anha mid year-dis prep 14.pptanha.org/members/documents/anhamidyear-disprep14.pdf · state, and...

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Disaster/Emergency Planning:

“Does my plan look good…”

2014 ANHA Mid-Year Convention

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What is a Disaster/Emergency?

• Emergency is defined as a sudden, unexpected event requiring immediate action due to the potential threat to health and safety, the environment, or property.

• It is an extraordinary situation in which people are unable to meet their basic survival needs, or there are serious and immediate threats to human life and well being

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“Act of God” Disasters

• Natural disasters are a common occurrence throughout the United States.

• From 2000‐2010, the U.S. experienced 560 federally declared natural disasters; the majority due to severe storms

• Natural disasters include floods, hurricanes, tornadoes, earthquakes, volcanoes, wild‐land fires, thunderstorms and lightning strikes

• Most natural disaster events are predictable, allowing communities and individuals the opportunity to prepare prior to the event

“Act of Man” Disasters:

•Man‐made can include terrorist, bio‐threats, acts of war, and riots, explosions, train wrecks, chemical spills, and toxic waste spills, mining accidents, etc.

•Blackouts and Brownouts should also be considered

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Goals and Objectives of Training:

•Not focused on Fire related disasters

• Why Not?

• Current Activity With..…

• Regulatory Actions, Inspections, Approaches

•What are the Regulating Agencies

• Types of Disasters

• Act of God vs. Act of Man

• Isolated vs. Widespread

Emphasis Now???

•History:

•2005 Katrina…….1836 deaths

In August 2006, HHS/OIG issued the report entitled:

•NURSING HOME EMERGENCY PREPAREDNESS AND RESPONSE DURING RECENT HURRICANES

Since……•Other Events…..

• 2011 AL Tornadoes….348 deaths

• 2011 Joplin Tornadoes…..158 deaths

• 2012 Hurricane Sandy……72 deaths

Not including: Ike, Rita, Ivan, Irene

• 2014 Washington Mudslide…..36+ deaths

• 2013 Arizona Wildfire…..19 deaths

• 2012 Sandy Hook School…..28 deaths

• 2012 Aurora Colorado…….12 deaths

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2006 OIG Recommendations:

• “The Centers for Medicare & Medicaid Services (CMS) should consider strengthening Federal certification standards for nursing home emergency plans by including requirements for specific elements of emergency planning.”

• “CMS should encourage communication and collaboration between State and local emergency entities and nursing homes.”

Rules and Regulations?

•Who makes the “Rules” for Disasters????

• Varying Agencies and Authority

• Federal

•HHS/CMS, FEMA, OSHA, NIST, NIOSH, CDC

• State

•ADPH, EMA, Local Authorities

• Problems?

• Interpretation, Enforcement….Assistance!!

Healthcare RegulationsFederal Survey and Certification Guidelines

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CURRENT Rules and Regulations (Healthcare):

•Federal Guidelines:• Title 42: Public Health

• CFR Part: 488

• SURVEY, CERTIFICATION, AND ENFORCEMENT PROCEDURES

• F 517

•“Written bylaws address the operation of the facility”

Rules and Regulations (Healthcare):

• Standard Operations Manual

• F 517

•§483.75(m)(1) The facility must have detailed written plans and procedures to meet all potential emergencies and disasters, such as fire, severe weather, and missing residents.


• F518

• §483.75(m)(2) The facilities must train all employees in emergency procedures when they begin to work in the facility, periodically review the procedures with existing staff, and carry out unannounced staff drills using those procedures.

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• Interpretive Guidelines §483.75(m)

• The facility should tailor its disaster plan to its geographic location and the types of residents it serves.

• “Periodic review” is a judgment made by the facility based on its unique circumstances changes in physical plant or changes external to the facility can cause a review of the disaster review plan.

• The purpose of a “staff drill” is to test the efficiency, knowledge, and response of institutional personnel in the event of an emergency.

*Unannounced staff drills are directed at the responsiveness of staff, and care should be taken not to disturb or excite residents……..HOW?????

PROPOSED Rules and Regulations (Healthcare):

• CMS Stated (12/27/2013):

• Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers…………

• To participate in the Medicare and Medicaid programs, long‐term care (LTC) facilities must meet certain requirements located at part 483, Subpart B, Requirements for Long Term Care Facilities

• LTC facilities provide a substantial amount of care to Medicare and Medicaid beneficiaries…….As of March 1, 2013, there were 15,157 LTC facilities and these facilities provided care for about 1.7 million patients.

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PROPOSED Rules and Regulations (Healthcare):

• CMS proposed:

• The “current” language be incorporated into proposed §483.73(a)(1)

• These requirements would be incorporated into proposed § 483.73(d)(1)and (d)(2).

• Sections § 483.75(m)(1) and (2) would be removed

What Does This Mean for LTC????

• CMS states:

• “These requirements are not sufficient to ensure that facilities are prepared for more widespread disasters that may affect most or all of the other health care facilities in their area and that may tax the ability of local, state, and federal emergency management officials to provide assistance”

Specific Changes Identified:

• First Change…….

