1. CMS Emergency Preparedness Ruling

2. Welcome Introductions What is the Northwest WI Healthcare Coalition?
What is the Western WI Public Health Readiness Consortium?

3. Disclaimer
Any information provided by any of Wisconsin’s emergency healthcare coalitions or their staff regarding the new Centers for Medicare and Medicaid Servicers emergency preparedness rule is intended for advisory purposes only. None of the tools or assistance provided guarantees any outcome during the facility survey visits. Facilities are solely responsible for meeting CMS requirements.

4. Outline for our morning…
Overview
Emergency Operations Plan
Policies and Procedures
Training and Testing Program
Resources

5. Overview: Why are we here?
The Centers for Medicare & Medicaid Services (CMS) issued the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule to establish consistent emergency preparedness requirements for healthcare providers participating in Medicare and Medicaid, increase patient safety during emergencies, and establish a more coordinated response to natural and human- caused disasters.

6. Overview
The rule was published on September 16, and is effective as of November 15, The regulations must be implemented by affected entities by November 15, 2017.

7. Overview
The rule applies to 17 different providers and suppliers and is a condition of participation for CMS.
Four key elements:
Emergency Operations Plan (EOP)
Policies and Procedures
Communications Plan
Training and Testing Plan

8. Emergency Preparedness Program
Emergency Plan
Policies & Procedures
Communication plan
Training and Testing
Integrated Health systems
Emergency & Standby power

9. Again, why are we doing this?? What is our reality?
If you haven’t faced a disaster yet, you will
It’s only a matter of time
WLUK, John Morrill

10. In the Headlines
“More than 40 residents of a memory care facility in Oconomowoc had to be evacuated from their building late Friday, May 19th because of a gas leak.”
“The North Shore Fire Department on Tuesday morning, December 20 responded to the scene of a fire at a nursing home in Glendale.”
“Officials said a sprinkler burst over the main electrical panel and building officials said the facility was evacuated because it could take several hours to repair the problem.”

11. This is really confusing….
Emergency Preparedness Where do we start?

12. Who is responsible for the work?
Start at the top!
Administrator
Director of Nursing
Maintenance Director
Human Resources
Safety Committee Members
Get creative where you can.
Interns
Nursing Students
Staff on light duty
Content Experts
Quickmeme.com

13. Emergency Operations Plan
Develop an emergency plan based on a risk assessment and using an “all-hazards” approach, which will provide an integrated system for emergency planning that focuses on capacities and capabilities.

14. All-Hazards Approach
The Joint Commission (TJC) advises healthcare organizations to take an "All Hazards" approach to emergency management. The approach calls for an organization to work toward hazard prevention while simultaneously preparing for the unexpected emergencies and unforeseen situations that inevitably occur.
Sep 9, 2016

15. Emergency Operations Plan
Policies and Procedures
Communications plan
Training/Exercises
Facility HVA/Community HVA
Continuity plan

16. Know the Plans Universe….
Internal Plans, partner Plans
Mother ship Plans
Jurisdictional Plans
State Level Plans
Know the system, it can help you in your local plan, and when you’re overwhelmed….

17. Identifying Risk: The HVA
Stands for “Hazard Vulnerability Assessment”.
A tool used to identify the potential risks for a facility
A prioritization process that will result in a risk assessment for “all hazards”
It is NOT a rubber stamp or just a box to be checked – it is a working document
Done annually

18. Why do we need an HVA?
Because Centers for Medicare and Medicaid Services says so!!!
It will identify areas most at risk and allow facilities to focus their preparedness planning on those risks

19. Many Available Tools Kaiser Permanente
Threat and Hazard Identification and Risk Assessment (THIRA)
UCLA
Kansas Model

20. Common to all… Type of Emergency Must Take into Consideration
Probability
Human Impact/Business or Facility Impact
Preparedness Efforts (Mitigation)
Risk “Score” or Probability
Must Take into Consideration
Location and Geography
Patient populations including those with disabilities and functional access needs
Type of services organization provides

