Ann Pickren

Hurricanes Harvey and Irma offered manifestations of what can happen in the absence of a sound emergency preparedness plan: In Texas during and after Harvey, the staff of one healthcare facility fled while leaving distressed patients behind. During Irma in Florida, eight patients at a nursing home that lost power died – despite the fact that a full-service hospital was a few dozen feet away.

As McKnight’s coverage of comments by The Centers for Medicare & Medicaid Services principal deputy administrator for operations at a recent hearing indicated, “several of the failings” that led to the nursing home resident deaths could be traced to inadequate training on the emergency preparedness plan, or following proper emergency protocol.

For nursing homes and other institutional long-term care facilities, severe weather events such as the devastating hurricanes as well as the more recent California wildfires test even the most robust emergency communications plans. And while long-term healthcare providers have dedicated significant resources to preparing for external emergency events, CMS was less confident the healthcare industry was prepared if a disaster or emergency happened directly to them.

Driven by that concern, CMS put the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers rule into effect November 16th, 2016. Affected healthcare providers and suppliers were given one year to comply and implement all regulations. The CMS rule, enforceable as of November 15th, 2017(a week from today), establishes a consistent framework that mandates incorporation of best practices and lessons learned in emergency preparedness.

Medicare and Medicaid participating providers and suppliers must evaluate their compliance posture for the four core elements of an Effective Emergency Preparedness Framework: 1) Emergency plan, 2) Policies and procedures, 3) Communications plan; and 4) Training and testing program.

Each is critical, but for purposes of this article we will focus on developing and maintaining a communication plan that complies with both federal and state law. Below are five strategies to improve your organization’s emergency communications plan:

  1. Establish easily activated communication channels for reaching others both on and off-site. During widespread emergencies, communication becomes a serious challenge very quickly. Cellular signals, email servers, and traditional phone lines can fail. However, it’s critical that your communication plan includes processes that would allow for communication with staff, care providers, families, and others who may or may not have alternative forms of technology such as HAM and satellite systems.
    This is why it is critical to expand beyond the traditional means of sharing information among both your internal and external constituents. Your Emergency Mass Notification System (EMNS) platform should be multimodal, meaning that all messages can be sent in multiple ways through the platform. It should also support one message being sent out as a phone call (to cell phones or landlines), SMS text message, email message, desktop alert, app notification, RSS feed, and pager.
  2. Follow ‘Chain of Command’ protocol for the order in which alerts are sent. It’s instinctive to know that local emergency response teams should be contacted and summoned before patient’s families are notified of a situation, but it’s much harder to execute, especially in urgent, chaotic situations. The best way to overcome it? Plan in advance and automate the process.
    The contact information for those you need to reach in a crisis (internal and external) should be kept securely within your mass notification system account, or should be able to be linked to an existing database for continuous updating. This provides the ability to create groups of contacts either in advance or on-the-fly (by using filters).
  3. Your contingency plan should establish backup resources. Plans should be aligned to your current vulnerability threat risk assessment. Backup resources should be established across everything from power to medical supplies to food and water reserves. Additionally, patient care must be well coordinated across healthcare providers, and with state and local public health departments and emergency systems.
    EMNS platforms can allow for your messages and contacts can be hosted on secure servers which are redundant and backed up regularly, ensuring that your data is safe and secure. Other things to consider include the ability to send alerts to all devices simultaneously; receive responses back and track results and mobilize emergency personnel or other staff instantly to respond to urgent or unexpected situations.
  4. Maintain coordination with other healthcare facilities. The CMS has maintained the critical importance of coordination with other healthcare facilities and public health officials. Coordination among healthcare facilities in a large-scale crisis is of utmost concern for patient safety and continuance of care.

    Your healthcare alliance, whether it is formal or informal, can communicate swiftly and easily through your mass notification service. Text messages can be used for urgent messages, phone calls for urgent messages that include instructions, and email for longer messages and sharing documents (attachments). All of this can be done through the service, all at one time.

  5. Account for constituents in a crisis and evacuation. Many healthcare providers dedicate a great deal of their emergency planning efforts towards accounting for constituents during a crisis or evacuation. Every situation is different, but here are a few key steps that are critical to include in your plan:
  • Break down the facility and staff into manageable groups.
  • Determine coordinators and leaders.
  • Identify locations and evacuation points.
  • Compile employee lists.
  • Make coordinators/leaders easily identifiable.
  • See OSHA’s workbook on accountability in a crisis for additional tips and details.

A sound emergency communications plan helps not only ensure compliance with the CMS rule, but also protects your people and property.

Ann Pickren is president of Enterprise Solutions at OnSolve. Jim Satterfield is the CEO and co-founder at Firestorm.