While an extreme case, this tragedy touched off a long-overdue conversation about whether healthcare facilities, and skilled nursing sites in particular, are prepared to handle emergencies. In covering the story, the New York Times noted that both federal and state guidelines required nursing facilities to keep temperatures at a comfortable level, even in the event of a power outage. And Florida Governor Rick Scott implemented more stringent emergency rules for senior living facilities following the incident.2 While not all parts of the U.S. are vulnerable to hurricanes, every single healthcare facility faces the threat of some type of emergency, from fires to disease outbreaks to earthquakes, and much more. For non-acute healthcare facilities (especially nursing homes), increased scrutiny and new regulations have made emergency planning more important than ever. “We are seeing a marked increase in awareness and planning, particularly since the natural disasters of the past year,” says Andrew Baron, regional vice president of Sizewise, a healthcare facility equipment supplier. “We believe local, state, and federal governments will encourage more emergency planning, as will various accrediting agencies.” To ensure both patient safety and the ability to operate, it’s critical that non-acute healthcare facilities: • Understand the requirements surrounding emergency preparation; • Make a plan; and • Know the resources available to help them throughout the process.
What’s the Scenario? While almost all non-acute healthcare facilities have some type of contingency plan in place for emergencies and disasters, plan effectiveness varies greatly. One of the primary challenges providers face is planning for different types of emergencies. According to Sizewise’s Baron, “It’s hard for a facility to plan for every possible event – whether it’s a major storm or something more minor like a broken water main in the facility.”
Figure 1: The Centers for Medicaid and Medicare Services (CMS) has issued emergency preparation requirements for the following 17 healthcare facility types:3 • Religious Nonmedical Health Care Institutions (RNHCIs) • Ambulatory Surgical Centers (ASCs) • Hospices • Inpatient Psychiatric Services for Individuals Under Age 21 in Psychiatric Residential Treatment Facilities (PRTFs) • Programs of All-Inclusive Care for the Elderly (PACE) • Hospitals • Transplant Centers • Long-term Care (LTC) Facilities: - Skilled Nursing Facilities (SNFs) - Nursing Facilities (NFs) • Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID) Along the same lines, healthcare facilities may have emergency preparation and response plans that put too much emphasis on the wrong scenarios. “Senior living communities typically don’t prepare enough, or they prepare incorrectly by not prioritizing their efforts on most probable events,” says Daniel Wicker, safety and compliance product consultant at maintenance, repair, and operations distributor HD Supply. Wicker cites facilities in the Midwest developing intricate hurricane evacuation plans but not having plans in place for tornadoes, which are far more likely and often occur with much less warning. Finally, some facilities may think they are well-prepared to deal with an emergency, when in fact they lack the resources to implement their plan. “Storing food and water for emergencies is only the beginning,” according to Pam Bentley, business development manager at Easy Meal Food Service, a supplier of storage and emergency preparedness food. A facility must also ask, “Will we have the staff to prepare the food, serve it, and clean up afterwards?”
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Home Health Agencies (HHAs) Comprehensive Outpatient Rehabilitation Facilities (CORFs) Critical Access Hospitals (CAHs) Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services Community Mental Health Centers (CMHCs) Organ Procurement Organizations (OPOs) Rural Health Clinics (RHCs) - Federally Qualified Health Centers (FQHCs) End-Stage Renal Disease (ESRD) Facilities
Regulations & Requirements For all healthcare facilities, it’s important to be aware of pertinent laws and regulations when planning for emergencies and disasters. These regulations not only provide requirements for emergency planning, but in many cases, they also offer helpful templates and resources. For senior living facilities and other non-acute healthcare providers, emergency planning requirements changed on November 15, 2017, when they had to begin complying with all aspects of a new Centers for Medicaid and Medicare Services (CMS) regulation issued a year earlier. This regulation, Rule CMS 3178-F or Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers, established emergency preparedness requirements for 17 healthcare provider types that are mandatory for participants in the federal Medicare and Medicaid programs. Providers that fail to meet these requirements risk losing Medicare and Medicaid reimbursement.4
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