During the comment period for the Centers for Medicare & Medicaid Services’ emergency preparedness regulations, some long-term care providers expressed concern about increased expectations for testing their plans. The new CMS requirement calls for at least two exercises each year, with at least one of those being a full-scale exercise.
While that level of testing may be an increase for some facilities, there’s no need to feel overwhelmed. Keep in mind that even full-scale exercises don’t require testing every aspect of the plan at once. It’s entirely reasonable to keep exercises simple if your testing program is in the early stages of maturity.
Start by scaling emergency preparedness exercises to your organization
Many organizations use a multi-year training and exercise plan (MYTEP) over a 3-to-5 year period to progressively test and evaluate all capabilities and elements of an emergency plan. Emergency preparedness testing will be more manageable and more effective if you define the scope of your exercises to match your needs, in the following ways:
Specify capabilities to be tested and the test objectives
For example, you might choose to test your capability to evacuate your facility, either as a table-top exercise or as a full-scale exercise with community participation. A table-top exercise would allow you to evaluate the effectiveness of your current plan for a full evacuation without actually evacuating all patients and staff. A possible objective for such a plan would be to engage key participants in describing the process of evacuating the entire facility within a particular time frame. A full-scale exercise would include patients and all staff on duty. The capability tested might be a partial facility evacuation, moving patients to one named location to another within the facility. The objective should state how many patients are to be moved and how long the evacuation should take, to provide clear metrics for success.
Limit incident command activation
When you created your emergency plan, you likely documented an expanded incident command system (ICS) with multiple roles and responsibilities. When testing an element of the plan — or activating the plan for an actual emergency — use the smallest incident command necessary.
Keep in mind that the required ICS functions include command, operations, planning, logistics and finance/administrator. However, the only position that is actually required is the incident commander: if one trained person can handle the incident, only that person need be activated. The ICS structure should be modular, so that positions can be activated, or removed, discretely. Using a virtual incident command system as part of an emergency management platform makes it easier to contain the size of the incident command structure by providing a central source for both situational awareness and resource orchestration.
Use established resources
The CMS requirement for exercises with community partners may feel onerous to facilities that haven’t collaborated with these partners in the past. In fact, local emergency management agencies, healthcare coalitions and community partners are all potential resources where you can connect with experienced exercise planners. Healthcare coalitions may have pre-planned exercises available specific to healthcare core capabilities — and they may have funding available to help defray the cost of testing. Because community involvement is necessary to show compliance, be sure to document the participation of any outside agencies or facilities.
Effective emergency preparedness evaluation processes make the most of activations
The evaluation phase of emergency preparedness isn’t just useful, it’s required by CMS regulations. To ensure compliance, think about documentation before, during, and after exercises.
Before even beginning exercises, document the procedures that will be used for evaluation and include them as an annex of your emergency plan. No specific evaluation format is required by CMS but leaving it too open-ended in your plan may backfire and produce vague or unhelpful results. Recording a clear procedure for evaluation will help standardize evaluation methods and promote objectivity.
You can’t painstakingly document and evaluate during an exercise or emergency, but detailed and comprehensive event logs can provide a great deal of information for evaluation. An emergency management platform that records communications and actions as events unfold provides situational awareness in the moment, then automatically collates them into after-action reports, saving a tremendous amount of time and effort later.
After the event, expect a written evaluation process to take anywhere from 2 to 6 weeks, depending on the scale of the event. Although finding opportunities for improvement will be the main focus, be sure that your organization recognizes individuals or departments for excellent performance. Acknowledging success is just as important as addressing shortcomings.
Revise the plan to include the needed improvements. This part of the process presents another chance to take advantage of community partnerships. Emergency management agencies or other collaborators can offer fresh insights, experience and a different perspective on areas for improvement.
Terry Zysk is the CEO of LiveProcess.
