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:
- Risk Assessment and Planning – Agencies need to perform a risk assessment that uses an “all-hazards” approach prior to establishing an emergency plan. The “all-hazards” risk assessment will be used to identify the essential components to be integrated into the facility emergency plan. This approach focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters. The assessment must be specific to the location of the organization and considers the particular types of hazards most likely to occur in the agency’s areas, including:
- care-related emergencies
- equipment and power failures
- interruptions in communications, including cyber attacks
- loss of a portion or all of a facility
- interruptions in the normal supply of essentials, such as water and food
- Policies and Procedures – Agencies need to develop and implement policies and procedures that support the successful execution of the emergency plan and risks identified during the risk assessment process.
- Communication Plan – The emergency preparedness communication plan developed and maintained must comply with both federal and state law. Patient care must be well coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management agencies and systems to protect patient health and safety in the event of a disaster.
- Training and Resting – A well-organized, effective training program must include initial training for new and existing staff in emergency preparedness policies and procedures as well as annual refresher training. The organization must offer annual emergency preparedness training so that staff can demonstrate knowledge of emergency procedures. The organization must also conduct drills and exercises to test the emergency plan to identify gaps and areas for improvement.
2019 Changes Made to Emergency Preparedness Requirements
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.
About Manchester Specialty
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.