Public Health Emergency Preparedness

Chapter 8. Conclusions

Table 17 summarizes our findings about the status of shuttered hospitals, and the additional needs for surge use.

With few exceptions, all of the necessary facility infrastructure, staffing, equipment, supplies, transportation, security, and information systems can be obtained, created, or installed at a partially-shuttered hospital to bring it to readiness as a surge facility.  Scenario 2 (infectious disease) raises issues that are of less concern under Scenario 1 (mass casualty trauma event) but even these more extensive needs can be addressed.

When community emergency planners consider the partially-shuttered hospitals that might be suitable for surge capacity expansion, a grading system might be helpful for prioritizing the most likely candidate facilities. This prioritization will need to be evaluated periodically in each community, since the status and merits of one shuttered hospital over another can change over time. We suggest the following factors which together might help in this prioritization:

• Shuttered hospitals are often in a state of transition to some other purpose. Location and the relative local value of the real estate may indicate the likelihood that a facility will remain empty and available or be converted to other purposes such as condominiums or assisted living.
• Similarly, a shuttered hospital may have an uncertain ownership status and may be owned by the city or by a developer or be part of a bankruptcy proceeding. Uncertain or changing ownership may mean that no one is legally able to negotiate for the use of the facility in an emergency. A partially shuttered hospital that maintains some sort of affiliation with a tertiary hospital (e.g., urgent care center, walk-in clinic) may be a more likely candidate for surge capacity since organizational/contractual arrangements already exist that can be used to advantage in an emergency.
• A hospital that has been vacant for many years is more likely to have been stripped of necessary fixtures, have undependable utilities, or have structure problems such as roof damage, and therefore may be a lesser candidate for surge capacity expansion.
• A larger shuttered hospital may have more to offer than a very small one, for surge capacity purposes.
• A surge facility located fairly close to the major tertiary medical centers may be advisable to minimize patient transportation time and issues.
• A facility that maintains a cafeteria/food preparation area, certified life safety systems, a phone switch, and similar basic functionality would be better than one that is entirely vacant and unused.

Planners could rank potential surge facilities using a list such as this as a first step in identifying the best candidate facilities.

The most efficient and comprehensive approach for opening and operating a surge facility might be for an existing tertiary medical center to take on the responsibility of making the surge facility a 'satellite' of the medical center. This would be more feasible if a former hospital is the satellite, rather than a school, hotel, or some other facility. Existing contracts and vendor agreements could be extended to the satellite surge facility and medical, security, materials management and other staff could lend their expertise, especially in the planning phase. Patient charts could remain unified and pharmacy and lab services could be extended to the satellite. While some cities may not have a tertiary medical center or an enterprise willing and able to fill this role, and while this approach is certainly not the only one that would work, it is a logistically reasonable and efficient approach for planners to consider.

Federal and State regulations pose barriers to the rapid conversion and reopening of a shuttered hospital (e.g., EMTALA, Medicare Conditions of Participation, HIPAA).⁷⁴ These issues need to be considered well in advance of a mass casualty event necessitating surge capacity expansion at any facility that is not a functioning hospital. Provision for waivers could be set in place in advance, for example, to permit this surge capacity expansion.  Perhaps the Federal government could offer 'model' waiver legislation as a starting point for States to consider.

Policy questions that planners need to consider remain unanswered, including:

• Who will have responsibility for operating the facility? Options include a local tertiary care hospital or hospital system or a city or State health department. Will this entity bear legal/liability responsibility as well?
• Who will have responsibility, at Federal and State levels, for to reviewing and revising regulations and establishing contingencies for waiving specific regulatory requirements in an emergency?
• How much will it cost to prepare and operate a surge facility and how will the surge facility and all of its staff, equipment, and supplies be paid for? Will third party insurers be asked to reimburse for care provided in the surge facility, and will the facility therefore need a sophisticated billing system (not dealt with here)?

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