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Sunday, July 12, 2020

How to Get FEMA Emergency Funding During the COVID Crisis

Brad Gair says, “In truth, if your reliance is on getting FEMA funding ‘fast’ in a hospital environment, that is your first mistake.”


KEY TAKEAWAYS

Securing an adequate amount of PPE remains an issue for hospitals and health systems.
Cash flow will remain a challenge for hospitals that have not already secured CARES funding.

Among the numerous challenges that U.S. hospitals are facing during the COVID-19 pandemic—besides keeping their facilities open, safe, and able to treat patients—is how to get paid by the federal government for the services they provide to the community.
A broad range of federal programs were allocated funding through the $175 billion Coronavirus Aid, Relief, and Economic Security (CARES) Act passed by Congress. But getting that money, either through FEMA or other agencies, has caused some confusion for governments, institutions, organizations, and individuals in search of COVID-19–related aid.
Brad Gair, senior managing director of Witt O’Brien’s, a Washington, DC–based emergency management and disaster response consultancy firm shares how hospitals and healthcare systems can secure funding during the pandemic.
Gair formerly served as deputy commissioner of New York City’s Office of Emergency Management, and as NYU Langone Health’s first vice president for emergency management and enterprise resilience. In both roles, he helped oversee disaster financial responses after 9/11 and Hurricane Sandy in New York City.

PSQH: What do you think are some of hospitals’ biggest emergency funding needs, and what are the challenges in getting them met?
Brad Gair: Hospitals have several immediate needs, including the following:
  • Personal protective equipment (PPE). This is an issue because essential workers continue to care for COVID-19 patients, and the counts are on the rise. This holds true for care delivered within a hospital or in an outside triage testing unit. Even in states where the COVID-19 patient levels are stabilized, if the facility has not planned and forecasted for additional PPE to cover the next surge, they are going to find themselves in the exact same position they were in when COVID-19 impacted the U.S. in March and April. Hospitals should be forecasting their future burn rates through September at the very least.
  • Staff capacity. This is an ongoing issue, especially if they continue to have staffing needs 24/7. Hospitals need to determine how they are going to best address their ongoing resource needs in that environment. Some have secured commitments for reserve staffing through mutual aid agreements. Large organizations can do this within their own hospital structures. Public hospitals or state hospitals will have a greater challenge—all the more reason to best understand what their staffing resource priorities will be for extended COVID-19 responses.
  • Cash flow. Because there is a significant sustained COVID-19 resurgence, cash flow is going to be a big issue for hospitals that are not in a strong position or that have not already secured CARES funding. The linchpin is understanding the whole ecosystem of funding that is out there, and how to plug costs into the right place to get the most linear, point-to-point funding opportunity, and how to do that in a manner that lets your application go through smoothly and quickly, and be rock solid so it won’t get challenged in the future. One of the biggest challenges is that aside from large, sophisticated organizations, few healthcare organizations really understand the whole scheme and how to plug into it.
PSQH: A disaster like COVID-19 is different than, say, Hurricane Katrina or Sandy, because with those two storms, you could see the damage—the lights went out, the basements got flooded, etc. With a pandemic, it’s different as facilities are technically still operational. Is it more difficult to get insurance companies and FEMA to label this as a disaster that needs emergency funding, and how do hospitals convince FEMA that they need funding immediately?
Gair: One misconception that can trip up hospitals is that FEMA reimbursement is not immediate or even fast. This is the case for a number of reasons, and the primary culprit is not having the documentation from the applicants necessary to justify funding.
In truth, if your reliance is on getting FEMA funding “fast” in a hospital environment, that is your first mistake. You need to understand what the total sources available are, and then the proper way of slotting in your costs into each of those funding opportunities so you can package those into an application for reimbursement.
The reality is that none of the federal funding that has been provided has been perfect. None has hit every potential variable right or anticipated every impact. There are going to be actions that hospitals take that are deemed appropriate that will never get funding from the federal government programs. It’s best to focus on the eligible funds you can get. And since some funding is first come first serve, focus on developing the best applications possible and getting them to the right funding source. And once the money is in your bank account, do not sweat it. Just have a plan to spend it appropriately.
PSQH: There have been some obvious costs for things (such as drive-through testing, field hospitals, etc.) that can’t really be planned for ahead of time. Are hospitals finding it difficult to get funding for these emergency services?
Gair: Testing is the biggest problem because it is really not a hospital’s responsibility to set up mass testing in another facility. That is fundamentally the government’s job. FEMA initially was setting up their own testing sites, and then states and local jurisdictions began operating their own.
It is going to be an interesting eligibility decision when it comes down to submitting those costs, and what the funding stream is going to do about it.
Hospitals need to be up front and not try to blur the lines. They should know what is covered and by whom. For example, a hospital may set up a triage unit outside the emergency room to do testing; this activity is likely to be considered by FEMA for reimbursement as there is a low chance of a duplication of benefit from another funding source such as insurance.
PSQH: One of the biggest things that experts suggest when disaster planning is to conduct a hazard assessment before bad things happen. In reality, could this pandemic (and the emergency funding it requires) have been planned for, and how does asking FEMA for assistance fit into that plan?
Gair: Yes, it could and should have been assessed in advance. This is not our first trip to the pandemic rodeo. Good hospital crisis-scenario planning should include pandemic response. Gauging the scope and depth of the event is a challenge, and sometimes you may have to be doing assessments on the fly, when you are in the thick of it. If you have somebody who understands the emergency planning process, they can help you work through even the most unimaginable scenarios. An expert who really knows how to navigate the government funding waters can help you find opportunities, define them, and slot your costs into the appropriate places to be in the best position for reimbursement.
Patient Safety & Quality Healthcare’s mission is to provide news, science, research, and a forum for opinion for clinicians, healthcare professionals, and everyone interested in improving quality in healthcare.

