by Michael Castle
Uncertainty still abounds on whether and how the virus could mutate as well as how many waves of the outbreak might take place. And with the Centers for Disease Control and Prevention (CDC) warning that it’s no longer a matter of if but when the coronavirus spreads further within the United States, patient care is priority #1. Still, for U.S. healthcare organizations, business continuity management is critical, and they must have a proper risk plan in place sooner rather than later to ensure they can provide effective services to patients.
Organizations should consider the following steps:
Conduct a proactive business continuity risk assessment: Organizations should identify potential internal operational, financial and market risks; determine direct and indirect impacts; and generate an action plan. It’s critical that action plans incorporate the CDC’s new guidance for how healthcare workers should test for coronavirus. Vulnerabilities via partners on the care continuum or third-party vendors should also be incorporated into action plans.
Identify a response team to lead ongoing crisis management efforts, coordinating with appropriate federal, state and local authorities, respectively: These efforts should include regular communication to internal and external stakeholders—with patients prioritized. In the event of an emergency, communication with patients, employees (particularly clinicians responsible for containing the outbreak) and partners on the care continuum is key. When it comes to patient communication, organizations should educate not only their direct patients but also their surrounding communities on what coronavirus is and key protective measures people can employ. Leveraging information from the WHO’s dedicated public advice page is a good place to start.
Regularly monitor announcements from the FDA around supply chain risks and recommended courses of action: The FDA has been releasing regular statements on how the agency is working to diagnose, treat and prevent the disease, as well as monitoring the medical supply chain for shortages, disruptions or fraud risk. Organizations should keep up to date with agency announcements and be ready to adjust their enterprise risk plan in tandem.
Collaborate with and proactively diversify the locations of your suppliers and vendors: Work closely with your drug and medical supply providers to build scenario models to determine ways to mitigate any additional risks to your supply chain. Identify ways to diversify your supply chain if possible and assess the cost-benefit of maintaining duplicative providers versus the costs of a lost supply chain. In the case of third-party billing or other vendors impacted, organizations would need to have a backup plan in place should vendors be unable to deliver on services.
Review your organization’s insurance policy: It’s crucial that healthcare organizations understand how to determine and capture lost revenue and income as a result of this unpredictable and unforeseen outbreak. Reviewing coverage around infectious disease, trade disruption, and workforce loss is critical to proactively managing the short- and long-term risks.
Review policies and procedures around the HIPAA Privacy Rule: On Feb. 5, the Department of Health and Human Services (HHS) reminded HIPAA-covered entities of the ways they can share patient information during infectious disease outbreaks. Organizations should ensure they—and their partners on the care continuum—have the proper information governance, cybersecurity and data privacy controls in place to mitigate increased risk around greater sharing of patient information.
Ensure integration of the latest medical billing codes around coronavirus detection: On Feb. 13, the Centers for Medicare & Medicaid Services announced new billing codes for providers and labs to test patients for coronavirus. The codes help ensure organizations can specifically track the public health response to the outbreak—and help mitigate incorrect patient healthcare costs. Organizations should ensure their billing processes have been updated to account for these new codes and that billing staff—domestic and overseas—understand how to correctly bill against them.
Provide refreshed training to clinicians on telehealth services and best practices: Ahead of anticipated quarantines or inability of certain patients to travel to facilities for in-person medical visits, organizations should review their telehealth capabilities and ensure all clinicians are familiar with the services at their disposal. Leveraging such services could be critical to addressing access to care issues that the outbreak could exacerbate.
Maintain contemporaneous documentation: While patient safety should be the priority, organizations must ensure they have a designated team—and top-down trainings—in place to keep careful records during operational disruptions. Email records around market conditions, cancellations of supply shipments or suppliers being impacted are crucial to preserve as they can be critical to a business interruption claim.
In times of uncertainty, it is important for healthcare organizations of all sizes to take actions to ensure operational and financial continuity. Are you reliant on one integral office manager? Do you only have one billing administrator that is already behind? Are you able to cut an electronic check? If any of this sounds familiar, have no fears. We are here to help develop backup plans and redundancies to get you past this crisis and grow stronger after.