Tragic Deaths Following Hurricane Irma Reinforce Need for Robust Implementation of Health Care Facility Preparedness
The news of the tragic death of eleven Hollywood, Florida, nursing home patients made headlines, and the investigation into what happened continues to make headlines. The facility, which maintained power but lost air conditioning, eventually ended up evacuating its patients to a nearby hospital, but not before eight patients died, and over forty were found in critical states of distress, presumably from the excessive heat within the building.
In a statement, Governor Rick Scott called the situation “unfathomable,” and said that he would “aggressively demand answers.” As a precaution, other nursing homes in the state without power or AC were evacuated. At the time of this writing, the investigation continues into what happened—the nursing home facility reportedly placed repeated calls for help with the county, utility company, and state agencies. Shortly after the evacuation, on September 16th, Governor Scott issued new rules that require nursing homes, within 60 days, to have the resources to “sustain operations and maintain comfortable temperatures” for at least four days after a power failure. However, Florida already had in place regulations that required nursing homes to maintain a temperature between 71 and 81 degrees—so it remains unclear why patients weren’t evacuated to other facilities sooner.
The tragedies of Hurricanes Harvey, Irma, and now Maria, have brought into relief how far emergency preparedness has come, while highlighting the continued need for additional planning and practice in implementing emergency plans and procedures. Hurricane Irma was a record-breaking storm in size and intensity, following on the heels of the record-breaking Hurricane Harvey. Both Irma and Harvey resulted in unprecedented—but predicted—power outages and flooding. Both storms led to multiple hospital evacuations, both prior to and after making landfall. One executive in charge of medical crises preparations and management in Texas said that Hurricane Harvey “challenged every plan we’ve ever written, every resource,” stating that they had even run out of wheelchairs. Florida officials have expressed similar sentiments about the challenges of Hurricane Irma.
Historic events are called historic for a reason. Hurricane Harvey dropped a record-breaking rainfall of close to 52 inches in places, exceeding Houston’s annual average precipitation in less than four days. Hurricane Irma was one of the largest hurricanes ever recorded in the Atlantic. It may be tempting to write these events off as once-in-a-lifetime storms, but as we have learned from other once-in-a-lifetime storms such as Hurricane Katrina and Superstorm Sandy, county, state, and health care facility emergency planners, and the patients and families that depend on them, cannot afford to do so.
Furthermore, many of the steps needed to better prepare health care facilities are already in place. In September of 2016, the Centers for Medicare and Medicaid posted a new final rule for emergency preparedness requirements for Medicare/Medicaid participating facilities. The rule, which goes into effect November of this year, covers 17 facility types—including hospitals, ambulatory surgical centers, hospices, transplant centers, and long term care facilities—and puts into place rigorous requirements for facility risk assessment and emergency planning, communication planning, policies and procedures, and annual testing and training of those plans. Specifically, risk assessment and emergency planning should include, but is not limited to, geographic hazards, equipment and power failures, interruptions in communications, and care-related emergencies. Communication plans should ensure, among other things, that communications are “well-coordinated” not only within the facility and other health care providers, but with state and local public health and emergency management agencies. Finally, facilities will be required to practice implementing plans through annual tabletop or full-scale exercises, which mimic emergencies and give administrators, staff, and other workers an opportunity to practice applying their knowledge and problem solving in a safe environment, from evacuating patients without power to locating and acquiring critical resources. Many of the facilities included in the rule have not been required to meet this kind of federal-level emergency preparedness requirements before. Facilities who do not meet the requirements risk losing CMS funding.
The rule’s efficacy will depend on an administration committed to active enforcement, including funding to help facilities fully and robustly comply with the new guidelines, which meet or exceed those required by state or accrediting organizations. Some have said the rule is unnecessary, given the presence of those state and accrediting bodies. The Joint Commission, for example, is responsible for accrediting approximately 80% of U.S. hospitals by ensuring hospitals’ compliance with state and federal regulations, and already imposes certain emergency preparedness requirements. However, a recent article in the Wall Street Journal cited the Joint Commission’s continued accreditation of hospitals that were routinely, and sometimes grossly, out of compliance with hospital safety requirements—including those already in place by CMS. And on Wednesday, National Public Radio reported findings that many nursing homes remain unprepared “for even the most basic contingencies.”
As we have seen time and again, emergency preparedness requires full participation—and adequate funding—to be successful. Our health care facilities and workers are heroes during “blue sky” times, providing critical services to patients of all ages and conditions everyday. Hurricanes Harvey and Irma brought countless stories of those heroes working tirelessly to provide care or evacuate patients even as flooding or power outages made conditions difficult or dangerous. It is incumbent that we provide these critical response partners, and the patients and families that depend on them, the resources needed to adequately prepare and respond for the next disaster.