The reports following recent hurricanes in the United States were heartbreaking. In the aftermath of Hurricane Harvey, residents of a Texas nursing home that had never flooded before were trapped by rising waters. Meanwhile, eight residents perished in a Florida nursing home that lost air conditioning after Hurricane Irma, despite the home’s prior preparations for power outages.
While many agencies in areas of high risk have already established emergency plans (and, unfortunately, may already have had to test those plans), many others have not yet thought through the full impact of all potential disaster scenarios. That will change soon, though, as home care agencies must meet the CMS Emergency Preparedness Requirements by November 15, 2017.
How can agencies ensure they’re prepared for the unexpected?
What the CMS Emergency Preparedness Requirements Include
CMS established emergency preparedness standards in November 2016 to ensure agencies across 17 provider and supplier types would be adequately prepared to provide client care during disasters, which might include pandemic flu outbreaks, hurricanes, chemical spills, earthquakes, or even nuclear attack. The goal is to establish national standards for emergency preparedness for both natural and man-made disasters and ensure agencies know how to coordinate with all federal, state, and local emergency preparedness systems.
Once the new rules are enacted, an agency must be able to provide a surveyor with documentation they have met CMS’s requirements and must be able to show where the agency’s plans are located. These plans will be incorporated into the agency’s Conditions of Participation (CoP) or requirements for certification.
CMS’s requirements revolve around four pillars of a comprehensive preparedness framework:
- Risk assessment and planning. Assess risks using an “all hazards” approach, identifying the capacities and capabilities that will be critical to be prepared for a full range of possible emergencies and disasters. Based on this assessment, create an emergency plan for the agency that outlines how the agency will ensure continuity of services and how it will coordinate with all government response plans.
- Policies and procedures. Based on the emergency plan and risk assessment, agencies must establish policies and procedures that will ensure they can adequately respond to the identified needs for staff and clients. Policies must include subsistence needs, evacuation plans, procedures for sheltering in place, and tracking of both staff and clients during an emergency.
- Communication plan. To protect the health and safety of staff and clients during an emergency, agencies must establish a detailed communication plan. The plan should include alternate plans in the event of no internet access or power outages, and should outline how medical records and client information will be shared with other care providers and emergency responders.
- Training and testing programs. Staff should be trained at least annually on emergency procedures. Additionally, agencies must complete at least two demonstration exercises per year, including one table-top exercise that includes a facilitator-led group discussion of a narrated, clinically relevant scenario, and one full-scale demonstration in which agencies simulate an actual emergency and practice a response involving actual agency operations. (Note that if an agency has activated their emergency plan during the year due to an actual disaster, the agency is exempt from the full-scale exercise for that year but must still complete a table-top exercise.)
Online training is available for both surveyors and providers. (The training, available here, is ostensibly for surveyors. However, providers can register for this training as well; simply select “I am a Provider” when prompted on the training website and search for the course.)
CMS has also created a helpful downloadable checklist to help agencies think through how they will meet these four pillar requirements.
Key Elements to Consider When Creating an Emergency Plan
As agencies create their own emergency plans, they need to think through all the possible disaster scenarios and how they might respond in each one. This means asking tough questions.
How will we access client data during internet outages?
With many agencies relying on mobile solutions to provide and document care, what happens if cell towers are damaged in a natural disaster? Two weeks after Hurricane Maria struck Puerto Rico, 88% of cell sites were still out of service, and only 40% of those on the island had Wi-Fi, cell service, or internet access. Agencies must ensure they have alternative methods, such as pagers or satellite phones, to communicate efficiently with staff.
Internet outages likely mean agencies will lose access to electronic medical records (EMRs). Agencies may therefore want to explore implementing an electronic solution that stores staff/client schedules and client/visit data and is accessible even when the system is offline. This would eliminate the need for paper documentation during the outage and enable the agency to securely store data until it can be synced with the EMR once systems come back online.
How will we prioritize client care and staff assignments?
While continuity of care is always a top goal, it might not be feasible during a disaster. Upon intake, staff should assign patients an acuity ranking, ranging from those patients who require uninterrupted services (e.g., patients who are on life-sustaining equipment) to those whose visits can be delayed 72 hours or more with little risk of adverse effects.
The ability to see this prioritization on clients’ EMRs will ensure the agency can safely determine the order of clients to be seen during an emergency.
How will we determine which clients should be evacuated, and when?
Agencies should establish evacuation plans, identifying routes, methods of transportation, and evacuation facilities for staff and clients in the event of emergency. Staff should keep a kit in their cars that keeps supplies like blankets, nonperishable food, bottled water, and emergency power supplies, in the event evacuation routes are blocked.
Keep in mind that for some vulnerable patients, evacuation may place them at greater risk than sheltering in place. Agencies should also register patients who require uninterrupted power for life support equipment with local utility companies and emergency responders.
And finally, every client should be provided with an adequate amount of medical supplies (e.g., catheter supplies, wound care, etc.) and medication to have on hand in case of emergency. As providers replenish these supplies, they should work with the client to demonstrate and review self-care procedures to perform if agency personnel are unable to reach the client.
How will we monitor staff locations?
Office staff must be able to identify and track the locations of each caregiver in order to route them to the nearest, highest-priority clients. Mobile solutions with GPS-based location services can help office staff identify real-time locations of field staff and direct them to in-need clients.
How will we protect sensitive client data?
Agencies must ensure they have a secure method for protecting sensitive health data when it’s shared with emergency responders, family, and other providers. An encrypted electronic solution can ensure personal data is adequately protected.
Unfortunately, crisis situations are always a possibility. Home health agencies must be ready to expect the unexpected, so they can be confident in their ability to provide necessary services even when the worst happens. Implementation of CMS’s emergency preparedness requirements is an important part of that readiness plan.
CellTrak’s Care Delivery Management solution can play a critical role in your ability to be prepared for disaster. Contact us today to learn more about how our solution can help your agency meet CMS’ emergency preparedness requirements and be ready for any scenario.