• “We believe the additional requirements in this proposed rule would ensure facilities would be prepared for the emergencies they may face now and in the future. Thus, our proposed emergency preparedness requirements for LTC facilities are identical to those we are proposing for hospitals at §482.15, with two exceptions. Specifically, at §483.73(a)(1), we propose that LTC facilities would establish emergency plans utilizing an “all‐hazards” approach, which in an emergency situation, would include a directive to account for missing residents”.

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•Second:• “Section § 483.73(c) requires these facilities to

develop an emergency preparedness communication plan, which includes, among other things, a means of providing information about the general condition and location of residents under the facility's care.”

• “We also believe that the residents and their families or representatives require more information about the facility's emergency plan……….


Continued:

• “Specifically, long term care facilities should be required to determine what information in their emergency plan is appropriate to share with its residents and their families or representatives and that the facility have a means by which that information is disseminated to those individuals”

Physical Plant Also Identified……

• Recommendations:

• “We are proposing at § 483.73(e)(1)(i) that LTC facilities must store emergency fuel and associated equipment and systems as required by the 2000 edition of the Life Safety Code (LSC) of the National Fire Protection Association (NFPA)”

• “We propose that LTC facilities test their emergency and stand‐by‐power systems for a minimum of 4 continuous hours every 12 months at 100 percent of the power load the LTC facility anticipates it will require during an emergency”

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Physical Plant Continued…..

• “We also believe that LTC facilities should consider their individual residents' power needs”

• For example, some residents could have motorized wheelchairs that they need for mobility or require a continuous positive airway pressure or CPAP machine due to sleep apnea

• “In § 483.73(a)(1) and (3), we propose that the LTC facility address, among other things, its resident population and continuity of operations in its emergency plan”

Summary of Major Provisions:

• Proposing emergency preparedness requirements that will be consistent and enforceable for all affected Medicare and Medicaid providers and suppliers

• Proposed rule addresses the three key essentials needed to ensure that health care is available during emergencies:

1. Safeguarding human resources

2. Ensuring business continuity

3. Protecting physical resources

CMS Quote……

“Current regulations for Medicare and Medicaid

providers and suppliers do not adequately address these key

elements”

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Program Elements/Expectations:

• CMS identified four core elements that are central to an effective and comprehensive framework of emergency preparedness requirements for the various Medicare and Medicaid participating providers and suppliers

Four Core Elements:

Number ONE:

• Risk assessment and planning

• Proposed rule would propose that prior to establishing an emergency plan, a risk assessment would be performed based on utilizing an “all‐hazards” approach

Four Core Elements:

Number TWO:

• Policies and procedures

• CMS is proposing that facilities be required to develop and implement policies and procedures based on the emergency plan and risk assessment

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Four Core Elements:

Number THREE

• Communication plan

• CMS proposed rule would require a facility to develop and maintain an emergency preparedness communication plan that complies with both federal and state law

Four Core Elements:Number FOUR:

• Training and testing

• CMS is proposing that a facility develop and maintain an emergency preparedness training and testing program. A well‐organized, effective training program must include providing initial training in emergency preparedness policies and procedures.

• Propose that the facility ensure that staff can demonstrate knowledge of emergency procedures and provide this training at least annually

• Would require that facilities conduct drills and exercises to test the emergency plan.

WHATCan You Do to Comply……Prepare????

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Tools for Compliance

• S & C‐14‐12‐ALL (February 28,2014)

• “Revised Emergency Preparedness Checklist” (Red)

• Highlights:

• Transportation Water Supply

• Missing Resident Procedures

• Resident Identification

• Housing or Shelter for Displaced Residents

• FEMA Guideline Compliance

• Collaboration with EMA, Local, and Other Healthcare

Tools for Compliance

•Nursing Home Incident Command System

• Developed in conjunction with ADPH, ANHA and University of South Alabama

• Disseminated and Trained in previous years

• “Templates” and Checklists

• DO NOT expect Fill‐in‐Blank

• Policies and Procedure Samples

• Shelter In Place

• Evacuation

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ADPH/U.S.A./ANHA Collaboration:

• David L. Wallace, Director of Preparedness Training/Center for Strategic Health Innovation at the University of South Alabama

• Emergency Management Programs Purpose/Goals/Objectives

• NIMS/ICS/NFR ‐ Federal and State guidelines for Emergency Preparedness Response Collaboration

• Components of an Emergency Management Plan

Tools for Compliance (Employees)

•OSHA Fact Sheet

“Planning and Responding to Workplace Emergencies”

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OTHER

Anticipated/Expected

Rules and Changes

Rules/Regulations (Life Safety Code)

• 2000 NFPA 101®‐Life Safety Code (CURRENT)

The Life Safety Code contains all the requirements for construction features of the building, means of egress, hazardous area, interior finishes, furniture and furnishings, and operational requirements for smoking, evacuation in case of emergencies and fire drills.

