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The Homeland Security Act of 2002 provided the authority for the creation of the Department of Homeland Security (DHS). It is also the Director of DHS to create a National Incident Management System (NIMS). Published in 2004, formed NIMS the framework for the detection, mitigation, response and recovery from natural and manmade disasters, events, and events of national importance in the United States, its territories, protectorates and Indian Tribal Nations. NIMS provides the framework for the creation of the National Response Plan (NRP), also published in 2004.

The National Plan is an all-hazards, all agencies approach to the detection, mitigation, response and recovery from disasters, whether natural or manmade events and incidents of national significance. A little-known provision of the NIMS a classification system for all emergency resources. This classification, the National Resource Typing System (NRTS) provides a unified cross-agency, cross-jurisdiction of the classification of all resources that are or could be in response to a NRP / NIMS case regardless of whether such equipment or resources staff.

Responsibility as a signatory:

All federal agencies, all 50 states, all U.S. protectorates and territories and all Tribal Nations within the scope and authority of the federal government have become signatories to NRP / NIMS. Among these are the signatories and Health Resource Services Administration (HRSA) and the Department of Health and Human Services (DHHS), parent company of the agency for Medicare, Medicaid and veterans health care funding. This status provides signatories for certain functions to these institutions and governments, as well as giving them certain rights and privileges. These rights and obligations are incumbent upon all agencies, their agents or the competent authority of any signatory to the NRP / NIMS.

In addition to an irrevocable agreement in full to any disaster, whether manmade or natural event or incident of national significance in the region, that the signatory or the authority that the signatories to the office, department or agency, all Signatories to the NIMS / NRP before have agreed to all changes, classifications, modifications and arrangements, which may be associated with by the Director of DHS or the NIMS Integration Center, or Center implementation of the NRP. Such changes, classifications, modifications and regulations must be implemented without amendment.

NIMS requirements for the DHS of importance:

Within NIMS, there are several clauses that are of importance for the creation of a new industry in the area of disaster preparedness, planning, training and evaluation in the United States. Recurring through the document, the term "establish qualifications, credentials and certification of hospitals and healthcare facilities in cooperation with ... and national professional organizations." This sentence is in respect of all hospitals and health care institutions at all levels of response - administrative, financial, logistics and above all functional. If hospitals are specifically pointed out that this sentence occurs with increased regularity. Until today, there was no classification, credentialing or certification by the DHS, NIMS and NRP.

The NRTS are no instructions on how to compile this report, for the qualification, certification, credentialing or entering the medical providers, particularly doctors. However, the NIMS Integration Center, 12 September 2006, quiet hospital and healthcare facility NIMS Implementation Plan.

NIMS responsibility to DHHS of importance:

In addition to an irrevocable agreement in full to any disaster, whether manmade or natural event or incident of national significance in the region, that the signatory or the authority that the signatories to the office, department or agency, all Signatories to the NIMS / NRP before have agreed to all changes, classifications, modifications and arrangements, which may be associated with by the Director of DHS or the NIMS Integration Center, or Center implementation of the NRP. Such changes, classifications, modifications and regulations must be implemented without amendment.

The Center for Medical Services (CMS) is the agency expressly authorizes DHHS and with responsibility for overseeing all operations for Medicare, Medicaid and Tricare. This responsibility includes the certification of the participating hospitals and healthcare facilities, whether directly through a network of regional offices (RO) and State agencies (SA) or by authorized private organizations, including the Joint Commission for the recognition of health care organizations (JCAHO) and the Healthcare Facility Accreditation Program (HFAP) of the American Osteopathic Association (AOA). CMS draws its authority directly from the Secretary of DHHS and is responsible for the implementation of all tasks and responsibilities of the Secretary of DHHS as Medicare, Medicaid and Tricare, including but not limited to the dissemination and legal advice to that end.

NIMS Implementation Center Hospital and Healthcare Facility Plan:

NIMS Implementation Center Hospital and Healthcare Facility Plan includes a new landscape that for disaster planning, preparedness, training and evaluation as well as national organizations involved in the certification or accreditation of healthcare facilities, healthcare professionals, professional planning and emergency management professionals .

JCAHO accreditation standards and disaster preparedness:

The Joint Commission for the recognition of health care organizations (JCAHO) has become the de facto standard for hospital and healthcare facility accreditation. The American Osteopathic Association (AOA) is a parallel Healthcare Facility Accreditation Program (HFAP). For the purposes of this discussion, there are virtually no differences in the standards set by JCAHO and AOA. How common is the JCAHO accreditation, the discussion will focus on the JCAHO standards.

The participating hospitals and health centers avoid "self-certification" on behalf of external accreditation by JCAHO. The CMS is used by DHHS JCAHO accreditation instead of the CMS certification for the purposes of the CMS provider eligibility. Loss of JCAHO accreditation is synonymous with loss of the CMS provider eligibility. JCAHO a compliance manual Standing together in the JCAHO standards for disaster preparedness in the post-9/11 era, and provides guidance on compliance with those standards.