CMS Looks to Fund Innovation for Home Dialysis

A proposed rule would pay for innovative dialysis equipment and support in the home setting for patients with end-stage renal disease.


KEY TAKEAWAYS

The proposed rule would expand and encourage additional payments for innovative medical equipment and supplies that can be used to ease access to dialysis in the home.
More than 85% of Medicare fee-for-service beneficiaries with ESRD travel to receive dialysis at least three times each week, spending an average of 12 hours each week attached to a dialysis machine.
ESRD patients have the highest rate of hospitalization of any single group, a trend consistent with having to frequently leave home to receive dialysis.
Home-based dialysis equipment and supplies for patients with end state kidney disease would be eligible for additional Medicare reimbursements under a proposed rule put forward this week by the Centers for Medicare & Medicaid Services.
CMS Administrator Seema Verma said the proposed rule – the latest in a series of initiatives put forward by Medicare to improve access to kidney dialysis – is particularly timely “in the midst of a deadly pandemic that poses a particular threat to those with serious underlying conditions.”
In addition to often having multiple comorbidities, ESRD patients also have the highest hospitalization rates for COVID-19 among Medicare beneficiaries.
“CMS data shows that those with ESRD have the highest rate of hospitalization of any single group, a trend consistent with having to frequently leave home to receive dialysis,” Verma said.
“(This) action represents a sorely needed course direction, making it easier for ESRD facilities to make new and innovative home dialysis machines available to patients who need them,” she said.
Currently, more than 85% of Medicare fee-for-service beneficiaries with ESRD travel to a facility to receive their dialysis at least three times each week, spending an average of 12 hours each week attached to a dialysis machine away from home, CMS said.
Under the proposed rule, which would take effect on January 1, 2021, CMS would:
  • Expand the transitional add-on payment adjustment for new and innovative equipment and supplies (TPNIES) that was introduced last year to now cover qualifying new dialysis machines when used in the home.
  • Encourage under the ESRD Treatment Choices (ETC) Model the greater use of home dialysis and kidney transplants for Medicare beneficiaries with ESRD to enhance care quality and reduce costs.
  • Determine whether new ESRD care delivery and payment options can improve the quality of care and reduce the total cost of care for patients with kidney disease.
  • Refine eligibility for the transitional drug add-on payment adjustment (TDAPA) under the ESRD PPS to target additional payments to innovative renal dialysis drugs and biological products.

