Valued Voice

With narrowing margins, continued rising costs and recognition of the burden regulation can place on their workforce, hospital leaders must carefully assess the services and initiatives in which they will participate. WHA is asking the Department of Health Services (DHS) to perform the same careful assessment as they work on the latest iteration of the DHS Chapter 118 rules guiding the state’s voluntary trauma classification program for hospitals seeking Level III and Level IV recognition.  

On Sept. 23, WHA responded to a DHS request for comments on the economic impact the proposed rule will have on hospitals. In the letter, WHA Senior Vice President of Workforce and Clinical Practice Ann Zenk notes, “WHA appreciates that the DHS 118 draft is far less prescriptive than the current criteria. That will be helpful. We would also appreciate an eye to implementation, and a balanced approach to the need to ‘show your work’.” Zenk adds, “Perhaps there is an opportunity to reduce some of the written requirements in this iteration of DHS Chapter 118. Beyond the dollars and cents required to staff these requirements, the compliance burden of ‘showing your work’ creates additional administrative costs and burden for already heavily regulated hospitals.”

Zenk serves on the DHS Chapter 118 Advisory Committee and in the letter also notes the importance of one of the goals of the review—making the criterion more flexible and attainable. 

“By providing more flexibility in equipment requirements, allowing a broader pathway to maintaining classification while addressing survey findings, and reducing required hours of education for busy health care professionals needed at the bedside, DHS is incorporating this view into the proposed chapter, and that is appreciated.”

WHA utilized an analysis of the proposed designated hours requirement and the level of committee participation proposed for busy hospital staff and leaders, emergency department physicians, general surgeons and orthopedic surgeons to illustrate that “even with more flexibility and the committee’s goal to consider attainability in the review, the economic impact of seeking Level III and Level IV Trauma Classification is not minor.”