We need to fill in the Gaps M E R G E N C Y Preparedness

We Already Know the Why !

MICHAEL HARVEY KATRINA TS Gordon Hurricanes and tropical storms along the Gulf Coast are examples of emergencies which have brought attention to the need for more guidelines and contingency plans for healthcare facilities and organizations. Accounts of recent emergencies have drawn attention to the need for whole communities and volunteers to participate in planning and relief efforts and the role of all healthcare providers. HARVEY KATRINA

Texas Fertilizer Plant Explosion NY ACTIVE SHOOTER Wildfires in California Texas Fertilizer Plant Explosion Missouri Tornado

Last Week on Wednesday nite in Louisiana Ruston, LA 2:30 4/24/2019 -- An E3 tornado with 145 mph winds touched down for over 6 miles, 1,000 feet wide in Ruston, LA, my home town. After the noise died down, in the dark with no communications and power available people started to develop plans for rescue and clean up. We were always told that we are too hilly, and we have too many trees to experience a tornado. Within the first day of clean over 500 tons of tree debris was removed. Hotels are gone, convenience stores are gone. Everyone that survived wants to help but how? What is the best thing to do in such a community wide disaster? If only we were prepared for such an event.

Understanding the “What” and the “HOW”

CMS Emergency Preparedness Rule First proposed in 2013 On September 8, 2016 the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. The regulation goes into effect on November 16, 2016. Health care providers and suppliers affected by this rule must comply and implement all regulations one year after the effective date, on November 15, 2017.

Emergency Preparedness Program Risk Assessment and Planning Policies and Procedures Communication Plan Training and Testing EPP

More than Fire Safety RACE & PASS More than BSL or ACLS

What are the requirements for each facility type? Appendix Z: Surveyor’s Interpretive Guidelines https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Downloads/Advanced-Copy-SOM-Appendix-Z-EP-IGs.pdf CMS Summary of Requirements by Provider Type (Chart)

EMERGENCY PREPAREDNESS EPP Develop a plan based on an all-approach or Hazard and Vulnerability Assessment. Have written policies and adopted plan. CALL PLAN Have a Communication Plan. Internal. External. Community. Alternative Communication methods. TRAIN/TEST Train initially and then annually; Two required exercises—one community or facility wide and another exercise of choice.

EPP Challenges for Rural Healthcare Providers Small, non-hospital providers may not have the experience and resources needed to assess risk, develop plan, and train or test. They have the same types of requirements as larger hospitals which may have participated in county or state exercises for years. (RHCs, Outpatient Rehab Clinics, Home Health) Small providers may have to establish new relationships and network opportunities with community, city, county or state agencies or organizations. They may still be left out of community-wide activities even after reaching out to their county OHSEP or state emergency management agency or other partners. They may be unintentionally left out of their healthcare system’s exercises or the system may not realize that off-campus locations need a separate EPP. May have to create or coordinate their own community-wide or facility-wide exercises.

Integrated Healthcare Systems If a clinic is part of a healthcare system consisting of multiple separately certified healthcare facilities that elects to have a unified and integrated emergency preparedness program, the RHC/FQHC may choose to participate in the healthcare system's coordinated emergency preparedness program. If elected, the unified and integrated emergency preparedness program must do all of the following:

Integrated Healthcare Systems Demonstrate that each separately certified facility within the system actively participated in the development of the unified and integrated emergency preparedness program. Be developed and maintained in a manner that takes into account each separately certified facility's unique circumstances, patient populations, and services offered. Demonstrate that each separately certified facility is capable of actively using the unified and integrated emergency preparedness program and is in compliance with the program.

Integrated Healthcare Systems (4) Include a unified and integrated emergency plan that meets the requirements of 491.12 along with 485.625. The unified and integrated emergency plan must also be based on and include all of the following: (i) A documented community-based risk assessment, utilizing an all-hazards approach. (ii) A documented individual facility-based risk assessment for each separately certified facility within the health system, utilizing an all-hazards approach. (5) Include integrated policies and procedures that include: A coordinated communication plan and Training and testing programs

Integrated Healthcare Systems TCT Surveyor Procedures: 1. Verify whether or not the facility has opted to be part of its healthcare system’s unified and integrated emergency preparedness program. Verify that they are by asking to see documentation of its inclusion in the program. 2. Ask to see documentation that verifies the facility within the system was actively involved in the development of the unified emergency preparedness program.

Integrated Healthcare Systems TCT Surveyor Procedures Con’t.: 3. Ask to see documentation that verifies the facility was actively involved in the annual reviews of the program requirements and any program updates. 4. Ask to see a copy of the entire integrated and unified emergency preparedness program and all required components (emergency plan, policies and procedures, communication plan, training and testing program). 5. Ask facility leadership to describe how the unified and integrated emergency preparedness program is updated based on changes within the healthcare system such as when facilities enter or leave the system.

RHC Specifics Outpatient providers are not required to have P&Ps for the provision of subsistence needs. RHCS must still have a P&P detailing how refrigerated medications will be handled during/after disasters that disrupt electrical power. RHC procedure may be to evacuate staff/patients when safe to do so, close/secure the clinic, and notify staff/patients that the clinic is closed until further notice.

Rural Healthcare Providers Partnering with Communities in Emergency Preparedness makes us all Community Action Heroes!

Thank You Jeff Harper InQuiseek jharper@inQuiseek.com (318)243-5974 7/7/2015 Thank You Jeff Harper InQuiseek jharper@inQuiseek.com (318)243-5974 Slides may not be reproduced without permission.