With a November implementation deadline fast approaching, healthcare providers are tasked with ensuring they are compliant with the Centers for Medicare & Medicaid Services (CMS) Emergency Preparedness Rule.
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With a November implementation deadline fast approaching, healthcare providers are tasked with ensuring they are compliant with the Centers for Medicare & Medicaid Services (CMS) Emergency Preparedness Rule.
The rule focuses on core elements of emergency preparedness, from risk assessments to training exercises
It will impact 17 types of providers and suppliers, including hospitals, long-term care, surgical centers and community mental health centers.
In recent years, Connecticut experienced a tropical storm and hurricane, the Halloween storm of 2011, active shooter events and other disasters. With the escalation of disasters throughout the nation, the existing regulations provided baseline guidance, but little beyond that.
The emergency preparedness rule aims to beef up those guidelines. They include several aspects.
Risk assessments and planning
Risk assessments are vital to maximizing patient safety when facilities are faced with threats.
By requiring providers to conduct a Hazard Vulnerability Assessment (HVA), CMS aims to ensure facilities have assessed their perceived risk for incidents such as loss of power, fire, tornado, and electronic health records failures, among other potential threats.
Findings from the HVA help facilities make informed decisions on procedures, equipment needs, drills and exercises.
Creating a communications plan
The fast pace at which disasters and emergency situations unfold requires healthcare facilities to have a comprehensive and actionable plan in place for communications.
Facilities need to ensure timely communications to local responders, media and others.
For nursing homes, a new targeting requirement is the need to communicate effectively with patients and their families, not only during an event, but also ahead of time.
This helps to control the spread of misinformation and demonstrate the facility's conscientious response to a potential situation.
Managing evacuations or high volumes of incoming patients
Emergency situations may pose two high impact scenarios to healthcare facilities — the need to evacuate a portion or all of the building, or the need to receive a high volume of patients simultaneously (a mass casualty incident or “surge”). To effectively respond to either of these scenarios, healthcare facilities need to have practiced their response prior to the actual incident occurring.
Hartford area healthcare facilities have taken a coordinated approach to preparing for these scenarios. More than 120 facilities in this region use a common platform and have planned and practiced how they will support one another in an emergency.
Education and training
While facilities have been required to conduct exercises twice per year, the new CMS rule stipulates that one of these exercises must be a full-scale, boots-on-the-ground exercise with a provider's emergency partners.
The other drill remains the facility's choice, using a high-impact threat to test their response. Connecticut is a national leader in this area, with nursing homes and assisted-living communities running full-scale disaster exercises since 2009.
With the new CMS rule requiring facilities to take a more prescriptive approach to maximizing patient safety, it is critical for facilities to prioritize how they will ensure compliance.
Healthcare leaders and staff of across Connecticut are working diligently to meet these challenges.
Scott Aronson is principal of Russell Phillips & Associates, an emergency management consulting firm with a regional office in Plainville.