How to Prepare for the New CMS Rule for Emergency Preparedness
The new 186-page rule is a complete paradigm-shift in how providers prepare and respond to emergencies.
Jaime Todd
4/24/2017
New emergency
preparedness requirements included in a Centers
for Medicare & Medicaid Services (CMS) final rule titled Medicare and Medicaid Programs; Emergency Preparedness Requirements for
Medicare and Medicaid Participating Providers and Suppliers, became effective Nov. 15, 2016 and the implementation
date is Nov. 15, 2017.
All
Hazards Focus
Emergency Preparedness Plans (EPPs) must now comprehensively
focus on the “All Hazards” approach to emergency management. An “All Hazards” approach includes mitigation,
preparedness, response, and recovery, and must address protocols to eliminate
or minimize disruptions to providers during emergency incidents.
The new CMS rule requires that providers prepare
for natural and/or man-made disasters following nationally recognized protocols
and requirements. The Federal Emergency Management Agency (FEMA), National
Incident Management System (NIMS), and the Incident Command System (ICS) are
referenced throughout the CMS rule. There are also specifications that providers
coordinate their EPP with local, state, and federal agencies.
Together with the providers’ state and local
requirements for emergency management policies, the EPP must outline a
comprehensive response plan for a full spectrum of emergencies and disasters.
There are three overarching concepts in the new rule: safeguard human
resources, maintain business continuity, and protect physical assets. There are
four categories for implementation: risk assessment and emergency planning,
policies and procedures, communication plan, and training and testing.
Follow this Basic Format
The rule does not specify a template to follow
in the development of the emergency preparedness plan. However, adopting the protocols
of FEMA, NIMS, and ICS, as referenced in the CMS rule, is recommended. The following
basic format includes FEMA protocols as well as the required components of a hazard
vulnerability analysis (HVA) and starts with the section titled: “Purpose.”
Purpose
Describe how your EPP is an “All-Hazards”
approach for emergency planning and response: All-Hazards is an integrated
approach to emergency preparedness planning that places a focus on
capabilities/capacities that are essential for effectively responding to
emergencies and disasters. The EPP applies to all members of program
administration and staff in all departments. The EPP also applies to non-staff
members who perform work at the site including clinical providers, technicians,
contractors, students, volunteers, and ancillary staff.
Services Available
Describe your facility and operation. An example
for a nursing home could include square footage, number of rooms and beds,
clinical and other services offered, programming, and departments, etc. Mention
whether the facility can potentially serve to temporarily support an influx of
injured or medically compromised patients during a disaster.
Authority, Situation,
and Assumptions
Detail oversight authority of the operation (i.e.,
board of directors [BOD], CEO, executive director, etc). Outline positions
responsible for day-to-day management. Describe who’s in charge when senior
staff are absent. In the case of an emergency after normal working hours—a
worst case scenario—detail emergency preparedness plan protocol that applies to
most senior staff on duty.
Situation description for a skilled nursing
facility would include physical plant outline, 24/7 operation, bed-capacity,
departments, number of staff, and that the facility is responsible for the
safety and protection of its residents and staff. Merge into the Assumptions
category by revealing that facility staff have received EPP training for a worst-case
scenario and will mobilize off-duty personnel to mitigate vulnerabilities and
assumptions:
Assumption
examples:
- Emergencies and
disasters can occur without notice, any day, and on any shift.
- Local authorities can
declare an emergency and the disaster may be local or state-wide
- The facility may receive
requests for resource support (supplies, equipment, staffing, or shelter) from
other health care facilities.
- Facility security may be
compromised during an emergency.
- Emergency may exceed the
facilities’ capabilities and external emergency resources may not be available.
Therefore, the facility will manage the incident without these resources.
Mitigation
Mitigation is the procedure for risk analysis
and emergency planning. The goal of mitigation is to eliminate or minimize the impact
of emergencies/disasters on day-to-day operations. During mitigation,
internal/external hazards that pose potential harm to the operation will be
identified and analyzed. Mitigation activities are dynamic and should occur both
before, during, and following a disaster/emergency.
HVA is the primary mitigation tool to highlight
threats and measure potential impact on the operation. HVA is a new concept for
long term care providers and the tendency is to over-analyze the technicality
of the process—but keep it simple. Below is an example of an HVA that addresses
a full-spectrum of potential threats with a simple classification and
measurement system:
Hazard Vulnerability
Analysis (HVA)
|
0=None
1=Rare
2=0ccasional
3=Frequent
Event
|
0=No
Impact
1=Limited
2=Substantial
3=Major
Impact
|
0=No
Impact
1
-Limited
2=Substantial
3=Major
Impact
|
Total
Risk
Number
|
Hazard
|
Likelihood
of Event
|
Impact
on
Population
|
Impact
on Property
|
Total
|
Dam Failure
|
1
|
2
|
2
|
5
|
Drought
|
2
|
2
|
1
|
5
|
Earthquake
|
2
|
2
|
3
|
7
|
Flood
|
1
|
1
|
1
|
3
|
Tornado
|
0
|
0
|
0
|
0
|
Wild Fire
|
1
|
1
|
1
|
3
|
Winter Storm (Severe)
|
1
|
1
|
1
|
3
|
Hazard Materials
Transportation
|
1
|
1
|
1
|
3
|
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