By Ryan Kelly –
With the recent hurricane hitting the East coast of Texas and another heading straight for Florida this weekend, it is a sober reminder of why we need some measure of emergency preparedness guidelines and procedures.
The MRHA recently sent tools and resource for members to access and a summary of the guidelines that will be enforced for RHCs and FQHCs beginning November 15, 2017.
The following represents these new guidelines. Resources available to you to help meet these needs is located below. Remember that regardless of guidelines or requirements, it’s always a good idea to know how your facility can / should be part of a holistic plan of disaster management and recovery in your community!
Emergency Plan §491.12 (a)
The first step to creating an emergency preparedness plan is to create what CMS calls an “all hazards approach” to emergency preparedness. An “all-hazards approach” to emergency planning focuses on the preparedness of providers for a full range of emergencies. This could mean preparing for natural disasters or considering risks around the area of a RHCs. CMS leaves it up to RHCs to develop their own process for creating a risk assessment. However, CMS does expect that the participation of all staff including an administrator, physician, a nurse practitioner or physician assistance and a registered nurse to be involved in assessing the risk of the RHC.
The plan must include strategies for addressing emergency events identified by the risk assessments and identify what services the RHC would be able to provide during an emergency.
Finally, the emergency plan should include a process for cooperation with local, state and federal emergency preparedness officials in a case of an emergency. The regulations specify that the RHC should document attempts to contact such officials for certification purposes.
It is important to note, that unlike hospitals CMS did not require RHCs to have a system to track the location of staff and patients in the facility’s care during and after emergency (although the regulations do seem to contradict themselves a bit in §491.12(c)(4). Furthermore, RHCs do not have to provide for basic subsistence needs for staff and patients.
Policies and Procedures §491.12 (b)
After an RHC creates an emergency plan, RHCs must then develop policies and procedures to address possible emergencies. RHCs must plan for safe evacuation from the RHC which includes the appropriate placement of exit signs and responsibilities of staff members.
There must be a way to shelter in place for people who remain in the facility. RHCs must also preserve their medical documentation. Finally RHCs must have a plan to use volunteers and other emergency personnel during an emergency.
Communication Plan §491.12 (c)
RHCs must develop and maintain an emergency preparedness communication plan. The plan should comply with federal and state laws and must be updated at least annually. The communication plan must include all relevant contact information and alternative means of communicating with staff and local emergency agencies.
The RHC must also have a way to provide information about the condition and location of the patients in the clinic at the time of the emergency. Finally, an RHC must have a way to indicate their needs and ability to provide assistance to the emergency authority.
Training and Testing §491.12 (d)
RHCs must develop and maintain a training and testing program based on the risk assessment, emergency plan and communication plan. This training program must include a documented initial training with all new and existing staff which is performed annually.
Furthermore, RHCs must test their emergency plan at least annually. CMS will consider a plan properly tested if the RHC performs and analyzes either two full scale community based exercises or one full scale community based exercise and a tabletop exercise.
Integrated healthcare systems §491.12 (e)
It is important to note that under this regulation there is an option to develop an emergency preparedness plan as an entire health system or independently as an RHC. If an RHC is part of a healthcare system it may elect to participate in the healthcare system’s coordinated emergency preparedness program instead of creating their own.
Resources Available to You
The Mississippi Rural Health Association has been working with clinics to help them meet these new demands.
We encourage you to contact your respective emergency management contact in the Mississippi State Department of Health. These contacts may be found on the Association resource page by clicking here. This map will show each individual contact per public health area, and these contacts may assist you in navigating many of the direct contacts needed for policy implementation.
Second, the Association has negotiated a service with Two Rivers Emergency Management. They are a professional consulting firm that can assist you in developing and sustaining and emergency preparedness plan. The following is the direct contact information for Two Rivers:
Mr. Michael Morlan, CEO
The Association hosted a webinar recently on the topic of emergency preparedness. Presented by the afore mentioned Michael Morlan, this webinar covers the basic requirements of the new plan and a basic understanding of how to meet those demands. Click here to register for this on-demand webinar, free for Association members.