Welcome to the most boring section of the revised Conditions of Participation. Coincidentally, it may very well be the most important part of the CoPs. Having lived through Andrew, Katrina, Rita, Gustav and the recent summer flooding, I assure you that nothing will go according to plan. However, if you do not have a plan, you will lose your true North and risk not knowing what to do next. There is nothing worse than seeing devastation all around you and not knowing what to do.
Write your plan and practice until you know it inside out. This is not an exercise to appease surveyors. This is how you will ensure your patients’ get through an emergency.
All agencies must have their plan reviewed at least annually. Plan must:
- Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.
- Include strategies for addressing emergency events identified by the risk assessment.
- Address patient population, including, but not limited to, the type of services the HHA has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
- Include a process for cooperation and collaboration with local, tribal, regional, State, and Federal emergency preparedness officials’ efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the HHA’s efforts to contact such officials and, when applicable, of its participation in collaborative and cooperative planning efforts.
Policies to be developed for:
- Patients during a natural or man made disaster
- Individual plans must be included as part of comprehensive assessment
- Procedures to inform state and local emergency preparedness officials about patients in need of evacuation based on medical or psychiatric need
- Follow-up procedures to determine services that are needed in the event of an interruption of services or due to emergency. Agency must notify state/local officials of any on-duty staff or patients that cannot be located.
- A system of accessible documentation that preserves both the content of the record and patient confidentiality.
- Use of volunteers including State or Federally designated healthcare professionals to address surge needs.
A communication plan must be developed as part of the Emergency Preparedness plan. It will include:
- Names and contact information for the following:
- Entities providing services under arrangement.
- Patients’ physicians.
- Contact information for the following:
- Federal, State, tribal, regional, or local emergency preparedness staff.
- Other sources of assistance.
- Primary and alternate means for communicating with the HHA’s staff,
- Federal, State, tribal, regional, and local emergency management agencies.
- A method for sharing information and medical documentation for patients under the HHA’s care, as necessary, with other health care providers to maintain the continuity of care.
- A means of providing information about the general condition and location of patients under the facility’s care as permitted under 45 CFR 164.510(b)(4). (HIPAA Disclosures that require an opportunity for the patient to refuse).
- A means of providing information about the HHA’s needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.
If an agency is part of a larger healthcare system consisting of multiple certified providers, the agency may participate in a unified plan encompassing all providers under the parent umbrella.
- Assign one person to implement with an understudy so nobody is left wondering who was supposed to do this when a tornado or hurricane hits.
- Many states have Emergency Preparedness requirements. Be sure your agency meets both sets of guidance.
- The decision to leave one’s family to go tend to patients is very hard. Encourage your staff to think about how they will provide for their children and elderly relatives in the event of an emergency so that they are not overly anxious being away from them.
- The section on communications is useful only if phones are working. If phones go down, how will your staff proceed?
- Find out where the high acuity shelters are planned before anything happens. If you wind up admitting patients to the hospital because of ventilators, IV’s, etc., you may create an artificially high hospitalization rate.
- If a disaster occurs where there is advance warning such as hurricane or flood, assign someone to keep up with when the restrictions on Medicaid drugs is lifted. You may have patients who will not have enough medications and cannot buy more until 30 days passes from their last prescription pick-up date.
If your agency has been through a disaster, please share with the rest of us anything you learned that got you through or thwarted your efforts.
Remember that disasters are not always natural. EHR failure is a different type of disaster you should have a plan for.
Oh, you are so correct! I will review the CoPs again and see if it is mentioned. Also, I wonder if the HIPAA regulations have a requirement that addresses IT system failures. Also, after the hurricanes in the South, IT failure was a huge consideration for agencies that housed their own data. There is not much of that anymore but at the time it was devastating and the devastation was not limited to home health. We had thousands of patients in Baton Rouge who had evacuated from New Orleans and the only thing they could tell us was they ‘took the purple pill and a sugar pill and something for pressure’. It was nightmarish. Everyone should have an ongoing offsite backup. Thanks for bringing this up.