The JCAHO standards have specifically adopted the START / JumpStart Disaster triage system (also known as Integrated Triage). JCAHO guidance also specifically address disaster preparedness and training through immersion simulation drills, as "the EU-wide" and "flow drills." The JCAHO guidelines may take the form of exercises, but this type of drill do not meet the need for inflow exercises. JCAHO states that an accredited hospital must be at least a Community-wide drill every year and at least two influx exercises every two years.

Center for Medical Services (CMS):

The Department of Health and Human Services (DHHS), signed NRP / NIMS is the regulator for Medicare, Medicaid and Tricare (Veteran's Administration) funded through the Center for Medical Services (CMS). The regulator provides certification for hospitals and other health care facilities either through JCAHO / HFAP or directly though its own system of government control offices / teams. CMS regulations with the force of federal law under various aspects of the Social Security Act Title XVIII and XIV, the Federal Register specific sections for this discussion are 42CFR482.1 and their legal counsel. The CMS State Operations Manual contains the clear orientation to the current interpretation of the 42CFR482.1 and CMS regulations. CMS provides for the enforcement of these rules and safety precautions.

As an office of a NRP / NIMS signatory agency, it is incumbent upon CMS to ensure the full implementation of the NRP / NIMS. This includes compliance with the NRP / NIMS compliance with all providers (hospitals and health facilities), funded by CMS. CMS regulations establish a legal prerequisite for the full NRP / NIMS compliance with all Medicare, Medicaid and Tricare certified hospitals and healthcare facilities. As an office of a NRP / NIMS signatory (DHHS), these requirements are not more than an adaptation of the NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan. Further, CMS has increased non-compliance with safety and preparedness, the level of an "imminent threat" and thus immediate suspension of a hospital or health facility, the status as a CMS (Medicare, Medicaid and Tricare) participating providers.

Correlation of the NIMS IC plan, CMS Regulations & JCAHO standards:

Correlation Table 1:
The NRP / NIMS agreement signed by DHHS and required to implement the CMS in conjunction with the applicable directives, regulations and rules, the approval of CMS, HRSA and JCAHO mandate for the complete and unaltered compliance with NRP / NIMS / NRTS and the implementation NIMS Center for Hospital and Healthcare Facility Plan falls all hospitals and healthcare facilities.

Correlation Table 2:
CMS and JCAHO standards call for the use of an Incident Command structure and to draw attention to the four phases of the disaster. This describes the NIMS Implementation Center Hospital and Healthcare Facility Plan for the use of the Incident Command System and ICS training.

Correlation Table 3:
CMS and JCAHO standards require hospitals and health facilities, together with the Community on the basis of a large number of institutions responses to the disaster as well as participation in the EU-wide multi-agency drills. This parallels the NIMS Implementation Center Hospital and Healthcare Facility Plan and effectively implemented this part of this plan.

Correlation 4:
The combination of the use of CMS CMS JCAHO accreditation as a certification and the deferment of the certification provided by hospitals to JCAHO Accreditation JCAHO makes the de facto certification to meet the NIMS Implementation Center mandate for the "self-certification." To JCAHO accreditation is also the de - facto certification for compliance with the NIMS Implementation Center Hospital and Healthcare Facility Plan for each individual hospital or hospital.

Correlation Table 5:
CMS and JCAHO standards require that an accredited hospital or clinic in the health sector to develop and publish for CMS / JCAHO review of an operational budget, including the provision of capital for all aspects of the business. This is consistent with the NIMS Implementation Center Hospital and Healthcare Facility Plan provisions on the preparedness funding.

Correlation Table 6:
CMS regulations and JCAHO standards necessitate revision of the existing as well as the regular updating of plans in relation to the two pre-event vulnerability analysis and post-event review (review of measures). These clauses validation of NRP / NIMS and NIMS Implementation Center Hospital and Healthcare Facility Plan for plan review and periodic reassessment.

Correlation Table 7:
CMS regulations and JCAHO standards for the individual requirements of the EU-wide and Surge (influx) disaster exercises. Further, both organizations hold tabletop exercises in favor of the patient and live environment simulator drills. The detailed and time again on these drills emphasizes the weight and importance on this stage by such laws and the approval of agencies. This focus reflects the equal importance of disaster drills NRP / NIMS and NIMS Implementation Center Hospital and Healthcare Facility Plan.

Correlation Table 8:
CMS regulations and JCAHO standards specify that hospitals and healthcare facilities have sufficient reserves and resources, including generators, potable water, medicines and oxygen to the safety of all staff, patients and residents. These requirements are divided into several important parts of the regulations, including Life Safety, Facility Operations, Patient Safety and Human Resources. The JCAHO and CMS-sections are actually more stringent and specific than the comparable NIMS Implementation Center Hospital and Healthcare Facility Plan servings.