Amid Surge, Hospitals Hesitate to Cancel Nonemergency Surgeries

Hospitals say they are more prepared to handle the crush of patients because they have enough protective gear for their workers and know how to better treat coronavirus patients.


KEY TAKEAWAYS

Hospitals say they will shut down nonessential procedures based on local assessments of risk, but not across whole systems or states.
Hospitals’ decisions to keep operating rooms open are being guided partly by money.
The AHA estimates that the country’s hospitals and healthcare systems lost $202.6 billion between March and June.

Three months ago, the nation watched as COVID-19 patients overwhelmed New York City’s intensive care units, forcing some of its hospitals to convert cafeterias into wards and pitch tents in parking lots.
Hospitals elsewhere prepped for a similar surge: They cleared beds, stockpiled scarce protective equipment, and — voluntarily or under government orders — temporarily canceled nonemergency surgeries to save space and supplies for coronavirus patients.
In most places, that surge in patients never materialized.
Now, coronavirus cases are skyrocketing nationally and hospitalizations are climbing at an alarming rate. But the response from hospitals is markedly different.
Most hospitals around the country are not canceling elective surgeries — nor are government officials asking them to.
Instead, hospitals say they are more prepared to handle the crush of patients because they have enough protective gear for their workers and know how to better treat coronavirus patients. They say they will shut down nonessential procedures at hospitals based on local assessments of risk, but not across whole systems or states.
Some hospitals have already done so, including facilities in South Florida, Phoenix and California’s Central Valley. And in a few cases, such as in Texas and Mississippi, government officials have ordered hospitals to suspend elective surgeries.
Hospitals’ decisions to keep operating rooms open are being guided partly by money. Elective surgeries account for a significant portion of hospital revenue, and the American Hospital Association estimates that the country’s hospitals and health care systems lost $202.6 billion between March 1 and June 30.
“What we now realize is that shutting down the entire health care system in anticipation of a surge is not the best option,” said Carmela Coyle, president of the California Hospital Association. “It will bankrupt the health care delivery system.”
The association projects that California hospitals will lose $14.6 billion this year, of which $4.6 billion has so far been reimbursed by the federal government.
But some health care workers fear that continuing elective surgeries amid a surge puts them and their patients at risk. For instance, some nurses are still being asked to reuse protective equipment like N95 masks and gowns, even though hospitals say they have enough gear to perform elective surgeries, said Zenei Cortez, president of the National Nurses United union.
“They continue to put us at risk,” Cortez said. “They continue to look at us as if we are disposable material.”
Elective surgeries, generally speaking, are procedures that can be delayed without harming patients, such as knee replacements and cataract surgery.
At least 33 states and the District of Columbia temporarily banned elective surgeries this spring, and most hospitals in states that didn’t ban them, such as Georgia and California, voluntarily suspended them to make sure they had the beds to accommodate a surge of coronavirus patients. The U.S. surgeon general, the Centers for Disease Control and Prevention and the American College of Surgeons also recommended health care facilities suspend nonemergency surgeries.
The suspension was always intended to be temporary, said Dr. David Hoyt, executive director of the American College of Surgeons. “When this all started, it was simply a matter of overwhelming the system,” he said.
Today, case counts are soaring after many states loosened stay-at-home orders and Americans flocked to restaurants, bars and backyards and met up with friends and family for graduation parties and Memorial Day celebrations.
Nationally, confirmed cases of COVID-19 have topped 3 million. In California, cases are spiking, with a 52% jump in the average number of daily cases over the past 14 days, compared with the two previous weeks. Hospitalizations have gone up 44%.
