Figure 2: Steps for developing and implementing an emergency plan 1. Involve executive level management. 2. Have peer-to peer discussions about plans already in place. 3. Look to industry experts and best practices. 4.
Start with a template and mold the plan to fit your facility or business model.
5. Implement the plan and communicate to staff by: a. Completing and documenting training; b. Practicing plan drills; c. Benchmarking outcomes vs. expectations; and d. Revising as necessary. (Courtesy of Sizewise. Reprinted with permission.)
This new regulation is particularly notable for non-acute healthcare providers, since previous CMS emergency planning standards were based on acute care. The standards now apply to all 17 healthcare provider types (see Figure 1), with different requirements for different kinds of facilities. According to HD Supply’s Wicker, some facilities may not realize that these standards apply to them, since they weren’t regulated in the 4 |
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past. “If your sign says healthcare, the standards apply to you,” he warns, “and you have to be prepared and have a plan.” While the specific standards vary by facility type, they cover four core elements of emergency preparedness:5 1. Risk assessment and emergency planning; 2. Communication planning; 3. Policies and procedures; and 4. Training and testing.
The standards themselves drill down into many aspects of emergency preparation, from how much emergency food and water skilled nursing facilities must keep on hand, to how many days’ worth of fuel needs to be stored for emergency generators. The types of emergencies and disasters include, but are not limited to, earthquakes, hurricanes, severe weather, flooding, fires, flu and virus outbreaks, and homeland security threats. Providers can find details on the CMS website at: www.cms.gov/ Medicare/Provider-Enrollment-andCertification/SurveyCertEmergPrep/ Emergency-Prep-Rule.html. In addition to federal regulation, states also play a large role in emergency and disaster planning for healthcare facilities. For example, state inspectors conduct the actual assessments to determine whether facilities are complying with the federal CMS regulations. States may also add another layer of standards and requirements on top of federal regulations. Following last year’s nursing home deaths in Florida, Governor Scott imposed a new rule requiring assisted living facilities and nursing homes to acquire sufficient generators and fuel to ensure comfortable temperatures for 96 hours following a power outage. The equipment must also be inspected within 15 days of installation.6 Florida also has its own reporting system for emergency planning and response, as well as criteria for specific provider types. (Nursing homes must have enough emergency food on hand to feed residents for 72 hours.)7
Putting the Plan in Place Once a healthcare facility understands federal and state emergency prepa-
ration requirements, making a plan that satisfies them may seem daunting – especially since plan development is only part of the process. Providers must also decide: • How (and to whom) they will communicate in an emergency or disaster; • What supplies they need to have on hand for different scenarios; and • When and how they will train staff and conduct drills. For senior living facilities, a first step in the planning process is to get the site’s leadership to agree on priorities. “Engage department heads in a round table discussion about their anticipated needs in an emergency,” recommends Sizewise’s Baron. From there, he suggests a series of steps that include team engagement, relying on outside resources, documentation, training, and evaluation (see Figure 2). A cornerstone of any emergency and disaster preparation plan is Hazard Vulnerability Analysis (HVA) (see Figure 3). The HVA is a tool that that identifies risks, their effects, and their probabilities of occurring. Prior to the new CMS guidelines, only hospitals needed to complete an HVA, but now non-acute providers like senior living facilities must do so as well. HD Supply’s Wicker points to this as an example of a helpful regulation since facilities that use the HVA properly will prioritize. “They won’t spend equal time on preparing for each risk, but rather spend the most time on what’s the most probable.” Drills are another key component of emergency planning. Simulating realworld situations puts a plan to the test and helps a facility determine which components are effective and which need more work. Drills and exercises may seem overwhelming to organize and execute, and some planners have success with a piecemeal approach. “Test pieces individually – like transportation or emergency generators – to make them less daunting,” recommends Wicker.
Being Resourceful Proper disaster and emergency preparation is a challenge that