DHHS Announces Final Rule Impacting All CMS Providers | National Emergency Preparedness

The Department of Health and Human Services (DHHS) has just announced new requirements for national emergency preparedness, effective November 15th, 2016. After review, the DHHS determined that most healthcare facilities are not adequately prepared for the complexities that emerge with real life emergencies. This final rule will require all Centers for Medicare & Medicaid Services (CMS) providers to plan for a variety of disasters and modify their current emergency preparedness plans to comply with an updated list of requirements. The details of these new requirements establish standards for emergency preparedness based on proven best practices and documented results from real life emergencies such as 9/11, Hurricane Katrina, and the 2009 influenza epidemic. These requirements are designed to establish a comprehensive, consistent, flexible, and dynamic approach to standardizing emergency preparedness.

The Department of Health and Human Services (DHHS) has identified four main elements essential to a comprehensive emergency preparedness framework. These include: Risk Assessment and Emergency Planning, Policies and Procedures, Communication Plan, and Staff Training and Testing. The following is a breakdown of the different components; understanding how these four areas impact emergency preparedness is imperative to developing a DHHS approved plan.

Risk Assessment and Emergency Planning

The final rule requires all assessments and emergency planning to take an “All-Hazards” approach to developing an emergency plan. This approach is specific to the unique situation, location, and vulnerabilities of different facilities, taking into account their location and the particular threats in the local area. The focus of this approach is capacities and capabilities to accommodate a wide range of different emergencies and disasters that threaten the individual facilities.

Types of emergencies to consider include:

• Equipment failure
• Power Failure
• Communication Disruption
• Cyber-attacks
• Destruction of part, or all, of the facility
• Disruption in supply of essentials

Policies and Procedures

Policies and procedures must be updated, and maintained, to support the emergency plan developed from the “All-Hazards” risk assessment. This means that in addition to completing a risk assessment and developing an emergency plan with consideration for the “All-Hazards” approach, the healthcare facilities policies and procedures must be designed to facilitate successful execution of the plan in the event of an emergency. This means that a comprehensive overhaul of current policies and procedures must be completed before the deadline of November 15th, 2016.

Communication Plan

The purpose of an emergency preparedness communication plan is to establish a system of communication between staff, physicians, and other necessary personnel in a timely manner. A successful communication plan ensures continuation of patient care and facility functioning while maintaining safety and efficiency. Identifying key personnel and developing a chain of communication ensures that in the event of an emergency, the healthcare facility continues to function as a whole and without disrupting patient care.

Staff Training and Testing

Appropriate training and testing is a necessity in emergency preparedness. As part of any emergency plan, all staff should be informed and prepared through adequate training. This can be confirmed through regular testing of staff, facilities, and equipment to identify any areas that need improving.

An effective training program must include initial training program of the newly developed emergency plan according to the “All-Hazards” risk assessment and must include all staff, new and old. To support this, annual trainings must be completed to complement the initial training and ensures maintaining staff knowledge of emergency planning, policies, and procedures. Additionally, facilities must also conduct regular drills and exercises to help identify gaps and areas for improvement.

In Conclusion

Ultimately, the final rule is designed to ensure that all CMS participating healthcare facilities, including hospitals, providers, and suppliers are adequately prepared for the unexpected. Drawing on historical evidence, and research that indicates many facilities are underprepared, the Department of Health and Human Services has outlined a new standard for emergency preparedness which takes effect on November 15th, 2016.

Make sure you are prepared, and learn how EoScene can help you maintain an effective emergency plan and facility management by calling 206-552-3449. We would be happy to review any of the key components of this final rule to make sure everyone is up to speed and prepared.

Link to CMS Final Rule: http://www.ashe.org/resources/pdfs/cms_rule_160908.pdf