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…
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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…
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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…
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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…
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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…
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Jan
22

CMS-3178-P – Don’t Count Your Chickens

As of today, only the Federal Healthcare Sector, about 10% of healthcare capacity in the US, is mandated to prepare for All-Hazards events, while the remaining 90% private sector has been expected to prepare voluntarily to meet their roles and responsibilities. Unfortunately, as is evidenced by every major disaster since 9/11, the Public Health and…
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