1/25/2017 DISCLOSURES

Transcription

1 DISCLOSURES The speakers, Caecilia Blondiaux and Kristine Sanger, disclose no actual or potential conflict of interest in relation to this program/presentation. The following planning staff report no actual or potential conflict of interest in relation to this program/presentation. Carol McLay DrPH, MPH, RN, CIC Hannah Andrews 1

2 CMS Emergency Preparedness Rule Understanding the Emergency Preparedness Final Rule How does this relate to Infection Control? Caecilia Blondiaux Survey & Certification Group Centers for Medicare & Medicaid Services Final Rule Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Published September 16, 2016 Applies to all 17 provider and supplier types Implementation date November 15, 2017 Compliance required for participation in Medicare Emergency Preparedness is one new CoP/CfC of many already required 4 2

3 Four Provisions for All Provider Types Risk Assessment and Planning Policies and Procedures Emergency Preparedness Program Communication Plan Training and Testing 8 Risk Assessment and Planning Develop an emergency plan based on a risk assessment. Perform risk assessment using an all-hazards approach, focusing on capacities and capabilities. Update emergency plan at least annually. 9 3

4 Policies and Procedures Develop and implement policies and procedures based on the emergency plan and risk assessment. Policies and procedures must address a range of issues including subsistence needs, evacuation plans, procedures for sheltering in place, tracking patients and staff during an emergency. Review and update policies and procedures at least annually. 10 Communication Plan Develop a communication plan that complies with both Federal and State laws. Coordinate patient care within the facility, across health care providers, and with state and local public health departments and emergency management systems. Review and update plan annually. 11 4

5 Training and Testing Program Develop and maintain training and testing programs, including initial training in policies and procedures. Demonstrate knowledge of emergency procedures and provide training at least annually. Conduct drills and exercises to test the emergency plan. 12 Emergency and Standby Power Systems Additional requirements for hospitals, critical access hospitals, and long-term care facilities. Locate generators in accordance with National Fire Protection Association (NFPA) guidelines. Conduct generator testing, inspection, and maintenance as required by NFPA. Plan to maintain and keep emergency power systems operational 13 5

6 Requirements Vary by Provider Type Outpatient providers are not required to have policies and procedures for the provision of subsistence needs. Home health agencies and hospices required to inform officials of patients in need of evacuation. Long-term care and psychiatric residential treatment facilities must share information from the emergency plan with residents and family members or representatives. 14 Interpretive Guidelines (IGs) The IGs are sub regulatory guidelines which establish our expectations for the function states perform in enforcing the regulatory requirements. Facilities do not require the IGs in order to implement the regulatory requirements. We note that CMS historically releases IGs for new regulations after the final rule has been published. This EP rule is accompanied by extensive resources that providers and suppliers can use to establish their emergency preparedness programs. Federal Register /Vol. 81, No. 180 / Friday, September 16, 2016 /Rules and Regulations

7 Compliance Facilities are expected to be in compliance with the requirements by 11/15/2017. In the event facilities are non-compliant, the same general enforcement procedures will occur as is currently in place for any other conditions or requirements cited for non-compliance. Training for surveyors is under development 18 The SCG Website Providers and Suppliers should refer to the resources on the CMS website for assistance in developing emergency preparedness plans. The website also provides important links to additional resources and organizations who can assist. Enrollment-and- Certification/SurveyCertEmergPrep/index.html 19 7

8 The SCG Website Continued Left Links on the website provide a variety of resources available The SCG Website Continued 8

9 FAQs Frequently Asked Questions (FAQs) have been developed and are posted on the CMS Emergency Preparedness Website Enrollment and Certification/SurveyCertEmergPrep/Emergency Prep Rule.html We will continue to edit and post new FAQs as inquiries are received. Collaboration with ASPR TRACIE SCG has been collaborating for several months with the ASPR TRACIE SCG s primary focus is on the development of Interpretive Guidelines and Surveyor Training Currently working to provide additional recommendations through ASPR TRACIE for stakeholders who are interested in developing training for providers 9