• Chapters 18/19, New and Existing Healthcare Occupancies

Rules/Regulations (Life Safety Code)

•2012 NFPA 101®‐Life Safety Code (Proposed)

• “Currently, CMS applies the standards set out in the 2000 edition of the LSC to facilities in order to ensure patients’ and caregivers’ health and safety. CMS is now proposing to adopt the 2012 editions of the LSC and the Health Care Facilities Code.”

• Includes 50+ Additional NFPA, ANSI, UL, ASTM Codes

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Rules/Regulations (Additional NFPA)

• NFPA Applicable Reference Standards

• 1999NFPA 99 (CURRENT), Standard for Health Care

Facilities This standard contains all the requirements for the installation, inspection, testing and maintenance of emergency power systems, the handling and storage of oxygen and emergency management plans.

•2012 NFPA 99 (PROPOSED)

• Chapter 11:

•Healthcare Emergency Preparedness

Rules/Regulations (Additional NFPA)

•NFPA Applicable Reference Standards:

•1999NFPA 110 (CURRENT) , Standard for

Emergency and Standby Power Systems This standard contains all the requirements for the installation, inspection, testing and maintenance of generators and emergency electrical systems up to and including the transfer switch.

•2010NFPA 110 (PROPOSED)

ADPH Rules (Licensure)

• 420‐5‐10‐.03 (Administrative Mgt.)

• (37) Disaster and emergency preparedness. The facility must have detailed written plans and procedures to meet all potential emergencies and disasters, such as fire, severe weather, and missing residents.

• (a) The facility must train all employees in emergency procedures when they begin to work in the facility;

• (b) Periodically review the procedures with existing staff;

• (c) And carry out unannounced staff drills using those procedures.

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ADPH Rules (State Specific)


• (38) The facility must have in effect a written transfer agreement with one or more hospitals approved for participation under the Medicare and Medicaid programs that reasonably assures that:

• (a) Residents will be transferred from the facility to the hospital, and ensured of timely admission to the hospital when transfer is medically appropriate, as determined by the attending physician; and


(38) Continued: (b) Medical and other information needed for care

and treatment of residents, and, when the transferring facility deems it appropriate, for determining whether such residents can be adequately cared for in a less expensive setting than either the facility or the hospital, will be exchanged between the institutions.



• (39) The facility is considered to have a transfer agreement in effect if the facility has attempted in good faith to enter into an agreement with a hospital sufficiently close to the facility to make transfer feasible.

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• 420‐5‐10‐.18 (Physical Plant)

• (4) General Requirements

(cc) Emergency Power

1. Nursing facilities and additions to nursing facilities constructed after October 20, 1967, shall have an emergency generator.

2. Nursing facilities and additions to nursing facilities constructed prior to October 20, 1967, may have an automatic battery‐powered system which will provide the emergency power required for at least 1½ hours. An emergency generator shall be provided if life support equipment systems are used.


•420‐5‐10‐.18 (Physical Plant)• (4) General Requirements

• (gg) When life support systems are used, emergency electrical service shall comply with NFPA 99 and shall be provided by an emergency electrical generator located on the premises.

“All Hazards” Defined?• “All‐hazards” does not literally mean being prepared for any and all hazards that might manifest themselves in a particular community, state, or nation. What it does mean is that there are things that commonly occur in many kinds of disasters, such as the need for emergency warning or mass evacuation, that can be addressed in a general plan and that that plan can provide the basis for responding to unexpected events”

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“All Hazards” .….

• Emergency plans never, or virtually never, cover everything that might be required in a disaster.

• For example…. requirements for evacuation for flood may differ significantly from those required for evacuation during a hazardous materials spill

• Plans need to be adaptable to circumstances and emergency managers and other officials, whether they be elected public officials or corporate officers, also

need to be adaptable, innovative, and, when necessary, improvisational

“All Hazards” .….

•Theory is that “all‐hazards” plans can provide a basic framework for responding to a wide variety disasters, but planners typically address the kinds of disasters that might be expected to occur in their business model or location

What Works......What Doesn’t???

Business Continuity Plan (BCP or COOP)

• Core Decision Components:

• Shelter‐in‐Place vs. Evacuation?

• Widespread vs. Isolated Event?

• Resources Available vs. Accessible?

• Short Term vs. Long Term Event

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What Works......What Doesn’t???

Known Failures and/or Opportunities for Improvement

1. Timely decisions by Key Personnel

2. Local Authority Dependency3. External Communication Capabilities

4. Transportation (Employee and Evacuation)

5. Surge Resources for all Exposures 6. CASH!!!!!!

Summary:• Evaluate Current Policies/Procedures

• Out with Old…In with New or Revised

• Don’t look for a “Cookie Cutter”

• Should Emergency decisions really be “fill‐in‐blank” programs?

• Develop an Emergency TEAM (in‐house and out)

• Program FAILS without a team

• KNOWYour Community Resources!!!!!!!!!!!

• Public and Private

•Q/A

Michael Arther, NHA

MCA Consulting, LLC

PO Box 5145

Glencoe, AL 35905

256‐390‐0554

[email protected]

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