When 12 residents of a Florida nursing home died in the days following Hurricane Irma, the need for better emergency preparedness came to the fore. That’s one reason why the Centers for Medicare & Medicaid Services’ emergency preparedness rule has unique requirements for nursing homes and LTCs. The rule went into effect in November, but facilities still may not have faced a planned or unannounced survey that shows whether they are compliant.
In most cases facilities that strive for excellent care and operations will find that their aims are aligned with emergency preparedness requirements. For example, the process of risk assessment, one of the four core elements of the federal rule, will be most useful when the aim is to be comprehensive rather than meet minimum compliance standards.
However, facilities have to decide whether to focus on high-impact but low-frequency events — such as an active shooter or hurricane — while minimizing attention to more common, but less impactful events. A more comprehensive approach to risk assessment and planning will not only protect resident and staff safety should the unthinkable happen, it will also facilitate continuity of operations for the organization.
Policies and procedures, a communication plan, and training and testing make up the other elements of the CMS final rule for emergency preparedness.
Emergency preparedness planning does not require reinventing the wheel
If you’ve already ensured your compliance with the new CMS emergency preparedness regulations, congratulations! But if your organization is one of the many whose readiness is not complete, don’t despair. Wherever you’re starting from, you don’t have to start from scratch.
An emphasis on coalitions and collaborations is baked into the new CMS rule. LTCs should take advantage of that emphasis by reaching out to potential partners, from other facilities in a shared healthcare system to community partners. Healthcare coalitions and emergency management agencies are natural allies in many areas of emergency preparedness planning, such as risk assessment, emergency plan development and community-based mock disaster drills. These agencies may also help your organization connect to sources of state or federal funds that support emergency preparedness.
Technological tools can automate or guide the emergency preparedness planning process while also saving time and money. An emergency management platform containing incident command tools, support for training exercises, contact and resource databases, and related tools provides structure that facilitates emergency planning as well as a centralized repository for documents that is accessible from anywhere.
Thorough records ease the CMS emergency preparedness survey process
Ongoing documentation will lead to a smoother CMS survey. Although the survey will also include inspections and interviews of key personnel, documentation will be the focus. Once surveyors arrive on-site, an organization will have about an hour to compile the documents needed. You’ll want to be sure you have careful documentation and records for every core element of the CMS emergency preparedness requirements. Templates, databases and automated documentation systems can help by making it easier to maintain current supporting information. For example:
- Risk Assessment and Emergency Planning: Hazard Vulnerability Analysis (HVA), a HICS-based incident command structure, Job Action Sheets (JAS)
- Policies and Procedures: Up-to-date inventory, including expiration dates, to meet subsistence needs; plans for tracking and sharing patient location and records; criteria for choosing to evacuate or shelter in place
- Communication plan: Contact groups for emergency management agencies, hospital leadership and other relevant stakeholders; means for sharing resource information with other facilities
- Testing and Training: After Action Reports (AARs) and event logs for analysis and improvement of the plan
This list is not exhaustive, and may look different depending on a facility’s needs. Thorough documentation —especially in conjunction with emergency management tools — will also streamline the mandatory process of reviewing and updating the plan annually.
For an overview of the CMS emergency preparedness requirements for nursing homes and LTCs, along with practical preparedness guidance, attend one or all of our webinar series, Long Term Care: CMS Emergency Preparedness Rule.
Terry Zysk is the CEO of LiveProcess.