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Emergency Preparedness Plans are Vital for Risk Management in CMS-Funded Healthcare Facilities

June 10, 2019

By Charles S. Touché - Vice President

A sudden and catastrophic earthquake. A wildfire raging through mountain towns. A virus spreading at unprecedented rates. Is your organization prepared to address a man-made or natural disaster? It’s a scary prospect, but we have to expect the unexpected in order to respond safely and swiftly.

Traditional or emerging risks can damage a business’ day-to-day operations or shut operations down completely. The 2014 Global Catastrophe Recap reported that severe weather alone caused $3 billion in damages in 2013. According to the National Oceanic and Atmospheric Administration, there were already two disasters that exceeded $1 billion in damages as of April 9, 2019.

Why CMS?

The 17 provider and supplier types receiving funding from The Centers for Medicare & Medicaid Services (CMS) are especially vulnerable. Millions of people rely on these facilities for everyday care. That’s why CMS implemented the Emergency Preparedness Rule in Nov. 2017.

The rule establishes national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters, in coordination with federal, state, tribal, regional and local emergency preparedness systems — no exceptions.

There are four core elements incorporated into the comprehensive preparedness plan. They should be reviewed and updated annually to reflect organizational priorities and needs.

 ·        Risk Assessment and Emergency Planning - In short, facilities must perform a risk assessment that uses an ‘‘all hazards’’ approach that will form the basis of an emergency plan. The assessment explores geographic hazards likely in a specific area, care-related emergencies, equipment and power failures, interruption in communications and loss of all or a portion of the facility and supplies.

By assessing “all hazards", facilities ensure their preparedness for a full spectrum of emergencies or disasters, whether internal, man-made emergency or natural. These plans should be updated annually.

·        Policies and Procedures Development - Similar to developing departmental policies and procedures, facilities must develop and implement policies and procedures that support the successful execution of the emergency plan and risks identified during the risk assessment process.

This should include provisions for the support of staff and residents, right down to specific instruction on whether to evacuate or shelter-in-place. Policies and procedures also should include a system of medical documentation that preserves resident information, protects confidential information and secures and maintains the availability of records.

·        Communication Plan - Communicating during a crisis is vital to providing important instructions and updates. During an emergency, providers and suppliers should have a system to contact appropriate staff, as well as patients’ treating physicians and other key individuals in a timely manner to ensure a continuation of patient care safely throughout the facilities. The plan must be well organized within the facility, across healthcare providers and coordinated with both state and local public health departments and emergency management agencies.

·        Training and Testing - Facilities must develop a well-organized, effective program that includes initial training for new and existing staff in emergency preparedness policies and procedures, with annual refresher training sessions. Required annual emergency preparedness training ensures that staff are knowledgeable and able to implement emergency procedures in the case of a crisis. The facility must also conduct drills and exercises to test the emergency plan as a way of identifying gaps and areas for improvement. This includes one community-based, full-scale exercise and one other drill.

Lovitt & Touché recognizes the necessity to support our clients who have exposure to this requirement. So, we’ve partnered with Copperstate Consulting, which provides unique insights into implementing the Emergency Preparedness Rule — so your organization is ready in case disaster strikes.

Our risk management team can help clients better identify potential risks and exposures, creating a comprehensive emergency mitigation and management plan that meets a business’ unique needs, while reducing operational risks.