21. Types of Emergencies

22. Probability 4: Highly Likely: Probable within the year
3: Likely: Probable within three years
2: Possible: Probable within five years
1: Unlikely: Probable within 10 years
PROBABILITY
Likelihood this will occur
4 = Highly Likely (probable within this year)
3 = Likely (probable within 3 years)
2 = Possible (probable within 5 years)
1 - Unlikely (probable within 10 years)

23. Impact Human: Possibility of Death or injury
Property: Amount of property severely damaged
Facility: Complete interruption/shutdown of facility or services
HUMAN
PROPERTY
FACILITY
IMPACT
Possibility of death or injury
Amount of property severely damaged
Complete interruption / shutdown of facility or services
4 = Multiple deaths
4 = >50%
4 = >30 days
3 = Injuries result in permanent disability
3 = 25-50%
3 = >2 weeks
2 = Injuries do not result in permanent disability
2 = 10-25%
2 = >1 week
1 = Injuries treatable with first aid
1 = <10%
1 = 24 hours or less

24. Preparedness 1. Planning: Do you have an Emergency Operations Plan?
TRAINING
EQUIPMENT
Emergency Management / Operations Plan
Staff trained and equipped
4 = No EMP or EOP
4 = staff not trained on EOP
3 = EMP/EOP partially complete
3 = some staff trained, no equipment
2 = EMP/EOP complete
2 = most staff trained, some equipment
1 = EMP/EOP exercised and/or evaluated
1 = Anticipated staff trained and properly equipped
1. Planning: Do you have an Emergency Operations Plan?
2. Training and Equipment
3. Other Considerations:
How integrated are you with external/community resources?
Do you have MOUs with partners?

25. Sample

26. The outcome of an HVA? You get a list of TOP 5 Threats
What is most likely to happen to you
Focus your PLANNING on these Threats
Look at the FUNCTIONS you would need to bring to bear.
Example: 3 of your top 5 might lead to an evacuation. Focus on the FUNCTION of Evacuation.

28. Policies and Procedures

29. Develop Written Policies & Procedures
Hazard specific response procedures
Communications procedures
Emergency operations plan
Business continuity plan
How are you going to provide care to your patients?
How to share medical information/when to share and with whom to share it with
What services are you going to provide during an emergency and how to communicate that with your patients?
Evacuation procedures
Once the your hazards have been assessed, it is appropriate to identify how you will prioritize those hazards and which ones will get your attention. We can’t write protocols for every hazard and so choosing the ones that are at highest risk is pertinent. A basic emergency preparedness program will have hazard specific response procedures, such as fire, severe weather, and elopement.
The level of detail necessary for your communications plan really depends on how you format this document. There should be an element of communication and notification in every hazard specific response procedure. Those elements should include, who is being notified and how. The other communications component that needs to be considered is, once everyone is safe, who needs to be notified, how will we notify them and how frequently will we communicate with them. For example, your facility as just evacuated, you know you need to notify resident’s loved ones, where is that list, who is contacting them, how will you communicate with them. Keep this simple. This can be a stand alone document or apart of your emergency operations plan and business continuity plan.
The emergency operations plan is going to describe chain of command and emergency management strategies for consideration. Strategies may include how and where you will get more food and water when you are running low, evacuation decision parameters and how to interact with the media.
Once you feel that you have gotten the emergency preparedness program to a level of maintenance, start to incorporate business continuity planning. You are going to do some of this along the way, but start to put more focus on it. You have identified that when there is a fire, you will evacuate. Your evacuation meeting location is across the road. You have an agreement with the local bus company to come pick up your residents and you are taking them to the church a half mile away. But then what? This is where business continuity planning comes into place. Who will be responsible for finding open beds for the residents? How will they do it? Will your staff go with the residents or will they be re-assigned to other duties? Can you continue to pay your staff? How will the billing process work?
Is your head ready to explode yet? Can you imagine how your head may feel if you don’t have an idea of how all this will work during the time of disaster?

30. Hazard Specific Plans
How are you going to care for your patients/residents?
The greater the risk, the more necessary the plan:
Fire
Severe Weather
Missing Resident
Other?

