Emergency Preparedness Requirements

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Emergency Preparedness Requirements National Hospice and Palliative Care Organization October 2018 Objectives Identify key elements of an effective emergency plan Describe the final rule by standard

1 Emergency Preparedness Requirements National Hospice and Palliative Care Organization October 2018 Objectives Identify key elements of an effective emergency plan Describe the final rule by standard and compliance expectations for 11/15/17 Discuss how to plug into your state and community emergency preparedness system 2 Diagram from Understanding the Emergency Preparedness Final Rule, The Centers for Medicare and Medicaid Services,

418.113 Condition of participation: Emergency preparedness Addition to CoPs, Subpart D The hospice must comply with all applicable Federal, State, and local emergency preparedness requirements.

2 Condition of participation: Emergency preparedness Addition to CoPs, Subpart D The hospice must comply with all applicable Federal, State, and local emergency preparedness requirements. The hospice must establish and maintain an emergency preparedness program that meets the requirements of this section. The emergency preparedness program must include, but not be limited to, the following elements: 4 What are the Parts of the Program? Threat and Risk Assessment Emergency Plan Policies and Procedures Communications Training and Testing 5 CoP Standards (a) Risk assessment and planning (b) Policies and procedures Emergency preparedness program (c) Communication plan (d) Training and testing 6 2

3 The Threat and Risk Assessment 7 Providers must complete and document an all hazards risk assessment Step 1 Identify risks and hazards Step 2 Select risks to address Step 3 Develop a plan to address selected risks 8 The Guidance and Practical Application Guidance: Risk assessments must: Must be documented Be specific based on facility & community Consider all possible risks for location Consider patient population Utilize an all-hazards approach Practical Application: You may want to: Mirror local risk assessments Mirror assessment of similar businesses Start with sampling many other risk assessments Include as many disciplines as possible in the process 9 3

4 Collaboration with Community Networks, Partnerships, Mutual Aid Make sure your patients get counted / your needs addressed Social Media How to provide support. Your Capabilities Your Availability 10 Partnerships and Relationships Get Creative on support and resources: New avenues for volunteer support: 4-wheel drive club as part of a transportation plan Shallow-water boat owners Ham Radio operators Collaborate with competitors Disaster preparedness is not a completive point New trend in Grant programs is mutual aid agreements Partnerships outside the industry or outside the area Mutual program development with new partners 11 The Emergency Plan 12 4

(a) Emergency Plan Develop an emergency plan based on an all hazard risk assessment focusing on capacities and capabilities Update emergency plan at least annually Include strategies for

hospice's ability to provide care 13 Truths about Disaster Preparedness and Response It only works when done in collaboration Preparedness is a team sport Success is more about

5 (a) Emergency Plan Develop an emergency plan based on an all hazard risk assessment focusing on capacities and capabilities Update emergency plan at least annually Include strategies for addressing emergency events identified by the risk assessment, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice's ability to provide care 13 Truths about Disaster Preparedness and Response It only works when done in collaboration Preparedness is a team sport Success is more about relationships, communication, and understanding than capabilities It is better to do more effort before a disaster than during one The disaster site is not the best place to be exchanging business cards

6 Issues for Consideration The only way to ask for assistance or offer your assistance before, during, or after an emergency situation is to communicate with others. Identify sources for information, and appoint capable staff to receive and interpret it on behalf of the organization. 16 Policies and Procedures 17 (b) 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 18 6

7 Additional Requirements for Hospice Inpatient Facilities A means to shelter in place for patients, hospice employees who remain in the hospice Safe evacuation from the hospice, which includes consideration of care and treatment needs of evacuees; staff responsibilities; transportation; identification of evacuation location(s) and primary and alternate means of communication with external sources of assistance 19 Additional Requirements for Hospice Inpatient Facilities A system to track the location of hospice employees' on-duty and sheltered patients in the hospice's care during an emergency If the on-duty employees or sheltered patients are relocated during the emergency, the hospice must document the specific name and location of the receiving facility or other location 20 Hospice Inpatient Units Maintain generators in accordance with National Fire Protection Association (NFPA) guidelines Conduct generator testing, inspection, and maintenance as required by NFPA Maintain sufficient fuel to sustain power during an emergency 21 7