Correlation Table 9:
CMS regulations and JCAHO standards specify the use of plain English and a common nomenclature across the communications, without for a different language or in the nomenclature of the disaster event. This common language requirement is much stricter than those formulated related NIMS Implementation Center Hospital and Healthcare Facility Plan sections to a large extent because of the high priority given by both CMS and JCAHO on the 1999 To err is human report published by the Institute of Medicine.

Impact of NIMS-IC plan, CMS Regulations & JCAHO standards:

Implication 1:
Whether by design or serendipity, the recently published CMS regulatory changes and progressive refinement of JCAHO standards have led to the accreditation criteria now closely approximate those in the NRP / NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan. This has the effect of creating a legal mandate for hospitals and healthcare facilities implement fully the NRP / NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan. It is the position of High Alert, that this creates a new market for Disaster Planning Services and Disaster Preparedness, Response and Recovery education.

Implication 2:
Due largely to the Nationals patient safety program of JCAHO and CMS in response to the Institute of Medicine report To err is human, recently published CMS regulatory changes and progressive refinement of JCAHO standards have resulted in accreditation criteria for resource acquisition / inventory and common nomenclature communication with those set out in the NRP / NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan. In addition, both agencies have linked these criteria to the facility Safety / Life Safety Criteria for Accreditation.

Impact 3:
After the catastrophic events of 2004 and 2005 hurricane season and the recent National Academies of Sciences reports on hospital and community disaster preparedness, recently published CMS regulatory changes and progressive refinement of JCAHO standards have resulted in accreditation criteria for disaster planning , training and exercises, which exceed those set out in the NRP / NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan. In addition, both agencies have linked these criteria to the facility Safety / Life Safety Criteria for Accreditation.

Impact 4:
Since the certification by the CMS and JCAHO accreditation indirectly for Medicare, Medicaid and Tricare insurance participation, and because CMS and JCAHO have tied much of its disaster preparedness criteria to the facility security and life safety criteria for the certification, the violation of these criteria would immediately CMS certification and thus delay Medicare, Medicaid and Tricare insurance involving the violation of the hospital or the hospital. Further, any private insurance program to participate in the event oa CMS suspension. So violation of the CMS and / or JCAHO criteria and disaster preparedness through the expansion of the NIMS Implementation Center Hospital and Healthcare Facility Plan holds significant financial penalties for any hospital or hospital.

Conclusion:

Based on the comprehensive review of the CMS regulations, JCAHO standards, NRP / NIMS and the NIMS Implementation Center Hospital and Healthcare Facility Plan, it is the position of High Alert, that this creates a market pressure towards comprehensive immersion simulation training with a Crawl - Walk - Run "Disaster Exercise program for staff and ICS training for the administration. This program can be found in 5-6 days and all the necessary training and drills for all patient safety, disaster response and community / multi-agency exercises according to CMS regulations, JCAHO standards, NRP / NIMS and the NIMS Implementation Center Hospital and health facility plan. One such program, the client hospitals and healthcare facilities with comprehensive disaster planning, preparedness and response training, significant improvements in the safety of patients through the use of simulation-based training and demonstrable cost savings compared to current market conditions, approach to these processes to protect while those customers from possible financial loss.

The random fire of CMS regulations, JCAHO standards, NRP / NIMS / NIMS Implementation Center Hospital and Healthcare Facility Plan revisions, National Academy of Sciences reports on the clinic and the preparedness and the Institute of Medicine report To err is human to create an unexpected environment, that de facto mandates for the complete and unmodified implementation of NIMS Implementation Center Hospital and Healthcare Facility Plan. Further market is ripe for the introduction of the next development of disaster preparedness training.

Immersion Simulation Training is training for the catastrophic inpatient bed environment and high fidelity human patient simulators for training is not only disaster and terrorism response / treatment, but also the safety of patients and other issues, the Institute of Medicine report To err is human. This model creates a learning environment similar to that for the training of pilots and fighter pilots. Teams, in this model, we are patterned after the techniques for training NASCAR pit crews to work quickly and accurately in a high risk, high stress and fast paced environment. NDLS-FL and its partners can not afford such an opportunity.

Dr. Maurice A. Ramirez is the founder and president of the consulting firm High Alert, LLC .. It serves the expert panels for pandemic preparedness and increase health plan with Congress and Cabinet members. Board certified in multiple specialties, Dr. Ramirez is a founding member of chairman of the American Board of Disaster Medicine and serves the nation as a senior-Federal Medical Officer in the National Disaster Medical System. Dr. Ramirez has a new book: everything you can, anywhere, anytime. His website is http://www.High-Alert.com