31. Example for Hospice:
Procedures to follow up with on-duty staff and patients to determine services that are needed, …due to an emergency. The hospice must inform State and local officials of any on-duty staff or patients that they are unable to contact.
Procedures to inform State and local officials about hospice patients in need of evacuation from their residences at any time due to an emergency situation based on the patient’s medical and psychiatric condition and home environment.
National Hospice and Palliative Care Organization

32. Example for Hospice:
A system of medical documentation that preserves patient information, protects confidentiality of patient information, and secures and maintains the availability of records.
The use of hospice employees in an emergency and other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.
National Hospice and Palliative Care Organization

33. Example for Hospice:
The development of arrangements with other hospices and other providers to receive patients in the event of limitations or cessation of operations to ensure the continuity of services to hospice patients.
There are specific policy requirements for hospice-operated inpatient care facilities which are very straightforward and address a hospice provider’s ability to ensure that their patients and staff are taken care of during an emergency response.
National Hospice and Palliative Care Organization

34. Communication in an Emergency…
Gather information
Monitor incoming calls
Coordinate messages
Monitor /media/social media
Keep management/incident command updated on the situation
Provide/share information with patients, staff, families, community, law enforcement, media etc.

35. Components of Communications
Need to maintain lists of your emergency contacts
Identify how those lists are maintained (Annually)
Who has access to your lists?
Identify when to contact and who to contact
Staffing plan
How are you going to communicate with them
Piggy-back on county and / or coalition.
ATT/RAVE, etc…

36. CMS and Communications
Requires health care facilities have a stand alone communications plan that:
Includes names and contact information for:
Staff
Contracted agencies that conduct business within the facility (i.e. rehab services, beauty salon)
Physicians
Neighboring health care agencies (i.e. hospitals, clinics, long term care agencies)
County contacts (public health, law enforcement, fire, emergency medical services, mortuary)
Regional contacts (health care coalition)
State contacts (licensing agencies,
Volunteers

37. CMS and Communications
Identifies how to contact staff and other contacts….
To include the primary and back up processes
Who to contact and when to contact people/resources
Identifies how to release information to health care providers in the event of an evacuation
Discusses how to release information about the patients basic condition and location
A process for sharing the long term facilities status, including occupancy, ability to provide services to local emergency management, county partners, health care coalition, and state agencies
Identify how to update patients/families/responsible parties the status of the facility and the emergency plans that are in place/being utilized

38. Communications Plan Hints:
Keep it simple
Be flexible
Easily accessible
Coordinate with other entities (local emergency management, law enforcement)
Review, test and practice
Utilize the Healthcare Incident Command System – Public Information Officer

39. In an Emergency….
Think about what types of Communication tools you may have or may not have…
What are the contingency plans for communication?

40. Can your Communications Plan:
Launch quickly?
Brief leadership/management on the situation?
Identify the Public Information Officer and their role in an emergency?
Identify how to prepare and issue statements to the media and other organizations?
Organize, monitor, and facilitate media coverage including social media?
Communicate situation information and procedural instructions to employees and other stakeholders?
Communicate with employee/patient families and the local community?
Continually adapt to changing events associated with the emergency?

41. Other Examples of Policies
1. Shelter In Place 2. Evacuation 3. Business Continuity Plan

42. Emergency Operations Plan
Outlines the facility’s strategy for responding to and recovering from a threat, hazard, or other incident
Information in the EOP is to be used during response and should provide abbreviated guidance and quick reference material
The Incident Command System should serve as the foundation on which to design the organizational structure and processes included in the EOP

43. Emergency Operations Plans
Hazard Vulnerability Assessment
Policies and Procedures
Incident Command Structure
Incident Commander
Safety Officer
Liaison Officer
Public Information Officer
Finance
Logistics
Operations
Planning

44. Organization of an EOP Example from Minnesota’s LTC Toolkit Title page
Introduction
Table of contents
Executive summary
Base Plan
Appendixes

