Jun
02

An Open Letter to Veteran Services Organizations about VA Healthcare

Veterans Administration Secretary General Shinseki resigned his position Friday after a meeting with the President, according to this Washington Post report, falling on his sword to eliminate distractions as the VA scrambles to fix widespread failures to provide timely care to veterans. With the hindsight of being an old soldier who has been deeply involved…
Read More

Apr
30

Bait and Switch: Ready or Not?

As we were reviewing the events that led up to adding 3178-P Proposed Rule into the Federal Register, we looked back over the available guidance going back to 9/11 to identify sources that might have saved lives in Katrina and other major disasters. We found two documents worth reviewing, both of which were supported or…
Read More

Apr
06

CMS-3178-P Proposed Rule Official Comments

As All Hazards Readiness consultants we have been following the Proposed Rule CMS-3178-P with interest since it was slipped into the Federal Register during the holiday season (December 27, 2013). Being  a third party that is largely in the middle of the issues between Providers and the Public, we see our role as one that…
Read More

Mar
12

CMS 3178-P Extension

Background: This Proposed CMS Rule was introduced very quietly into the Federal Register on December 27, 2013, right in the middle of the holiday season. We were a little surprised at the timing and knew that these proposed changes would have a major impact on the industry for a couple of reasons: 1)      The timing…
Read More

Feb
19

Revisiting the Drug Shortage Two Years On

We originally published this article in Journal of Healthcare Protection Management, volume 28, #1, in early 2012. Many of the same issues exist today and some have become worse, as noted at the end of the article. Drugs, drugs – who has the drugs? Dr. James Blair, DPA, MHA, FACHE, FABCHS, MCAS  Drug diversion, although…
Read More

Feb
04

Why CMS-3178-P is Filling an Important Gap in Readiness

Editor’s Note: As we see the CMS-3178-P Rule find its’ way into the Federal Register, we pulled out a few posts from 2009 that pointed to the need for tighter regulations, especially given the failures in preparation in Joplin and Hurricane Sandy Disasters, to name the most visible. We have seen in an earlier article…
Read More