keith fehr, ms, chfm mihs director of emergency management azcher-central chair · ·...
TRANSCRIPT
Keith Fehr, MS, CHFMMIHS Director of Emergency Management
AzCHER-Central Chair
Describe the foundational information used by CMS when developing the Proposed Rule Changes
Review CMS Proposed Rule Changes for Emergency Management, specific to Community Health Centers
Summarize the expected implementation of the Proposed Rule Changes
§ 491.6(c) Standard: Emergency Procedures
Training staff in handling emergencies
Coordinate plan with local and State authorities
Conduct drill annually with written evaluation
Reporting Info:◦ Has your organization conducted a thorough
Hazards Vulnerability Assessment: Date Completed?
◦ Does your organization have an approved EPM plan – Date approved by Board?
◦ Report the CURRENT STATUS and describe any CHANGES related to the development and implementation of an emergency preparedness and management plan, including participation in drills or exercises and participation or attempts to participate with State and local emergency planners.
CMS reviewed guidance from FDA, CDC, HRSA, ASPR, TJC, AOA, NFPA and state-level requirements.*
Findings were that current requirements do not address the need for:*◦ Communication to coordinate with community
◦ Contingency planning
◦ Personnel training
* https://federalregister.gov/a/2013-30724
Emergency Management Program◦ All-Hazards
◦ Mitigation, Preparedness, Response, and Recovery
◦ Compliant with federal and state requirements
◦ Stipulates NFPA 1600 as industry standard for EMP
Hazard Vulnerability Assessment (HVA)◦ All-Hazards
◦ Essential functions, community risks, facility risks, contingencies
At-risk population planning
Available services during a disaster
Succession Planning in the EOP
Cooperation, collaboration, and communication with local, tribal, regional, state, and/or federal partners.
Policies and procedures to support the program (annual review/revision)◦ Emergency Preparedness Policies
◦ Communication Plan
◦ Means of providing assistance
◦ Evacuation & Shelter in Place
◦ Medical documentation/records
Exercises◦ 1 Operational-based annually
Preferred with community
◦ 1 Table-Top annually
Staff training◦ Roles and responsibilities
◦ Incident Command Training is implied
“Integrate” with the community response
Formal implementation date pending from CMS.
Cost analysis from CMS (Burden on Facility)*◦ RHC HVA = 10 hours ($712 per facility)
◦ RHC Plan = 14 hours ($949 per facility)
◦ RHC P&P = 12 hours ($968 per facility)
◦ RHC Comm = 10 hours ($734 per facility)
◦ RHC Training Program = 10 hours ($526 per facility)
◦ RHC Exercise Prep and Follow-up = 5 hours ($276 per facility)
◦ Subtotal = $4,165 per facility
* https://federalregister.gov/a/2013-30724
Cost analysis from CMS (Burden on Facility)*◦ FQHC HVA = 5 hours ($356 per facility)◦ FQHC Plan = 8 hours ($530 per facility)◦ FQHC P&P = 8 hours ($608 per facility)◦ FQHC Comm = 5 hours ($367 per facility)◦ FQHC Training Program = 10 hours ($526 per
facility)◦ FQHC Exercise Prep and Follow-up = 5 hours ($276
per facility)◦ Subtotal = $2,663 per facility
* https://federalregister.gov/a/2013-30724
Identify current applicable licensing requirements for OTCs, specific to emergency management
Summarize NFPA 99 (2012 ed.) and NFPA 1600 (2010 ed.) applicable standards for emergency management
Discuss potential gaps in planning that may exist due to the changes in NFPA editions
Requirements*◦ Documented Disaster Plan with these elements:
Procedures for protecting the health and safety of those on the premises
Assigned personnel responsibilities
Evacuation, transport, or transfer instructions
Arrangements to provide other services to meet the patients’ needs
◦ Documented annual review◦ Annual evacuation drills per shift◦ Meet applicable Fire Codes
* Adapted from Title 9. Health Services: Chapter 10. Health Care Institutions: Licensing: Article 10. Outpatient Treatment Centers: R9-10-1029
Fire Code requirements◦ NFPA 99 Healthcare Facilities 2012 edition
◦ 3.3.71 Health Care Facilities: Buildings, portions of buildings, or mobile enclosures in which medical, dental, psychiatric, nursing, obstetrical, or surgical care is provided.
◦ Chapter 12 Emergency Management
AHJ Requirements
Senior Management Requirements
Emergency Management Committee
Category 1 vs. Category 2
Emergency Management Program
Hazard Vulnerability Analysis◦ Identify and Prioritize Hazards/Threats
Natural Hazards
Human-Caused
Technological
◦ Analyze the potential impact: Continuity of Operations
Care for new and existing patients
Health, safety, and security
Support of Staff
Property, environment, economic, regulatory/contractual, reputation
Involve Community
Mitigation Plan◦ Strategies to minimize impact
Preparedness◦ Documented inventory of resources and management
system◦ 96 Hours of sustainability◦ EOP with command structure and critical functions
support identified: Communications Resources and assets Safety and security Clinical support activities Essential utilities Staff Roles
Response and Recovery◦ Command Structure consistent with community◦ Activation and deactivation criteria, including authority and
process Internal declaration process
◦ Plan to respond for extended periods without support from outside Resource conservation Service curtailment Partial or total evacuation
Staff Education◦ Time of hire general overview◦ Incident Command Systems◦ Position-specific◦ Annual refresher
Community Health Center IMT
Source: Community Health Care Association of New York State (2007). Community Health Center Emergency Management Plan.
