With hurricane season around the corner, we thought it would be a good idea to address the need for hospice providers to ensure that their emergency preparedness plans are in compliance and ready to respond in the event of both natural and man-made disasters. This is particularly relevant for Medicare- and Medicaid-participating hospice organizations providing in-patient facilities. A new ruling issued by the Centers for Medicare & Medicaid Services (CMS) that went into effect November 15, 2017 is aimed at insuring emergency management is integrated into a hospice’s daily operation and culture.
According to the CMS, comprehensive emergency management for hospice providers must include the following:
- Hazard Identification: Hospice providers should assess hazards that could potentially affect a facility directly and indirectly based on the particular area where it is located. Indirect hazards could affect the community, but not the provider, and as a result interrupt necessary utilities, supplies or staffing.
- Hazard Mitigation: This includes the actions taken to eliminate or reduce the probability of the event, or reduce its severity or consequences, either prior to or following a disaster or emergency. The emergency plan should include mitigation processes for both residents and staff.
- Preparedness: The plan must address how a hospice provider will meet the needs of patients and residents if essential services break down because of a disaster. The plan will be based on a thorough review of the basic facility information, hazard analysis and an examination of the provider’s ability to continue providing care and services during an emergency.
- Response: Activities immediately before (for an impending threat), during and after a hazard impact must address the immediate and short -term effects of the emergency.
- Recovery: Activities and programs implemented during and after response are designed to return the hospice facility to its usual state or a “new normal.”
Policies/Procedures, Communication, Training & Testing
The emergency preparedness plan, according to the CMS new ruling, must include policies and procedures for the hospice facility to follow, a communication plan, staff training and a testing program that is evaluated and rehearsed annually. Policies and procedures, for example, must address staffing, provision of patient services, evacuation, sheltering in place, safeguard of supplies, maintenance of clinical records, and collaboration with other community providers. The plan must also include a plan for managing the consequences resulting from power failures, natural disasters, and other emergencies that would affect the hospice’s ability to provide care; the types of services the hospice has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
The communication plan as outlined by the CMS should include contact information (primary and alternate) for hospice staff, contractors, and federal, state, tribal, regional, and local emergency preparedness staff. The process by which hospice patient information and clinical documentation will be shared with other health care providers to maintain continuity of care must also be included in an emergency plan. In addition, CMS requirements mandate that the hospice provider disclose the process under which patient information and information about the general condition and location of patients under its care will be shared as permitted under the Health Insurance Portability and Accountability Act (HIPAA), in the event of an evacuation; and the process to provide information about a hospice’s inpatient unit occupancy, needs, and its ability to provide assistance to emergency preparedness officials.
The training portion of an emergency plan should at minimum address:
- Staff knowledge of emergency procedures;
- Documentation of all emergency preparedness training;
- Exercises to test the emergency plan that include participation in a full-scale exercise that is community- or facility-based, as well as facilitation of an additional activity that may include a second full-scale exercise or a tabletop exercise; and
- Documentation of testing and lessons learned.
Testing the policies and procedures in place is also critical to the success of an emergency plan. For example, an inpatient facility might test their policies and procedures for a flood that may require the evacuation of patients to an external site or to an internal safe “shelter-in-place” location (e.g. foyer, cafeteria, etc.), and include requirements for patients with access and functional needs and potential dependencies on life-saving electricity-dependent medical equipment.
There is a great deal more involved in ensuring that an emergency plan is in CMS-compliance and truly responsive and effective, including making sure that providers develop a relationship with local emergency response coordinators so that their patients are recognized and included in a community’s emergency response plan. Providers should also educate and provide written information to patients and families about their emergency policy preparedness policies and what to expect from the hospice during an emergency or disaster, what to do in the event of an emergency or disaster, and how to be prepared for an emergency or disaster.
In addition to having an updated emergency plan in place, having the right coverages as part of a comprehensive insurance program is essential. This includes Property insurance with Equipment Breakdown and Business Interruption coverages. Manchester Specialty Programs provides hospice providers with a complete range of insurance solutions. For more information about our business and insurance lines, you or your local agent/broker may contact us at 855.972.9399.
Sources: CMS, NHPCO