8 The Communication Plan 22 (c) 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. Home health agencies and hospices required to inform officials of patients in need of evacuation. Review and update plan annually. 23 The Communication Plan Must Include Names and contact information for the following: Hospice employees Entities providing services under arrangement Patients' physicians Other hospices Contact information for the following: Federal, State, tribal, regional, and local emergency preparedness staff Other sources of assistance 24 8

9 The Communication Plan Must Include Primary and alternate means for communicating with the following: Hospice's employees Federal, State, tribal, regional, and local emergency management agencies A method for sharing information and medical documentation for patients under the hospice's care, as necessary, with other health care providers to maintain the continuity of care A means, in the event of an evacuation, to release patient information as permitted under 45 CFR (b)(1)(ii) 25 Disasters and HIPAA Providers and health plans covered by the HIPAA Privacy Rule can share patient information for treatment, payment, and operations without patient authorization. Even if a state law is stricter than HIPAA and requires authorization prior to disclosing PHI for treatment, any personal health information necessary for treatment may be shared in an emergency without authorization. 26 Practical Approach to a Communication Plan Think like you are in a disaster Do not count on all the communications/it systems that you use today are going to be available We have all of our medical records on a backup server... but it is in the flooded basement Who will you need to reach? Have a primary and secondary means of communication Nothing gets better without power, figure out how to communicate without primary power. 27 9

10 Training and Testing 28 (d) Training and Testing Develop and maintain training and testing programs, that is based on the emergency plan, risk assessment, policies and procedures, and the communication plan Maintain documentation of all emergency preparedness training 29 Training Program Requirements Initial training in emergency preparedness policies and procedures to all new and existing hospice employees, and individuals providing services under arrangement, consistent with their expected roles Demonstrate staff knowledge of emergency procedures Provide emergency preparedness training at least annually 30 10

Training Program Requirements Periodically review and rehearse its emergency preparedness plan with hospice employees (including nonemployee staff), with special emphasis

exercise Analyze response and document the event 32 Testing Requirements Exemption If the hospice experiences an actual natural or manmade emergency that requires activation of

11 Training Program Requirements Periodically review and rehearse its emergency preparedness plan with hospice employees (including nonemployee staff), with special emphasis placed on carrying out the procedures necessary to protect patients and others 31 Participate in full scale community based exercise A second full scale exercise or table top exercise Analyze response and document the event 32 Testing Requirements Exemption If the hospice experiences an actual natural or manmade emergency that requires activation of the emergency plan, the hospital is exempt from engaging in a community-based or individual, facilitybased full-scale exercise for 1 year following the onset of the actual event 33 11

12 Analyze Outcomes Analyze the hospice's response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the hospice's emergency plan, as needed 34 Practical Approach to Training and Testing Table Tops are easy and kind of fun Rehearsed decision making Only good if multidisciplinary; preferably with some external partners Simply gather all the relevant participants, introduce a scenario, and walk through the process. Test assumptions, understand what other elements are doing, check the hand-offs and support arrangements Take copious notes and follow-up with process changes 35 (e) Integrated Healthcare Systems If a hospice is part of a healthcare system consisting of multiple separately certified healthcare facilities that elects to have a unified and integrated emergency preparedness program, the hospice may choose to participate in the healthcare system's coordinated emergency preparedness program 36 12

13 Requirements for Integrated Healthcare Programs Demonstrate that each separately certified facility within the system actively participated in the development of the unified and integrated emergency preparedness program Be developed and maintained in a manner that takes into account each separately certified facility's unique circumstances, patient populations, and services offered Interpretive Guidelines Interpretive Guidelines (IGs) are formatted into one Appendix. Advanced Copy of Interpretive Guidelines: New Appendix Z of the State Operations Manual (SOM) contains the interpretive guidelines and survey procedures for the Emergency Preparedness Final Rule for all provider types. Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert- Letter pdf Interpretive Guidelines The tags for emergency preparedness will be E Tags and accessible to both health and safety surveyors and LSC Surveyors. State survey agencies will have discretion regarding whether the LSC or health and safety surveyors will conduct the emergency preparedness surveys. Note: Surveying for compliance with the emergency preparedness requirements does not begin before November 15,