45. Base Plan—Provides an understanding of how the organization responds and how it interfaces with its outside environment during response
Purpose and/or mission: Goal and objectives
Scope
Situation and assumptions
Policies and authorities
Concept of operations
Summary of HVA
Chain of Command
Definitions – Emergency Alerts and Key Terms
Activation of Plan

46. Possible healthcare concept of operations stages:
Event recognition
Initial notification and activation
Mobilization
Incident operations
Demobilization
Transition to recovery

47. Business Continuity Plans
Ensures that the service and products are not disrupted and can return to normal operations rapidly
Business continuity management
Contingency planning
Disaster recovery

48. Business Continuity
Utilize the same procedures and the same format as the EOP
May not need to include specific incident response appendixes
Leadership must be involved
Committee will also provide for better cooperation from departments

50. Training and Testing

51. What’s already required?
What are your current annual training requirements?
BBP, CPR/1st Aid, etc…
Piggy back on these
What’s the new ruling?
Who’s role is what?
What does our plan look like?

52. Emergency Response Training Requirements
FEMA/NIMS compliance
Federal Emergency Management Agency
National Incident Management System
ICS 100, 200
NIMS 700, 800

53. Where to Find Trainings….
FEMA Independent Study Website
e=3
Let’s go there!

54. Testing – What’s required?
Communications Drills
Annual Required Exercises

55. Exercise Requirements
1 Tabletop (Internal)
1 Full-Scale Community Based Exercise
Get INVOLVED in your Healthcare Coalition
They perform an Annual Healthcare Coalition exercise that meets all Federal Requirements around exercising and is HSEEP compliant
Homeland Security Exercise and Evaluation Program

57. Next Steps

58. Develop an Action Plan Determine goals and objectives
Identify the top 3-4 areas that need attention
Develop strategies to accomplish each item
Assign a time frame to each item
Assign a person to complete each item and identify the resources needed
Monitor this action plan frequently
I like action plans. I want to know what needs to be done, who is doing and when is it going to be done by? We realize that establishing any new program can feel overwhelming. We are here to help.
Identify the top 3-4 areas that need your attention. The HVA, writing protocols for the top 2 hazards and testing them. It may be that simple – then get to work on them. Monitor them. If you can handle working on more items that 3-4, go for it.

59. Build Relationships Create contact lists Know your neighbors
Develop relationships with
Emergency Manager
EMS
Law Enforcement
Fire
Health Care Coalition
Building relationships is so important. You want relationships with fire, police and emergency medical services. They are your local responders and all disasters are local. These people are the ones who will be the first to arrive and the last to leave. Another relationship that you may find to be very beneficial is with the emergency preparedness healthcare coalition. We are made up of healthcare facilities all working on emergency preparedness. These relationships will serve you well in times of crisis.
Document these relationships. Write them into your plans. CMS wants to know how you work together.

60. Healthcare Coalitions
Wisconsin DHS: Office of Preparedness and Emergency Health Care (OPEHC)
Get involved
Exercises and Training

61. Low Hanging Fruit Complete HVA Identify Top 5
Develop Activation/Notification Protocol
Communications Plan
Join Healthcare Coalition
Join Local Emergency Planning Committee (LEPC)
Plans to focus on in Year 1
Communications
Evacuation
Shelter In Place
Continuity

62. It’s a Marathon, not a Sprint…
Take your time
It’s a process

63. ALL THESE RESOURCES….
Literally, don’t create anything new from scratch….
It already exists
Find it, localize it, adopt it, test it

64. ALL THESE RESOURCES…. CMS ASPR TRACIE
(search for Emergency Preparedness Ruling)
ASPR TRACIE
West Central and Central MN Health Care Preparedness Coalition
library/
Northwest WI Healthcare Coalition
Western WI Public Health Readiness Consortium

65. ALL THESE RESOURCES….
National Hospice and Palliative Care Organization
content/uploads/2017/03/Emergency_Preparedne ss_for_Hospice_1.pdf
State Toolkit will be coming out soon.

66. THANK YOU