Posted on: June 14, 2019 by Manchester Specialty
Home health care and hospice agencies continue to struggle with the development of disaster preparedness plans that will not only be in compliance, but also effective and realistic during an event, according to the National Association for Home Care & Hospice (NAHC). In fact, NAHC cites that one of the top five deficiencies for home health care and hospice is ‘maintaining and updating their agency disaster plan.’ In addition, the Centers for Medicare and Medicaid Services (CMS) earlier this year issued new interpretive guidelines for its emergency preparedness requirements, which were initially released in late 2016 with compliance and implementation required by November 2017.
Let’s first review what is required of home health care and hospice providers with regard to their emergency plans, as set forth by the CMS:
One of the changes CMS made to its 2017 emergency preparedness plan requirements for home health care and hospice agencies includes the addition of “emerging infectious diseases” to the current definition of all-hazards approach. In light of events such as the Ebola Virus and Zika, the CMS believes that facilities should consider preparedness and infection prevention within their all-hazards approach, which covers both natural and man-made disasters.
In addition, stakeholders and providers asked for additional clarifications related to portable/mobile generators. The CMS has added guidance on this matter, stating that “facilities should use the most appropriate energy source or electrical system based on their review of their individual facility’s all-hazards risks assessment and as required by existing regulations or state requirements. Regardless of the alternate sources of energy a facility chooses to utilize, it must be in accordance with local and state laws and manufacturer requirements, as well as applicable Life Safety Code (LSC) requirements.”
Home health agencies must also include policies and procedures in their emergency plans to ensure 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 tornados; 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 in order 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. Home health agency 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.
It’s important that home health agencies and hospice providers comply with the CMS emergency preparedness requirements and ensure that their plans are updated and maintained. Disaster planning supported by a strong insurance program is fundamental to patient and employee safety, asset protection, and an organization’s success.
Manchester Specialty provides a total business insurance solution for home health care providers. We can help you provide the following insurance lines to your clients: General Liability, Professional Liability, Workers’ Compensation, Management Liability, Cyber Liability and Non-Owned & Hired Auto insurance, among other key coverages. For more information about how we can help you protect your insureds, please contact us at 855.972.9399.
Posted in: Home Healthcare Providers