Emergency Preparedness Rule Provider Resources
The Centers for Medicare and Medicaid Services (CMS) do not plan to provide any formal technical assistance, such as CMS-led trainings, to providers and suppliers. Instead, as with all regulations, they will release interpretive guidance for the regulation to help facilities implement the regulations and provide information regarding best practices.
They encourage facilities to use the extensive resources listed in the proposed and final rules, and we have listed many of them here.
Agencies and Organizations
Assistant Secretary for Preparedness and Response (Check out the healthcare emergency preparedness information on their TRACIE web portal, which includes resources to improve preparedness, response, recovery and mitigation efforts. It has sample plans, tools, templates, and training and exercise materials and provides access to expert technical assistance and an information-sharing exchange platform to assist the exchange of best practices, vetted tools, and information between public health, healthcare professionals, and emergency preparedness partners. (TRACIE stands for Technical Resources Assistance Center Information Exchange.)
Health Resources and Services Administration (Check out their information on emergency preparedness and continuity of operations.
Institute of Medicine, now called the Health and Medicine Division (of the National Academies of Sciences, Engineering and Medicine).
Substance Abuse and Mental Health Services Administration’s (SAMHSAs) Disaster Technical Assistance Center (DTAC) for behavioral/mental health response.
Research and Tools
‘‘Provider Survey and Certification Frequently Asked Questions: Declared Public Health Emergencies—All Hazards, Health Standards and Quality Issues’’, (updated 5/21/2013) answers questions for all providers and suppliers regarding the lessons learned during and after incidents, and links to other emergency preparedness planning resources.
Planning tools along with other emergency management and business continuity information can be found on Health Resources and Services Administration’s (HRSA) web site and also in HRSA’s, Policy Information Notice entitled, Health Center Emergency Management Program Expectations ,August 22, 2007.
National Fire Protection Association’s (NFPA) NFPA 1600: Standard on Disaster/Emergency Management and Business Continuity Programs, 2013 Edition, This address the development, implementation, assessment, and maintenance of programs for prevention, mitigation, preparedness, response, continuity and recovery. Under most definitions, the NFPA 1600 is an industry standard for disaster management.
Healthcare System Preparedness and Health Care Coalitions
January 2012. Information, guidance and resources to support planners in preparing for mass casualty incidents and medical surges from the Assistant Secretary for Preparedness and Response (ASPR). The document includes a total of (8) healthcare preparedness capabilities that are: (1) Healthcare system preparedness (for example. information regarding healthcare coalitions); (2) healthcare system recovery;(3) emergency operations coordination, (4) fatality management; (5) information sharing; (6) medical surge; (7) responder safety and health; and (8) volunteer management.
Adapting Standards of Care Under Extreme Conditions: Guidance for Professionals During Disasters, Pandemics, and Other Extreme Emergencies. Prepared for the American Nurses Association by the Center for Health Policy, Columbia University School of Nursing, policy paper, March 2008. Aimed at the nursing population, this paper discusses the challenges to meeting the usual standards of care during natural or man-made disasters and makes recommendations for effectively providing care during emergency events.
‘‘Guidelines for Establishing Crisis Standards of Care for Use in Disaster Situations,” (Institute of Medicine (IOM) September 2009) report to the HHS provides guidance for State and local health agencies and health care facilities regarding the standards of care that should apply during disaster situations. This report covers guidance on conserving, substituting, adapting, and doing without resources.
CMS Emergency Response and Recovery page, with downloads and related links.
Emergency Preparedness Checklist – Recommended Tool for Effective Health Care Facility Planning from Centers for Medicare and Medicaid Services, 2014
Emergency Preparedness Related to People with Disabilities
The National Council on Disability’s Web site has a page entitled, ‘‘Emergency Management,’’
Reports from the National Council on Disability contain specific information on emergency planning for people with disabilities and how important it is to include them in emergency planning. These include:
Developing and Maintaining Emergency Operations Plans, November 2010, Federal Emergency Management Agency
Surge Tool Kit and Facility Checklist, Reopening Shuttered Hospitals to Expand Surge Capacity, prepared for the Agency for Healthcare Research and Quality in February 2006. This web-based interactive tool allow hospitals and emergency planners to estimate the resources needed to treat a surge of patients resulting from a major disaster, such as an influenza pandemic or a terrorist attack.