Testing Emergency Plans and Operations◦ 2 Operations-based exercises per year
◦ Based upon HVA priorities
◦ Community Integration and Stand-alone capability can be Table-top exercise(s)
◦ Designated evaluator
◦ Debrief, After Action Report, and Improvement Plan
Annual review/revision of HVA and EOP
Standard on Disaster/Emergency Management and Business Continuity Programs
Additional activities that the AHJ can evaluate on top of NFPA 99 Chapter 12.
Program Administration◦ Program budget and schedule, including milestones
◦ Compliance with applicable legislation, regulations, etc.
◦ Performance Objectives
Based upon HVA and Business Impact Analysis (BIA)
Short-term and Long-term objectives
◦ Financial Management
Mitigation, Preparedness, Response, and Recovery
Crisis Management procedures
Documentation tools to capture financial impacts
Crisis Management Planning◦ Addresses threats to strategic, reputational, and
intangible elements of the entity.
Business Impact Analysis (BIA)◦ Interruptions/disruptions of functions, processes,
and applications.
◦ Identify critical functions and the point where interruption impact is unacceptable to the entity.
Prevention◦ Cost Benefit Analysis and driven by level of risk
Volunteer and Donation Management
Mutual Aid/Assistance Agreements
Communication and Warning Systems
Employee Assistance and Support
Business Continuity & Recovery Plans
Crisis Communications/Public Info Plan
Program reviewed annually and/or when the following occur:◦ Regulatory changes
◦ Changes in hazards/potential impacts
◦ Resource availability/capability changes
◦ Organizational changes
◦ Funding changes
◦ Changes in products, services, or operations
Importance of Participation
Describe the role of Healthcare Coalitions within the community
Discuss Return on Investment opportunities based upon Coalition participation
Identify tools and resources available to Coalition members
4 Regional Healthcare Coalitions◦ AzCHER-Central
Gila, Maricopa, and Pinal Counties
Contact: Keith Fehr, [email protected]
◦ Northern Healthcare Coalition Apache, Coconino, Navajo, and Yavapai Counties
Contact: Jeff Lee, [email protected]
◦ Southern Healthcare Coalition Cochise, Graham, Greenlee, Pima, and Santa Cruz Counties
Contact: Judy Lynn, [email protected]
◦ Western Healthcare Coalition La Paz, Mohave, and Yuma Counties
Contact: Greg Bachmann, [email protected]
AZ Burn Disaster Telemedicine Network
AZ Local Public Health Emergency Response Association (ALPHERA)
AZ Pediatric Disaster Coalition
AZ Tribal Executive Committee (AzTEC)
Coyote Crisis Collaborative
Include, but are not limited to:
• Acute Hospitals• Specialty Hospitals• Critical Access Hospitals• Ambulatory Surgical Centers• Community Health Centers• Long Term Care• Skilled Nursing Facilities• Assisted Living Facilities• Dialysis Centers• Hospice• Home Health • Behavioral Health• Tribal Health Facilities• Indian Health Services• Veteran’s Administration• Blood Systems, Inc.• Veterinarians
• Local Public Health• Local Emergency Mgt• State Public Health• State Emergency Mgt• Tribal Public Health• Tribal Emergency Mgt• Fire Departments• Police Departments• Sheriff Departments• EMS/Ambulance Companies• National Guard• Department of Defense• Medical Examiners• At-Risk Population Reps• Healthcare Associations• Schools
Coalitions help you meet requirements:
◦ Sharing HVA with community
◦ Sharing plans with community
◦ Participation in Memorandums of Understanding (MOUs)
◦ Access to communication processes and systems
Plan writing, review, and revisions
Incident Command and Emergency Management Training
Exercise development and facilitation
Special Interest Projects:◦ Decontamination◦ Medical Reserve Corps◦ Amateur Radio use
Meet you neighbor that may have resources you need during a disaster.
Build a working relationship before the incident occurs.
Find out about the ever evolving world of Emergency Management.
Find out about conferences, workshops, seminars
Emergency Support Function (ESF) #8 – Public Health and Medical Response
◦ Specific way to request assistance from Coalition partners to Federal Assistance.
◦ Reimbursement process.
◦ Declared Disaster…what is that?
Emergency Management 101◦ Local, basic intro to role
Incident Command System Training◦ FEMA ICS and “ICS-Light” Classes
◦ HICS, NHICS, CHCICS, PHICS
Standardized HVA and Community HVA tools
Standardized Plan Templates & Annex Templates
Assistance documents◦ Memorandum of Understanding (MOU)◦ Memorandum of Agreement (MOA)◦ Mutual Aid Compact (MAC)
Annual Exercises◦ Exercise Plans, Scenarios, Master Scenario Events Lists
(MSEL), Exercise Evaluation Guides, After Action Reports, and Lessons Learned
◦ Moulage and Mock Patient Support◦ Controller, Evaluator, Observer Support
Access to Training and Exercise Calendars◦ Training at FEMA Facilities (Healthcare Leadership
and Enhanced Unified Command)
◦ State-wide, regional, and local training and exercises
◦ National, regional, and local conferences
4 Regional Healthcare Coalitions◦ AzCHER-Central
Gila, Maricopa, and Pinal Counties
Contact: Keith Fehr, [email protected]
◦ Northern Healthcare Coalition Apache, Coconino, Navajo, and Yavapai Counties
Contact: Jeff Lee, [email protected]
◦ Southern Healthcare Coalition Cochise, Graham, Greenlee, Pima, and Santa Cruz Counties
Contact: Judy Lynn, [email protected]
◦ Western Healthcare Coalition La Paz, Mohave, and Yuma Counties
Contact: Greg Bachmann, [email protected]