14 Survey Issues Missing agreements with other hospice providers No individual patient emergency preparedness plans Lack of evidence of two exercises Events 41 Psychology of a Disaster The focus narrows significantly If you do not make checklists in non disaster time, you may forget what needs to be completed Compliance is not the primary focus during a disaster but you will be surveyed for compliance withy requirements 42 14

15 Lead Up to a Disaster Lean forward proactive response May be conflict with some business models 43 Things To Consider

Post Joplin Tornado - 2011 49 1135 Waivers An 1135 Waiver is an allowance under section 1135 of the Social Security Act (SSA) and relaxes regulatory requirements in a disaster area or during an

17 Post Joplin Tornado Waivers An 1135 Waiver is an allowance under section 1135 of the Social Security Act (SSA) and relaxes regulatory requirements in a disaster area or during an emergency situation. An 1135 Waiver can be requested by a State or individual provider when: The U.S. President declares a major disaster or an emergency under the Stafford Act or an emergency under the National Emergencies Act, and The U.S. Department of Health and Human Services (HHS) Secretary declares a public health emergency. 50 What Can Be Waived The 1135 Waiver allows only regulations that govern provision of care to be waived. Examples Certain conditions of participation certification requirements Deadlines and time tables for performance of required activities to allow timing of such deadlines to be modified Sanctions for non-compliance 51 17

18 What Cannot Be Waived The 1135 Waiver does not allow regulations that govern provision of care to be waived. Example: More than 5 days of respite care 52 Lessons Learned 53 Readiness No matter the disaster type, providers agree that pre-disaster planning and a well-developed and rehearsed emergency plan was critical in preparing for what was to come. Consider completing disaster assessments and preparation plans with each patient as they are admitted to service. Pre-planning can reduce a significant amount of stress for both the hospice provider and their patients

19 Readiness Coordination of services, supplies, staff, medications, and everything else that may be needed pre and post disaster requires a detail oriented approach, out of the box thinking, and diligent follow up. 55 Pearls of Wisdom from Providers A rule of thumb in disaster preparedness is to be ready to self-sustain for 3-5 days. What if it is longer? Provide real cash advances to staff before a disaster event. ATM machines and credit card processors will not work during power outages post disaster and cash may be the only currency accepted to buy gas, food, and supplies. 56 Pearls of Wisdom from Providers Take care of your staff. Give them time before the emergency event to take care of their family and make arrangements. Coordinate with the state and local emergency management agency to discuss staging areas for supplies, fuel, generators, and charging stations

Pearls of Wisdom from Providers Communicate with providers outside of your service area pre-disaster to discuss care and placement of patients as needed.

20 Pearls of Wisdom from Providers Communicate with providers outside of your service area pre-disaster to discuss care and placement of patients as needed. Travel contracts with hospice providers Memorandums of understanding with temporary facilities for inpatient care 58 NHPCO resource Emergency Preparedness for Hospice Providers (Feb 2017) regulatory/emergencypreparedness-0 59 Another Helpful Resource ASPR TRACIE Technical Resources, Assistance Center, and Information Exchange (TRACIE) meets information and technical assistance needs of healthcare coalitions, healthcare providers, emergency managers, public health practitioners, and others working in disaster medicine, healthcare system preparedness, and public health emergency preparedness 60 20

21 61 NHPCO members enjoy unlimited access to regulatory and quality reporting assistance Feel free to questions to or

22 How to keep up NHPCO provider members have access to: NHPCO News Briefs Every Thursday Regulatory and compliance updates every week Regulatory Alerts For time sensitive and important regulatory issues Sign up to receive regulatory alerts Regulatory Round Ups Once a month, all regulatory issues summarized My.NHPCO regulatory entries for specific groups 64 22

EMERGENCY PREPAREDNESS ACUTE CARE

EMERGENCY PREPAREDNESS ACUTE CARE Medicare and Medicaid Programs; Emergency Preparedness; Requirements for Medicare and Medicaid Participating Providers and Suppliers 42 CFR 482.15 Published September 16, 2016; Effective November 15, 2016;