Effective November 15, 2017, all Medicare providers and suppliers should have an emergency preparedness plan for natural as well as human-made disasters.
What does this mean? Well, that varies among suppliers and providers, but there are four elements that any adequate plan for disaster must encompass: an emergency plan, policies and procedures, a communication plan, and training and testing. Let’s dig into these elements one by one for a more thorough understanding of what’s expected of Medicare and Medicaid providers and suppliers come November.
Emergency Plan
Taking into account the patient population, the most likely scenario for internal emergencies, man-made disasters, and natural disasters, the provider or supplier should develop a plan that is based on an all-hazards risk assessment. The planning should be sufficiently thorough to encompass a variety of potential emergencies including but not limited to:
- Dam Failure
- Drought
- Earthquake
- Flood
- Tornado
- Wildfire
- Hurricane
- Winter Storm
- Power Failure
- Nuclear Attack
- Active Shooter
Should the provider be a healthcare system, consisting of multiple separately certified healthcare facilities that elects to have a unified and integrated emergency preparedness program, the facility may choose to participate in the healthcare system's coordinated emergency preparedness program. If the center chooses to utilize an integrated emergency preparedness program, it must show that each facility actively participated in the development of the emergency preparedness program. The program must take into account each separately certified facility's unique circumstances, patient populations, and services offered. All participants must demonstrate that they are capable of using the program
Policies and Procedures
Per the Centers for Medicare & Medicaid Services, or CMS, every facility should develop and implement the policies and procedures that make up the facility’s emergency plan, addressing the the risks previously identified. These procedures and policies should include, at minimum, the following:
- Food for staff and patients
- Water for staff and patients
- Medical supplies for staff and patients
- Alternate sources of energy for lighting and temperature
In addition to these provisions, facilities should determine when transfer would be appropriate, and how it would be enacted. Also, if applicable, the facility should have a predetermined method of tracking patients as well as staff both during and after the emergency as well as a method of alerting the patients’ families and friends as to their whereabouts.
Communication Plan
In the event of emergency, every facility should have a plan to coordinate the care of their patients between healthcare providers, with consideration made for both state and local health departments as well as emergency management agencies and their systems.
Alternative methods of communication, such as satellite-based internet, cell phones, and pagers should be in place, as should a method of sharing information pertaining to patients should evacuation occur and patients be transferred to a different facility.
Another form of communication is WatchPoint AtRisk Registry, a single source for local emergency managers that offers critical care information and an up-to-date location for vulnerable patients within the community. This will ensure that patients including those on life support, homebound, elderly, disabled, or people with special needs will have the care they need should an emergency occur.
Above all, a facility should be able to undertake this communication quickly— no one wants patient care to suffer because the facility is slow to share the required information.
Training and Testing
Last, but not least, CMS requires facilities to implement annual emergency preparedness training and testing programs, complete with exercises and drills to determine if the program created will function well in the event of a true emergency.
CMS requires a community-based drill as well as a second drill of the facility’s choosing, but because these exercises are so significantly impacted by supplier and provider type, the requirements vary. Regardless of the type of provider or supplier, these exercises should help shape the emergency training that goes on throughout the year. This training should also be documented as proof of compliance coupled with the results of the required exercises or drills. Should a drill or exercise point out weak spots in the plan, it should be reviewed and modified.
This new mandate is intimidating for many providers and suppliers, but if they adhere to the elements listed above, they’ll not only adhere to CMS’s rules, but improve their emergency preparedness should the worst occur.
Brightgray’s cloud-based portal, WatchPoint AtRisk Registry, offers anyone involved in emergency planning for vulnerable patients the robust reporting and administrative capabilities that make data management, planning, and coordination more efficient than ever before. Click here to request a demo today.
