Emergency Preparedness for Long-Term Care Administrators: Regulatory Changes and Impact Mary Helen McSweeney-Feld, Ph.D., LNHA Associate Professor, Interprofessional Health Studies Towson University, Towson, MD Kathryn Hyer, Professor and Director, Florida Policy Exchange Center on Aging University of South Florida, Tampa, FL  

DISCLOSURE(S) Research Support: State of Maryland Office Of Health Care Quality Baltimore Gas and Electric Company Consultant: N/A Discussion of Off-Label, Investigational, or Experimental Drug Use:

Presentation Goals You will be able to: Identify recent changes in CMS requirements for emergency preparedness, as well as select state emergency preparedness guidelines, for long-term care administrators and their communities Describe the impact of these final requirements on administrators and residents of long-term care communities and their families in the event of an emergency or disaster; Locate peer-reviewed materials that can assist educators in training long-term care administrators, residents and their families in these areas.

CMS Final Emergency Preparedness Requirements for Healthcare Organizations November 17, 2016: CMS final rule for emergency preparedness requirements for long-term care communities that are Medicare/Medicaid certified becomes effective (first introduced in 2014) Long-term care communities that participate in Medicare/Medicaid have one year to comply and meet all requirements (until Nov 17, 2017) Takes an “all hazards” approach to preparedness using a Continuity of Operations Plan (COOP) New requirements evolved from preparedness guidelines developed by the Joint Commission, FEMA, ACHE and other healthcare organizations; similar to hospital preparedness Called the CMS “Emergency Preparedness Checklist”

CMS Final Emergency Preparedness Requirements, con’t All Hazards = be prepared for any type of event Some events may require you to stay in your building (“shelter in place”) Other events may require you to evacuate your building (plan on where you will go) Community-based = start with a locally based approach to preparedness, have a relationship with local emergency management

CMS Final Emergency Preparedness Requirements, con’t CMS also assumes that you will use a Continuity of Operations Plan (COOP): a plan that ensures you can perform essential functions Have an Incident Command Structure (FEMA): a standardized approach to the command, control and coordination of emergency response Response to any emergency or disaster triggers the ICS system – someone has to be the Incident Commander, other staff report to the Commander and have other functions

Simple Incident Command System (www.ready.gov)

CMS Final Emergency Preparedness Requirements, con’t Final guidelines include Staff and Resident tracking requirements (during and after the emergency or disaster); must account for missing residents Secured and Available Medical Records In the event of an evacuation, method to release patient information consistent with the HIPAA Privacy Rule Backup generators Mandatory annual staff training and drills (including full-scale exercises including evacuations) Shared information with health care departments, local emergency managers and residents’ families on emergency preparedness requirements (community approach)

CMS Recommended Checklist

CMS Emergency Preparedness Requirements: Why is this Important? 2005: Hurricane Katrina – impacted Gulf States 2006: OIG report on nursing home preparedness in Gulf States showed high levels of compliance with Federal standards, but significant problems implementing these standards, esp. with evacuations and re- entry to facilities and collaboration with state and local emergency managers 2007: CMS introduces the first recommended emergency preparedness checklist for healthcare providers 2012: OIG follow-up report on nursing home preparedness showed continued gaps in preparedness in evacuations, lack of collaboration with local emergency managers and residents that developed health problems 2014: CMS introduces a new revised emergency preparedness checklist 2016: CMS issues final emergency preparedness rule for HC organizations

CMS Emergency Preparedness Requirements: Information from Maryland 2015: MD Office of Health Care Quality provides grant to train MD long-term care providers in the new CMS requirements, and review MD COMAR emergency preparedness regulations 2 training events: Central MD and Eastern Shore, MD Staff from 58 providers representing all regions of the state of MD attended Majority were nursing home providers, some ALF & CCRC organizations represented

CMS Emergency Preparedness Requirements: Information from Maryland, con’t Data collection from both events indicated Majority had an emergency plan, conducted drills for shelter-in-place Some providers had an “all hazards approach” to preparedness Few had drills for evacuation scenarios and facility re-entry Majority had a resident family communication plan Some providers had secured and available medical records Few had shared emergency plan information with local health care departments and local emergency managers Eastern Shore providers had a higher level of preparedness than others Maryland has not had a major statewide disaster in recent years

CMS Emergency Preparedness Requirements: Information from Other States Lane and McGrady (2016): Data collection from North Carolina and South Carolina shows progress in overall planning and sheltering-in-place tasks, as well as contact with local emergency managers Problems still exist with back-up evacuation sites and evacuation routes, identification of resident care items and obtaining copies of state and local planning regulations.

CMS Emergency Preparedness Checklist: Limitations Checklist is focused on facility planning and resident/family needs Needs of staff are not addressed in the final checklist provisions What happens if you have staff that lose their homes and family members while they are working for you? Psychological first aid issues of staff and residents not addressed in the checklist

Other Limitations Data on emergency response and recovery by long- term care facilities is limited Data collected focuses on community characteristics, not facility characteristics and effectiveness of planning Ongoing data collection needed to measure the effectiveness of the final CMS emergency preparedness checklist for long-term care facilities

Recommended Practices Some areas have their own emergency planning coalitions – CMS has a list ESF-8: hospital and public health preparedness coalition. Does your state have a long-term care industry representative as part of that coalition? Register with your state and local emergency management agencies; they may have GIS mapping capabilities to locate your facility in an emergency or disaster Some states have established disaster plans and protocols for nursing homes (Florida has a nursing home evacuation plan) State medical reserve corps offer free training (staff members may want to join) DRILL, DRILL, DRILL….

Other Helpful Resources www.ready.gov; Federal Government emergency preparedness website https://training.fema.gov/is/crslist.aspx; FEMA Independent Study training classes – ICS 100, 200 and 700 are important, specialized class topics for weather, pandemics, active shooter available emergency.cdc.gov; many emergency preparedness resources http://www.redcross.org/get-help/prepare-for- emergencies/workplaces-and-organizations; Red Cross Ready Rating Rating program is a new opportunity The National Center for Disaster Medicine and Public Health has published a free online curriculum on Caring for Older Adults in a Disaster https://ncdmph.usuhs.edu/KnowledgeLearning/2015-OAC.htm Disaster Medicine and Public Health Preparedness (journal published by Cambridge University Press) has an upcoming special issue on Caring for Older Adults in Disasters (in press) There are many active disasters sites, and research that can be conducted…

Questions?? Any questions?

Contact Information Email me for supplemental information Mary Helen McSweeney-Feld, Ph.D., LNHA Associate Professor, Towson University mmcsweeneyfeld@towson.edu 410-704-3909 (office) Our contact information is listed on the slide. Thank you for your time. Please note our email addresses. Send us a note for additional documents attached.