likely that as in years past when these items were on the block for cuts, they will be replaced by the House and Senate who realize their essential nature in their districts.  If they don’t restore these proposed cuts, though, we’ll be sure to weigh-in…

By Ryan Kelly –

Recently, a major ransomware “worm” has infected computers throughout the world, notably those in the healthcare system.  Hospitals were a huge target of this software.

There is a growing concern that healthcare facilities are a prime target because of the outdated hardware and software in many facilities.  Particularly a problem with rural facilities, machines are running software that is 15 years old or more and have not been serviced in 5 years or more.

If you have computers that are running old versions of Windows (Vista, Windows 2003 or 2005) or other old software models, you need to look into updates immediately.  New computers are relatively inexpensive and can be installed with your preferred software and files quickly.   If you do not make this switch, you are prime for a data breach and may be liable for significant problems as well as fines.

Additionally, please instruct all staff to not open suspicious files even if they are sent from a trusted source.  These files (data files, pdfs etc) can contain malware and ransomware files and can infect an entire healthcare system.

In summary, stay updated and be smart with what you open.  You can control your data if you get out in front of the problems early and often!

The MRHA has been planning to expand work in four key areas as required by the identified needs of our members.  This work will include two new task forces and two new user groups.

EMR Task Force

This group is designed to be a temporary meeting of any facilities or providers in Mississippi interested in switching to a new electronic medical record system and who would like to work with others also looking to switch.  The goal of the group is to identify the top needs that they have with a new EMR and to identify bundled purchase options for reduced cost and maximum impact.

Delegated Credentialing/Provider Enrollment Task Force

This group is designed to bring together clinic and hospital staff working to improve their credentialing and provider enrollment services.  This is one of the most common issues that our members face, and improvement is needed.  This task force will investigate several delegated credentialing and provider enrollment options to see if they will help to improve each facilities’ processes.  

Accountable Care Organization User Group

The ACO User Group is designed to unite members of Mississippi’s ACOs into a central location for monthly learning sessions.  This user group will meet once per month to share updates and best practices on what has helped them to achieve reduced cost and increased quality in the nation’s new population health model.

Telehealth User Group

The Telehealth User Group will combine efforts with the Mississippi Telehealth Association and unite providers, users, and technology companies together to discover better ways to deliver telehealth and improve access to quality healthcare and increased profitability of telehealth.  In addition, the user group will work to complete a new manual for telehealth implementation in the state.

We encourage all members to be a part of these groups.  Contact us at president@mississippirural.org to sign-up.  Work will begin soon, so don’t delay!

By Ryan Kelly –

According to recent reports, CMS is proposing a $3 billion increase in payments to inpatient hospitals beginning in 2018.

Long promoted by groups like the MRHA and NRHA, increase funding for hospitals is critical in order to properly support the struggling safety net in our rural areas.

Along with increased payments, CMS is also looking to alter the funding formulas.  The Medicare Payment Advisory Commission suggested the idea of changing these formulas, saying the change would distribute the funds in a more equitable fashion.

According to ModernHealthcare, ‘the agency will distribute roughly $7 billion in uncompensated care funds in fiscal year 2018. That’s a bump of approximately $1 billion from the prior year. This change reflects the CMS’ proposal to use new data to estimate the rate of uninsurance which calculates the total amount of uncompensated care payments available.’

Safety net hospitals would also see a change in the way they receive DSH payments (disproportionate-share payments). The new formula will lean mostly on the amounts of uncompensated care and charitable care each hospital claims on its Medicare cost report. The current formula uses a formula based on the number of Medicaid, dual-eligible and disabled patients each hospital served.

I have not yet calculated what impact this would make in Mississippi for our facilities, but it is believed that the change would disproportionately benefit non-Medicaid expansive states like ours.  If we receive new data on this proposed change, we will be sure to send it out soon.  For now, though, this appears to be good news for our rural hospitals.