by Misty Kevech, HHQI RN Project Coordinator
Weather extremes keep hitting the U.S. throughout the year. In your area of the country you might be experiencing violent storms, tornadoes, or hurricanes. Others may be dealing with excessive heat, black outs, or forest fires. Flooding and landslides are also occurring in many parts of the country. In fact, California recently experienced the most intense earthquakes in 20 years. Natural disasters are happening constantly across the country, including locations that are not usually affected. Beyond the weather related disasters, other emergencies we could encounter include terrorism, shootings, or cyber and other security threats.
So how do we prepare for our patients for emergencies and disasters?
The Centers for Medicare & Medicaid Services (CMS) released the Emergency Preparedness regulation in fall of 2016 and healthcare providers were to be compliant by November 15, 2017. The Interpretive Guidance was published by CMS in June 2017. CMS released an Emergency Preparedness rule update this past February that includes added “emerging infectious diseases” to the definition of all-hazards approach for both natural and man-made disasters. Examples provided were influenza, Ebola, and Zika virus, but could be any new or trending infection threats.
All providers, including home health and hospices, are required to include the Four Core Elements of Emergency Preparedness:
- Risk Assessment and Emergency Planning
- Communication Plan
- Policies and Procedures
- Training and Testing
This site also includes general resources for Emergency Preparedness and OCR Emergency Preparedness HIPPA Disclosure documents.
Individual Patient Emergency Plans and Evacuation
Let’s take a look at a few regulations related to creating patient emergency plans and considerations for evacuation. Each patient must have an individual plan for disasters as part of the patient’s assessment. The plan needs to be in writing and discussed with patients, their representatives, and their caregivers. The following information is from several CMS Emergency Preparedness (EP) documents.
In the 2016 EP rule, HHAs are required to minimally have policies and procedures for five different areas. The following are three of the five topics that related directly to addressing evacuation for patients:
- The plans for the HHA’s patients during a natural or man-made disaster. Individual plans for each patient must be included as part of the comprehensive patient assessment, which must be conducted according to the provisions at § 484.55.
- The procedures to inform State and local emergency preparedness officials about HHA patients in need of evacuation from their residences at any time due to an emergency situation based on the patient’s medical and psychiatric condition and home environment.
- The procedures to follow up with on-duty staff and patients to determine services that are needed, in the event that there is an interruption in services during or due to an emergency. The HHA must inform State and local officials of any on-duty staff or patients that they are unable to contact.
[Emergency Preparedness regulation (2016) p. 176]
HHAs must include policies and procedures in its emergency plan for ensuring all patients have an individualized plan in the event of an emergency. That plan must be included as part of the patient’s comprehensive assessment.
For example, discussions to develop individualized emergency preparedness plans could include potential disasters that the patient may face within the home such as fire hazards, flooding, and tornadoes; and how and when a patient is to contact local emergency officials. Discussions may also include patient, care providers, patient representative, or any person involved in the clinical care aspects to educate them on steps that can be taken to improve the patient’s safety. The individualized emergency plan should be in writing and could be as simple as a detailed emergency card to be kept with the patient. HHA personnel should document that these discussions occurred and also keep a copy of the individualized emergency plan in the patient’s file as well as provide a copy to the patient and/or their caregiver.
- Through record review, verify that each patient has an individualized emergency plan documented as part of the patient’s comprehensive assessment.
[Emergency Preparedness Interpretive Guidance (2017) pp. 24-25]
Mobility is an important part in effective and timely evacuations, and therefore facilities are expected to properly plan to identify patients who would require additional assistance, ensure that means for transport are accessible and available and that those involved in transport, as well as the patients and residents are made aware of the procedures to evacuate. For outpatient facilities, such as Home Health Agencies (HHAs), the emergency plan is required to ensure that patients with limited mobility are addressed within the plan.
[Emergency Preparedness rule update (2019) p. 14]
Are Your Patients Prepared?
Here are a few questions to consider related to EP individual plans:
If you are a HHA leader:
- Does your staff know and understand the regulations related to individual plans?
- Is EP and individual care plans part of your orientation process?
- Do you have a method to track transportation needs/limitations including mobility?
- Have your audited charts for realistic plans and confirmed the patient/caregivers are aware?
- Has your testing including practice with staff on patient evacuations?
- Have you began addressing “emerging infectious diseases” with your EP plans related to patients?
If you are a HHA clinician:
- Are you aware of the EP regulations?
- Do you know the agency’s EP policies and procedures are located? Have you read them?
- Are you creating individual EP care plan for each patient taking in consideration of any mobility issues?
- Do you notify your patient needs/limitations for evacuation to the appropriate person within your agency?
- Do you know where to access patient materials to provide additional information for patients/caregivers to discuss and plan?
- CMS Emergency Preparedness Rule web page provides up-to-date information and documents for providers that include home health and hospice. There are also links to valuable resources for various threats as well as templates and checklists.
- The Ready.gov (FEMA) website provides resources on specific types of disasters including information sheets, preparation and survival documents, videos, additional links, and much more.
- MyHHQI Blog, 09/13/18, September is National Disaster Preparedness Month: Social Determinants, Health Care Coalitions and Disaster Preparedness. Guest blogger: Barbara B. Citarella, RN, MS, CHCE, NHCP-BC, President & CEO, RBC Limited Healthcare & Management Consultants
- MyHHQI Blog, 07/31/18, Summer Heat and the Risks for Seniors
- MyHHQI Blog, 01/19/18. Preparing for Winger Weather: What to Have in Case of Emergency Guest Blogger: Patricia Sarmiento, writer for Public Health Corps
- Also go to HHQI’s Resource Library and use the Topic Filter for “Emergency Preparedness” to see additional resources