Good emergency planning practices and regulatory compliance mandate that long-term care facilities identify the potential threats, perils, and hazards that can adversely impact operations both from an internal (facility-based) and external (community-based) perspective. 

As required in Centers for Medicare & Medicaid Services Appendix Z, in accordance with E-006, providers must utilize a process of risk analysis to determine these hazards.  In addition to simply identifying the hazards that are unique to individual facilities, LTC operators should also focus on the “consequences” associated with the risks so appropriate plans and protocols can be developed to protect all stakeholders.

When the CMS Emergency Preparedness Rule went into effect in November 2016, a great deal of emphasis was placed on utilizing a risk assessment process to identify the internal and external hazards. This is because many providers did not embrace such a process prior to implementation of the rule. 

Many facilities developed emergency plans that were generally in alignment with the geo-centric factors associated with the location of their property. Facilities in seismically active areas focused planning for earthquakes. LTC providers in coastal regions were primarily concerned with hurricanes. Properties in the Midwest prepared for tornadoes and other forms of severe weather.

The CMS requirement to prepare for “all hazards” broadened the planning process throughout the LTC industry, as well as the entire healthcare continuum receiving this type of federal funding. But identifying the hazards alone simply is not enough. Planning for the “consequences” of the identified risks and perils is an essential component of a comprehensive emergency and disaster planning process.

One thing for sure is that emergency situations oftentimes go sideways. Here’s an example:

An identified risk in every LTC facility is the potential for an electrical power failure. The consequences of a power failure are often mitigated by the fact that most facilities are equipped with an emergency generator to provide alternate power. But what happens during a real-world power failure when the emergency generator fails to start, or the generator catches fire while it is operating? These exact scenarios have happened to providers.

The emergency planning process needs to include contingencies that address these types of questions based on this particular example:

  • What if the generator fails to start because the battery is dead?
  • What if the generator shuts down due to a broken radiator hose?
  • What if the generator catches fire during operation?
  • How is the generator’s fuel resupplied when a power failure lasts longer than normal, and the fuel supply is running low?
  • And so on…

If severe weather is identified as a high-risk peril at a long-term care facility, planning and preparing should focus on the “consequences” of the severe weather. What if the roof is torn off?  What if the power goes out? What if the facility is flooded? What if staff can’t get to work because of downed power lines and trees along with other scattered debris due to a tornado touchdown blocking all of the roads?  

Planning and managing the “consequences” of all identified hazards helps refine the emergency and disaster planning process. As much effort, if not more, should be dedicated to consequence management. Understanding that an impending hurricane may require a facility in Florida to either shelter in place or evacuate and developing plans and protocols to execute these procedures is a good example of managing the consequences of an identified hazard. 

Long-term care operators must remember that they are given the awesome responsibility of providing care, compassion and other services to some of our nation’s most vulnerable citizens.  The emergency planning process must consider the consequences of a facility’s identified threats and perils to help safeguard residents, staff and visitors during an adverse incident. 

Stan Szpytek is the president of the national consulting firm, Fire and Life Safety Inc. based in Mesa, Arizona. He is a consultant for the American Assisted Living Association and is the Life Safety/Disaster Planning Consultant for the Arizona Health Care Association, California Association of Health Facilities and Utah Health Care Association. Szpytek is a former deputy fire chief and fire marshal with more than 40 years of experience in life safety compliance and emergency preparedness. For more information, visit www.FLSafety.org or e-mail Szpytek at [email protected].

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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