CHHS Staff Educate Healthcare Facilities on Emergency Preparedness Planning
Recently, two members of the CHHS, Senior Law and Policy Analyst Netta Squires and Senior Policy Analyst Ashley McKibbin helped their client, Montgomery County Office of Emergency Management and Homeland Security (OEMHS) conduct the first every Emergency Preparedness Planning for Montgomery County Healthcare Facilities Workshop. The workshop was prompted by various requests and questions that various Montgomery County government agencies were receiving in regards to the new Centers for Medicare & Medicaid Services (CMS) Emergency Preparedness Rule.
Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers (81 FR 63859) states that facilities must have the following components:
- Risk assessment and emergency planning: – facilities required to perform a risk assessment that uses an “all-hazards” approach prior to establishing an emergency plan
- Policies and procedures: – facilities required to develop and implement policies and procedures that support the successful execution of the emergency plan
- Communication plan:facilities required to develop and maintain an emergency preparedness communication plan that complies with both federal and state law. . . . have a system to contact appropriate staff, patients’ treating physicians, and other necessary persons in a timely manner
- Training and testing: facilities required to develop and maintain an emergency preparedness training and testing program.
According to the Interpretative Guidance, facilities are required to develop an emergency preparedness program that meets all of the standards specified within the condition/requirement. The emergency preparedness program must describe a facility’s comprehensive approach to meeting the health, safety, and security needs of their staff and patient population during an emergency or disaster situation. The program must also address how the facility would coordinate with other healthcare facilities, as well as the whole community during an emergency or disaster (natural, man-made, facility). The emergency preparedness program must be reviewed annually.
An effective emergency preparedness program for healthcare facilities is more important than ever in light of the recent hurricanes in Florida, Texas, and Puerto Rico and the impact those storms had on the healthcare sector specifically. The story of 14 dead at The Rehabilitation Center at Hollywood Hills in the aftermath of Hurricane Irma was the most s CHHS Staff Educate Healthcare Facilities on Emergency Preparedness Planning striking example.
The new rule, finalized last year, will be enforced starting on November 15, 2017 and affects Conditions of Participation and Conditions for Coverage for Medicare and Medicaid. With this in mind, McKibbin and Squires began working with Montgomery County OEMHS, Montgomery County Department of Health and Human Services (HHS) Public Health Emergency Preparedness (PHEP) Program, and the Region V Hospital Coalition to plan the workshop in early July. One of the main struggles of the core planning team was how to communicate such important and detailed information to so many different facility types. The core planning team wanted to make the workshop accessible for the greatest number of participants in the county; it was decided that the presentation would be a broad overview of the four components of the new rule (risk assessment and emergency planning, policies and procedures, communication plan, and training and testing) while also allowing for engagement with speakers immediately after their talks and as part of a question and answer panel.
Speakers discussed such topics as Business Continuity Planning, Hazard Vulnerability Assessment, and Medical Surge. Ms. McKibbin spoke to attendees about the general CMS regulations overview, survey results from attendees, and training and testing. She also participated in the question and answer panel with all the speakers and additional subject matter experts.
In addition to the presentations themselves, the team was also able to provide attendees with templates and other resources through the Emergency Preparedness Planning for Healthcare Facilities website which was created specifically for this event. This website continues to be updated to provide facilities in the County with the most up to date information on training and testing opportunities, Montgomery County threats and hazards, and resources from CMS.
The workshop provided an important opportunity for healthcare facilities to engage with local emergency management personnel. This kind of partner engagement is critical to building a more resilient and prepared community. McKibbin and Squires continue to help OEMHS expand these partners. Ms. Squires works with the Region V Healthcare Coalition and MOCEP and Ms. McKibbin collects the emergency planning program documents from facilities in the county and updates the Emergency Preparedness Website.
The entire CHHS staff continues to work with clients to helps address needs and responsibilities related to the new CMS regulations. CHHS recognizes that individual healthcare facilities are especially challenged in navigating the emergency preparedness landscape. Small and medium sized facilities have limited resources to devote to emergency preparedness planning on top of what they do on a daily basis. This does not mean however that they do not have a business interest and a responsibility to their clients and patients to be prepared. CHHS is working to provide guidance and realistic solutions to small and medium sized healthcare facilities in order to incorporate emergency preparedness planning and policy considerations into their daily operations.