Governors, county supervisors and city councils have responded by requiring people to wear masks, shutting down bars and restaurants — again — and closing beaches on the July Fourth holiday weekend.
But by and large, government leaders are not calling on hospitals to proactively scale back elective surgeries in preparation for a surge.
“Our hospitals are telling us they feel very strongly and competent they can manage their resources,” said Holly Ward, director of marketing and communications at the Arizona Hospital and Healthcare Association. If they feel the situation warrants it, “they on their own will delay surgeries.”
In some states, like Colorado, public health orders that allowed hospitals to resume nonemergency surgeries in the spring required hospitals to have a stockpile of protective equipment and extra beds that could be used to treat an influx of COVID-19 patients.
States also set up overflow sites should hospitals run out of room. In Maryland, for example, the state is using the Baltimore Convention Center as a field hospital. The state of California last week reactivated four “alternative care sites” — including a hospital that was on the verge of closure in the San Francisco Bay Area — to take COVID-19 patients should hospitals fill up.
But the decision to reduce elective surgeries in California will not come from the state. It will be made by counties in consultation with hospitals, said Rodger Butler, a spokesperson for the California Health and Human Services Agency.
The question is whether hospitals have systems in place to meet a surge in COVID-19 patients when it occurs, said Glenn Melnick, a professor of health economics at the University of Southern California.
“To some extent, elective care is good care,” Melnick said “They’re providing needed services. They are keeping the system going. They are providing employment and income.”
In Los Angeles County, more than 2,000 COVID patients are currently hospitalized, according to county data. While that number is projected to go up by a couple of hundred people over the next few weeks, hospitals believe they can accommodate them, said county Health Services Director Christina Ghaly. In the meantime, hospitals are preparing to bring on additional staff members if needed and informing patients who have scheduled surgeries that they could be delayed.
“There’s more patients with COVID in the hospitals than there has been at any point previously in Los Angeles County during the pandemic,” Ghaly said. “Hospitals are more prepared now for handling that volume of patients than they were previously.”
While hospitals have not stopped elective surgeries, many have not ramped up to the full schedule they had before COVID-19. And they say they are picking and choosing surgeries based on what’s happening in their area.
“We were all things COVID when it was just starting,” said Joshua Adler, executive vice president for physician services at UCSF Health. “We didn’t know what we were facing.”
But after a couple of months of treating patients, hospitals have learned how to resupply units, how to transfer patients, how to simultaneously care for other patients and how to improve testing, Adler said.
At Scripps Health in San Diego, which has taken more than 230 patients from hard-hit Imperial County to the east, its hospitals have scaled back how many transfers they will accept as confirmed COVID-19 cases rise in their own community, said Chris Van Gorder, president and CEO of Scripps Health.
A command center set up by the hospital system reviews patient counts and medical supplies and coordinates with county health officials to study how the virus is spreading. Only patients who need urgent surgeries are being scheduled, Van Gorder said.
“We’re only allowing our doctors to schedule cases two weeks out,” Van Gorder said. “If we see a sudden spike, we have to delay.”
In California’s Central Valley and in Phoenix, where cases and hospitalizations are surging, Mercy hospitals have suspended elective surgeries to focus resources on COVID-19 patients.
But the other hospitals in the CommonSpirit Health system, which has 137 hospitals in 21 states, are not ending elective surgeries — as they did in the spring — and are treating patients with needs other than COVID, said Marvin O’Quinn, the system’s president and chief operating officer.
“In many cases their health deteriorated because they didn’t get care that they needed,” said O’Quinn, whose hospitals lost close to a $1 billion in two months. “It’s not only a disservice to the hospital to not do those cases; it’s a disservice to the community.”