10 Training Considerations Don t Lose Sight of the Intent! Providers/Suppliers and Emergency Preparedness officials should consider aiming training on overall Emergency Preparedness, with integration of the four core elements. Work toward assisting emergency preparedness officials and facility leadership on how to guides i.e. how do you complete a hazard vulnerability assessment/ risk assessment? How do you draft a communication plan? How do Infection Preventionists Play a Role? The emergency preparedness regulation calls for a risk assessment based on an all hazards approach. Taking this into consideration, Infection Preventionists could assist facility leadership to incorporate infectious diseases in their emergency plans. Examples from Lessons Learned Ebola Virus (shortages in PPE, disposal of waste and hazardous material concerns) Zika Virus Influenza 10

11 Recent Example Ebola Virus Shortages in waste disposal Shortages in Personal Protective Equipment (PPE) Lack of staff knowledge in PPE procedures for prevention of transference and de robing Additional Emergency Preparedness Regulation Area for IC The provision of subsistence needs for staff, patients and residents, whether they evacuate or shelter in place, include, but are not limited to the following: (b)(1)(i) Food, water, medical and pharmaceutical supplies (b)(1)(ii) Alternate sources of energy to maintain the following: (b)(1)(ii)(a) Temperatures to protect patient and resident health and safety and for the safe and sanitary storage of provisions; (b)(1)(ii)(b) Emergency lighting; (b)(1)(ii)(c) Fire detection, extinguishing, and alarm systems; and (b)(1)(ii)(d) Sewage and waste disposal. 11

12 What Do These Provisions Mean for You? Infection Preventionists could consider the following if assisting facility s in their emergency planning Loss of power systems could have implications for sewage and waste disposal Loss of power systems which limit ability for heat or air conditioning could lead to increased humidity leading to infection growth Laundry services may become limited, therefore causing increased risk of contamination from staff to patient Limited laundry services could lead to shortages in clean patient clothing and linen causing concerns for infection Thank you! SCGEmergencyPrep@cms.hhs.gov 12

13 CMS and Infection Prevention: How this rule can help you Prepared and presented by: Kristine Sanger, Associate Executive Director, Association of Healthcare Emergency Preparedness Professionals Revised January, 2014 Objectives Describe the components of the CMS Emergency Preparedness Regulation Provide a list of resources that may help explain the regulation further and help with compliance Review the list of facilities that this rule affects Conduct a dialogue of exercise priorities in response to the CMS Emergency Preparedness Regulation 13

14 Four Core Elements 1. Risk Assessment and Emergency Plan 2. Policies and procedures 3. Communication 4. Training and Testing Program Deadline Must be in full compliance by November 17,

15 Reasons for IP to be involved 1. Keep IPC front and center 2. Team work 3. Highly Infectious Diseases are a Major Emergency Preparedness Concern 4. Communication Policies and Procedures 15

16 Tips Do this process as a committee, team, or group Compare your end results with other community entities' HVA s (i.e. Fire, Emergency Management, Public Health, Hospital, Law Enforcement) 16

17 Exercise Requirements Develop and maintain training and testing programs, including initial training in policies and procedures and demonstrate knowledge of emergency procedures and provide training at least annually. Also annually participate in: A full scale exercise that is community or facilitybased An additional exercise of the facility s choice. Training List types of training to meet priorities and achieve the associated capabilities Identify what training is currently available Determine the training that is needed as a prerequisite to planned exercises and to satisfy prior year Improvement Plans Ensure a building block approach to training 17

18 Exercises Exercise Program Management Exercise Program Objectives Multiyear Training & Exercise Plan Corrective Action Process Be sure to include: Stakeholder engagement Resource Management 18

19 Identify Priorities Risk Assessment/HVA Improvement Plan Recommendations External Requirements Accreditation/Regulation 1. CMS

20 Schedule training and exercises Training and Exercise Plan 2017 Agency Hospital Emergency Management 1 st Qtr 2 nd Qtr 3 rd Qtr 4 th Qtr Jan Feb Mar Apr May Jun Evacuatio n Seminar MERS Co V TTX Training on Evacuation Equipment PPE Workshop Transport Drill Alternate Care Facility Workshop Ju l Aug Sep Oct Nov Dec Evacuation Functional Exercise MERS Co V Patient Full Scale Exercise Public Health Law Enforcement EMS EvacuationUse MERS Co V Hazmat Fire Department HHSS HSEEP AHEPP LLIS NETEC TRACIE Don t reinvent the wheel 20

21 Utilize your partners Local coalitions Public Health Nearby hospitals or LTC s State EMA Associations Evaluate HSEEP Homeland Security Exercise Evaluation Program After Action Report Participant Feedback Hotwash 21

22 Discussion and questions 22