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Implementing an Effective CMS Emergency Communications Plan

You’ve spent countless hours developing a new emergency plan. But if the communications portion of your plan is lacking, it’s not quite ready for prime time yet.

Brightgray Solutions, a leader in disaster preparedness, has gathered a big list of best practices for implementing an emergency communications plan effectively. Here are some tasks to add to your list.

Task #1: Act With Urgency

The deadline to have your plan in place has already passed. It was November 15, 2017. We’ve heard that government surveyors are already out in the field, so don’t wait to implement your plan.

Task #2: Establish a Chain of Command

Who’s in charge during an emergency? Decide on a chain of command, and communicate it clearly. The chain of command includes the order in which you notify emergency services, like 911 and public utilities.

Task #3: Gather Contact Information

Your plan needs a patient contact list, which needs to be maintained in a disaster management software. Make sure you include: employees, patients, patients’ families, first responders, government agencies, public utilities, community groups, tribal organizations, systems management companies, security partners, and your financial and insurance companies.

Task #4: Provide Alerts

During a crisis, all of the groups mentioned above will need to stay connected with constant updates - especially your staff and patients. Have a method in place to provide alerts as circumstances change.

Task #5: Establish Pre-recorded Messages

Pre-recorded messages are a great way to offer emergency alerts on a moment’s notice. These messages can be sent to local emergency management departments, your staff contact list, patients’ families, and more.

Task #6: Make it Cloud-Based

It’s best to have several methods of storing your plan. Cloud-based storage ensures it stays out of reach of local disasters. A flood or fire could ruin your paper copies. A cyber attack could make your electronic copies inaccessible. But cloud-based storage means as long as someone in your organization can access the internet, your plan is ready and waiting.

Task #7: Build in Redundancy

Just as it’s a good idea to have several ways of storing your plan, it’s a good idea to have multiple methods of communicating about the plan during a disaster. Set up email templates, text-message templates, social media posts, scripts for media outlets, and official printed notices that can be posted on the exterior of your building. You’ll be glad to have options during an actual crisis.

Task #8: Communicate and Update

Provide a copy of your plan to local disaster-related agencies, check in with them to ensure they clearly understand it, and have a schedule in place to give them timely updates. Make someone responsible for giving them a new copy of your plan annually, at the minimum.

Develop procedures for notifying local and State emergency management agencies of your facilities vulnerable, at-risk patients for evacuation assistance purposes. This component of the Communication Plan is especially important for home health agencies, homebound hospices and PACE providers as defined in each of the specific chapters of CFR 42 that relate to those facility types.

Task #9: Communicate Part Two

The need for health care providers, in particular homebound hospices, home health agencies and PACE providers, to maintain documentation of their emergency management agency communication for survey certification purposes. Include bullet points emphasizing the policies and procedures of those provider types must address:

  • When and how this information is communicated to emergency officials
  • Also include the clinical care needs of those at-risk patients to facilitate the patient’s evacuation and transportation including, but not limited to, the following:
    • Whether or not the patient is mobile.
    • What type of life-saving equipment does the patient require?
    • Is the life-saving equipment able to be transported? (E.g., Battery operated, transportable, condition of equipment, etc.)
    • Does the patient have special needs? (E.g., Communication challenges, language barriers, intellectual disabilities, special dietary needs, etc.)

Since such policies and procedures include protected health information of patients, facilities must also ensure they are in compliance with applicable the Health Insurance Portability and Accountability Act (HIPAA) Rules at 45 CFR parts 160 and 164, as appropriate. See (81 FR 63879, Sept. 16, 2016).

Surveyors have already begun reviewing for a facility's Communication Plan, looking to verify that it includes procedures to inform State and local emergency preparedness officials. They want to know about patients in need of evacuation from their residences due to an emergency situation. They want to see detailed the patient’s medical and psychiatric condition and home environment. This will help make sure emergency responders have the right equipment needed.

This all sounds like a huge undertaking, but software services like WatchPoint AtRisk Registry can make this process quick and easy.

Task #10: Use Response Tracking

A crucial aspect of emergency communications is tracking the responses received from stakeholders. In the healthcare field, this is especially important since your facility is responsible for patients’ wellbeing. In an evacuation situation, you need to know exactly who is where, and what their status is. Add digital response tracking to your communications program, and you’ll have a clear picture of what’s happening.

Always Have a Plan B, C, D …

Things don’t always go according to plan during an emergency. Make sure your facility has numerous alternate options that can be implemented, depending on the circumstances. Brightgray's WatchPoint AtRisk Registry provides the flexibility to assist people during a disaster, no matter what happens. It’s a sophisticated emergency management platform that can handle a huge amount of communications information.

Click here for a free demo of WatchPoint AtRisk Registry to ensure your facility stays within the law and at the forefront of disaster preparedness.

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