With hurricanes Helene and Milton wreaking havoc on the Southeast recently, we are reminded of the importance of disaster preparedness and ensuring the safety of our most vulnerable populations served by the long-term care sector.

In advance of Milton, Florida officials said hundreds of healthcare facilities had reported evacuations. They added that with more than 600 nursing homes in Florida, hurricane emergency evacuation drills “have become standard practice.” 

“This is not a quick process,” reminded Florida Health Care Association Strategy and Communications Senior Director Kristen Knapp in a Washington Post article on Oct. 9. “You’re evacuating a large number of people, their equipment, while also making sure they have enough supplies.” 

The hurricanes provide a stark reminder to the long-term care industry of the importance of disaster preparedness and disaster preparedness plans in the facility. 

Now that our heroes in Florida made it through these storms, now is a good time to take a closer look at your own facility disaster plans, including policies and procedures. Are your staff properly trained in disaster preparedness?  Have you provided drills or in-services about what to do in the event of evacuations or relocations of residents?

Being prepared

The Centers for Medicare & Medicaid Services has posted healthcare provider guidance regarding emergency preparedness for every emergency, not just hurricanes. Facilities can use this guidance to develop (and now update) effective policies in their facilities:

Hazard identification: Providers should make every effort to include any potential hazards that could affect the facility directly and indirectly for the particular area 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: Hazard mitigation is activities 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.  Mitigation details should address care for the facility residents, and how the facility will educate staff in protecting themselves in the likelihood of an emergency. Comprehensive hazard mitigation efforts, including staff education, will aid in reducing staff’s vulnerability to potential hazards. These activities precede any imminent or post-impact timeframe and are considered part of the response.

Preparedness: Preparedness includes developing a plan to address how the provider will meet the needs of patients and residents if essential services break down as a result of a disaster. It will be the product of a review of the basic facility information, the hazard analysis, and an analysis of the provider’s ability to continue providing care and services during an emergency. It also includes training staff on their role in the emergency plan, testing the plan, and revising the plan as needed.

Response: Activities immediately before (for an impending threat), during and after a hazard impact to address the immediate and short-term effects of the emergency.

Recovery: Activities and programs implemented during and after response that are designed to return the facility to its usual state or a “new normal.”

Developing a disaster and emergency preparedness plan

Indeed, for long-term care facilities, CMS requires a specific emergency preparedness plan which must be reviewed and updated annually:

The plan must do the following: 

(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing residents. 

(2) Include strategies for addressing emergency events identified by the risk assessment. 

The CMS regulations require, and it makes sense, that each resident’s condition be taken into consideration and that facilities utilize cooperation with local emergency preparedness officials, which would include police and fire departments when implementing their emergency plans.

Risk assessment needed

Also, according to Appendix Z, Emergency Preparedness, of the State Operations Manual, facilities need to develop a risk assessment based on their Emergency Preparedness Plan for long-term care facilities.

When developing an emergency preparedness plan, facilities are expected to consider, among other things, the following:

  • Identification of all business functions essential to the facility’s operations that should be continued during an emergency;
  • Identification of all risks or emergencies that the facility may reasonably expect to confront;
  • Identification of all contingencies for which the facility should plan;
  • Consideration of the facility’s location;
  • Assessment of the extent to which natural or man-made emergencies may cause the facility to cease or limit operations; and
  • Determination of what arrangements may be necessary with other healthcare facilities, or other entities that might be needed to ensure that essential services could be provided during an emergency.

The further emergency preparedness requirements of individual state laws and regulations and the rest of Section 483.73 are too lengthy to describe here.  But here is a good start if you have to dust off your policies for disaster preparedness. Clearly, facilities can review the federal regulations and check off each requirement as it relates to each lengthy subsection of Section 483.73:

  • Policies and procedures
  • Communication Plan
  • Training and Testing
  • Emergency and Standby Power Systems
  • Integrated Healthcare Systems

In all, taking care of the necessary disaster or emergency preparedness policies and training in your facility now can give you better peace of mind when it comes to caring for the residents and the communities you serve.  

Neville M. Bilimoria is the Managing Partner of the Chicago Office, Partner in the Health Law Practice Group and member of the Post-Acute Care And Senior Services Subgroup at Duane Morris LLP.

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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