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Disaster Preparedness Planning
CMS requires disaster preparedness planning for healthcare facilities
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Disasters can happen anywhere, and at anytime. Hurricanes Harvey and Irma were two of 75 disasters declared by FEMA in 2017, most of which were due to devastating fires, floods and severe storms, with the potential for others on the horizon. Many of these disasters can have a significant impact on your healthcare organization, your patients, your employees and their families, and the community you serve.
The Centers for Medicare and Medicaid Services (CMS) has created mandatory disaster preparedness guidelines for certain health care providers as a Condition for Coverage or Participation. In addition to these guidelines, CMS also offers a preparedness checklist for all providers.
Don’t be unprepared. Experts agree that advance planning and preparedness can make a significant difference during an emergency.
Advance planning & creating a disaster plan
If you haven’t already, take the time now, before a crisis occurs, to make a disaster plan for your practice or facility. How quickly your company can get back to business depends on the emergency planning done today.
Six key things to include in your disaster plan:
1 | Prepare an office disaster kit
You want to have a kit prepared in advance to allow you to provide basic medical care where necessary. This kit should include some essential medical supplies and equipment and be stored in a safe, easy-to-access location. Below are just a few examples of the types of items to include in your kit:
- Essential business documents
- Computer backups
- Emergency rations, bottled water, flashlights
- Hand sanitizer and other infection prevention items
- Exam gloves and other essential personal protective equipment (PPE)
- Stethoscope, thermometer, etc.
- Prescription pad
- Bandages
2 | Plan for a possible alternate office location or evacuation of your facility
Do some advance research on potential locations where you could continue to care for patients if your primary office is damaged. Consider working with McKesson to set up your alternate site locations before the event occurs (contact your McKesson Account Manager or Customer Service for details). You may also want to purchase a generator for use if the power is out for a period of time.
For healthcare organizations providing in-facility resident care, such as long term care facilities, evaluate and make decisions on Shelter-in-Place (SIP) provisions so you are prepared when a disaster such as flood or prolonged loss of power occurs.
You should also plan for what you will do if your community is not accessible to emergency responders, vendors and employees.
3 | Have backup plans for patient records
This is crucial for your facility. Have multiple backup methods for redundancy, and keep the backups in an off-site location. Also make sure the records are accessible to you and your staff so treatment can continue.
Backup options include:
- Online (cloud) storage
- Remote server
- Portable hard drive
- Flash drive/memory card
4 | Use a team approach by including staff/employees in the planning process
Review disaster preparedness plan details with all staff members on a regular basis. Personal contact information (e.g., cell phone numbers, email addresses, emergency contact information) for all staff should be shared for vital communications during a disaster. Designate critical staff, volunteer coverage, and how to meet staff needs such as transportation to and from work.
5 | Plan for communication with vital stakeholders
Determine how and what you might communicate to patients, residents, family members, and the community in a crisis. Plan for various communications methods, which can include:
- Text messaging
- Social media
- Voicemail
- Word of mouth
6 | Review your plan annually
Perform an internal review of the emergency plan on an annual basis and update if necessary based on factors such as regulatory changes, potential new hazards, and budgetary considerations.
Also consider these topics in your facility’s disaster plan:
- Telehealth and virtual provider interface
- Emergency nutritional supplies
- Personal Protective Equipment (and gear for highly contaminated locations)
- External access to important procedures and protocols
- Staff fatigue and accommodations
Don’t forget to also create a personal and family plan for disaster preparedness. To get help with your plan, go to www.ready.gov.
CMS requires disaster planning for certain healthcare providers
Certain health care providers are required by CMS to have disaster preparedness plans in place as a Condition for Coverage or Participation. The four main elements of an Emergency Preparedness Program includes risk assessment and planning, policies and procedures, communication plan, and training and testing. Providers must be compliant by November 15, 2017. Compliance with the rule will be verified by the Joint Commission, an independent, not-for-profit organization which accredits and certifies healthcare organizations, or a similar organization.
For example, federal regulations require that Medicare- and Medicaid-certified nursing homes have written emergency plans and provide employees with emergency preparedness training. CMS published an emergency preparedness checklist that healthcare communities including nursing homes can use as a guidance to develop and update plans.
See below for CMS listed entities for disaster plan requirements*:
- §416.54, Condition for Coverage for Ambulatory Surgical Centers (ASCs)
- §418.113, Condition of Participation for Hospices
- §441.184, Requirement for Psychiatric Residential Treatment Facilities (PRTFs)
- §460.84, Requirement for Programs of All-Inclusive Care for the Elderly (PACE)
- §482.15, Condition of Participation for Hospitals
- §482.78, Requirement for Transplant Centers
- §483.73, Requirement for Long-Term Care (LTC) Facilities
- §483.475, Condition of Participation for Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)
- §484.22, Condition of Participation for Home Health Agencies (HHAs)
- §485.68, Condition of Participation for Comprehensive Outpatient Rehabilitation Facilities (CORFs)
- §485.625, Condition of Participation for Critical Access Hospitals (CAHs)
- §485.727, Conditions of Participation for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services
- §485.920, Condition of Participation for Community Mental Health Centers (CMHCs)
- §486.360, Condition of Participation for Organ Procurement Organizations (OPOs)
- §491.12, Conditions for Certification for Rural Health Clinics (RHCs) and Conditions for Coverage for Federally Qualified Health Centers (FQHCs)
- §494.62, Condition for Coverage for End-Stage Renal Disease (ESRD) Facilities
Additional resources
Medications & disaster preparedness
Patient populations that are dependent on medications to assist with managing chronic illnesses may have difficulties if provider locations are inaccessible or if medications are stored improperly.
Emergency preparedness regulation FAQs
Check out the below frequently asked questions from CMS to learn more about emergency preparedness regulations.
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*List not all-inclusive
Sources:
State Operations Manual, Appendix Z – Emergency Preparedness for All Provider and Certified Supplier Types and Interpretive Guidance, Center for Clinical Standards and Quality/Survey & Certification Group, June 2, 2017
SNIBBE, KURT, Hurricane Harvey is One of 74 Disasters Declared by FEMA in 2017, Orange County Register, August 29, 2017
Preparedness Checklist for Pediatrics Practices, American Academy of Pediatrics, 2013
Emergency Preparedness Checklist, Recommended Tool for Effective Health Care Facility Planning, Centers for Medicare & Medicaid Services, Rev. December 2013
CMS Emergency Preparedness Rule & Supply Chain Impact, HIDA Regulatory Insights, Vol. 4, 2017
www.Ready.gov
Unless otherwise noted, the recommendations in this document were obtained from the sources listed above. Be advised that information contained herein is intended to serve as a useful reference for informational purposes only and is not complete clinical information. This information is intended for use only by competent healthcare professionals exercising judgment in providing care. McKesson cannot be held responsible for the continued currency of or for any errors or omissions in the information.
