CMS emergency preparedness rule: What to know
Don Basler, Marketplace Expert
The Centers for Medicare & Medicaid Services instituted a rule requiring emergency preparedness of certain facilities participating in their programs. The deadline for compliance is November 15, 2017. A key component of compliance is developing a communication plan that enables organizations to communicate and act upon an emergency situation quickly and effectively. We'll explore the key components to consider and best practices to ensure compliance before the deadline that's quickly approaching.
What is required?
As previously mentioned, facilities must have a written emergency communication plan that contains information about how the facility coordinates patient care including within the facility, across healthcare providers and with state and local public health departments. The plan also should include how the facility interacts and coordinates with emergency management agencies and systems to protect patient health and safety in the event of a disaster. Additionally, it should include components that support the coordination of care. It also must be reviewed annually and updated as necessary.
Facilities have flexibility in how they formulate and operationalize the requirements of the communication plan. Institutions in rural or remote areas with limited connectivity to communication methodologies such as the Internet or cellular capabilities need to ensure their communication plans address how they would communicate and comply with this requirement in the absence of these tools.
For example, if a facility is located in a rural area with limited or no Internet and phone connectivity during an emergency, the plan must address what alternate means are available to alert local and state emergency officials. Optional communication methods facilities may consider include satellite phones, radios and short wave radios.
Who should be included in my communication plan?
Every healthcare institution has unique, and possibly complex, communication needs. While every scenario may require different individuals to be considered in the plan, there are a few that should be included for every organization. These include all staff members, entities providing services under arrangement (food services, gift shops, facilities staff), patient facing physicians, residents and caregivers, partnering hospitals and CAHs and volunteers.
For everyone included within the plan organizations will want to make sure they have the names and specific contact information for each person. Additionally, they should incorporate a process to ensure all new staff is added to the list and departing staff are removed from the list.
The requirement to have contact information for “other facilities” requires a provider or supplier to have the contact information for a provider of the same type as itself. This may present collection and data maintenance obstacles, depending on the specific relationships between the organization and its peer institutions. However, it also can provide an opportunity to coordinate with peers in a structured and clear fashion that facilitates collaborative partnerships and builds stronger relationships.
All contact information must be reviewed and updated at least annually. Contact information contained within the communication plan must be accurate and current. Sound recordkeeping and maintenance is a good discipline to reinforce.
A facility must have the contact information for those individuals and entities outlined within the standard. While formatting is up to the organization's discretion, it should be readily available and accessible to leadership during and emergency event or similar safety incident. Facilities are encouraged but not required to maintain these contact lists both in electronic format and hard-copy format in the event that network systems are not accessible.
Technology can help
Today technology can be a major time saver in complying with any standard including CMS' emergency preparedness rule. Mass notification solutions, like Rave Mobile Safety's Rave Alert provide a platform for complete internal and external healthcare communications.
There are four aspects to complying with the CMS emergency communication plan:
- Collection –Organizations need to collect the contact information for all people identified in the rule
- Updating – Institutions need to keep contact lists current – adding new and removing old
- Backup – Facilities need to demonstrate that they will have backup access to contacts lists in an emergency
- Audit trail – Organizations need to show that their information has been reviewed
Most of the built-in functionality within a mass notification system already addresses the more demanding CMS requirements.
Organizations should look for a solution that has a variety of ways to easily add contacts into its database. For example, some solutions come with the functionality to automatically integrate with HR and ERP systems as well as physician or caregiver databases.
If a solution has this functionality, institutions should also ensure that it's automatically updating from those tools. They should look for a tool that updates the database with on-going, proactive freshness checks.For backup, facilities should look for a tool that enables them to schedule or manually pull and review enrollment reports. Having these automatically sent to a server or printer removes the potential for a user to forget to complete this necessary task.
Finally, organizations should look for a tool that always has relevant audit data available. The solution should have strong reporting and records retention within its platform to ensure compliant contact management over time.
While the deadline for compliance for the CMS emergency preparedness rule is quickly approaching, there's more than enough time to ensure your organization is in a good place to comply. Technology can play a major role in ensuring the communications plan portion of the requirement is up to par with what's needed. With the right tools at hand, institutions will not only comply, but will better prepared should an emergency incident occur in the future.