A number of months ago, CMS released the Interpretive Guidelines on Emergency Preparedness for all providers. Many have not heeded the warning and we are now at the 11th hour. Your agency must have all plans in place and all drills completed by November 15, 2017. If you have not begun the process, you are not alone.
Where to Begin with Emergency Preparedness
Emergency Preparedness (EP) planning is complicated. Many agencies are struggling to construct a plan that will meet the highly detailed guidelines in place. It is important to begin your journey to EP compliance by reading the rule. You can find it here, in the Draft Interpretive Guidelines for the 2017 Conditions of Participation (CoPs).
Under the guidelines, every agency is required to meet all of the standards within the requirement. Remember, this part of the CoPs is not a draft. CMS has released the emergency preparedness interpretive guidelines and these will not change. First of all, your policies and procedures will require that you show a comprehensive approach to meeting the health, safety, and security needs of individual staff members and your patient population during an emergency or disaster situation. Learn more about the CoPs from QIRT experts here.
Preparing for Disasters
Leadership will need to show surveyors exactly how your agency intends to coordinate with other healthcare facilities in the community should a disaster occur. Most importantly, disaster potential for your area must be studied, and your state website will provide much of this information. State websites for Emergency Preparedness also provide information to help agencies prepare individual disaster plans.
The plan must include (but not limited to):
- Natural disasters
- Man-made disasters
Your facility-based disaster plan must include (but not limited to):
- Care-related emergencies
- Equipment and utility failures, including but not limited to, power, water, gas, etc.
- An interruption in communication, including cyber-attacks, loss of all or portion of a facility, and interruptions to the normal supply of essential resources such as food, war, fuel (heating, cooking, and generators).
In conclusion, you will need to use all the information available from state websites, the CDC, local health departments, FEMA, AHRQ, etc. to formulate your agency’s plan. Surveyors will want to see your agency-specific risk assessment. You will not be able to ‘copy and paste’ from friends in the home care community.
What Should I Do Now?
This is not everything you need to know about the preparation of an Emergency Preparedness Plan, but it is a nice beginning. Consequently, QIRT will continue to share our knowledge because this important preparation is complex. The time to prepare is now.
A number of publishers in home health are preparing draft EP manuals with necessary forms and related documentation that could provide a framework for compliance. QIRT consultants have spent the past year helping agencies prepare for the implementation and preparing sample Policy and Procedures manuals that address this new world order. QIRT expertise will help your agency prepare and allow you to continue to focus on patient care.
Contact QIRT consultants and continue to follow QIRT Alerts for updates on EP compliance and more.