Hospital Patient Tracking
The Joint Patient Assessment and Tracking System (JPATS) was developed through an interagency association between The Department of Human Services, The Assistant Secretary of Preparedness and Response and the Department of Defense.
Hospital Evacuation Decision Guide is designed to provide hospital evacuation decision teams with organized and systematic guidance on how to consider the many factors that bear on the decision to order an evacuation, and assist decision teams in identifying some of the special situations, often overlooked, that may exist in their facility or geographic area that could affect the decision to evacuate. The evacuation guide distinguishes between ‘‘pre-event evacuations’’ which are undertaken in advance of an impending disaster, such as a storm, when the hospital structure and surrounding environment are not yet significantly compromised and ‘‘post event evacuations,’’ which are carried out after a disaster has damaged a hospital or the surrounding community.
Hospital Assessment and Recovery Guide (AHRQ Publication No. 10–0081), helps hospitals determine when to get back into a hospital after an evacuation. Comprised primarily of a 45-page checklist, the guide covers 11 separate areas of hospital infrastructure that should be evaluated before determining that it is safe to reoccupy a facility, such as security and fire safety, information technology and communication and biomedical engineering.
For Health Centers
Health Center Emergency Management Program Expectations, (No. 2007–15), dated August 22, 2007 has content that is relevant to all health providers.
Rural and Small Communities
Rural Communities and Emergency Preparedness, (published by the Health Resources and Services Administration’s (HRSA) Office of Rural Health Policy, April 2002, addresses the issues faced by rural communities with respect to emergency preparedness. There are many factors that limit the ability of rural providers and suppliers to deliver optimal health care services in the event of a natural or man-made disaster. The authors found that geographic isolation is a significant barrier to providing a coordinated emergency response.
Providing Mass Medical Care with Scarce Resources: A . Community Planning Guide, published by AHRQ, Publication No. 07-0001, Rockville MD, February 2007. Disasters can create situations where scarce resources must be distributed in a manner that is different from usual circumstances, but still appropriate to the situation.
Standing Together: An Emergency Planning Guide for America’s Communities, published by The Joint Commission 2006 (TJC), is a comprehensive resource that offers step-by-step guidance for development of an emergency preparedness plan that is applicable to small, rural, and suburban communities. This document may be particularly useful for small or rural facilities and agencies.
Hazard Analysis/Hazard Vulnerability Assessment
The Comprehensive Preparedness Guide 201: Threat and Hazard Identification and Risk Assessment Guide, August 2013.
Preparedness Guide 201 Supplement 1: Threat and Hazard Identification and Risk Assessment Guide Toolkit, April 2012.
The Use of Threat and Hazard Identification and Risk Assessment for Preparedness Grants, April 2012.
Meeting HIPAA Requirements During Emergencies
BULLETIN: HIPAA Privacy in Emergency Situations, November 2014, U.S. Department of Health and Human Services, Office for Civil Rights.
HIPAA Privacy Rule: Disclosures for Emergency Preparedness - A Decision Tool. This tool guides the user through a series of questions to find out how the Privacy Rule would apply in specific situations. By helping users focus on key Privacy Rule issues, the tool helps users appropriately obtain health information for their public safety activities. It is designed for covered entities as well as emergency preparedness and recovery planners at the local, state and federal levels.
HIPAA Privacy Rule Compliance Guidance and Enforcement Statement For Activities in Response to Hurricane Katrina
The 1135 Waiver Process
Requesting an 1135 Waiver, a CMS Survey and Certification document. Under an 1135 waiver, health care providers unable to comply with one or more waiver eligible requirements may be reimbursed and exempted from sanctions (absent any determination of fraud or abuse). Requirements to which an 1135 waiver may apply include Medicare conditions of participation or conditions for coverage and requirements under the Emergency Medical Treatment and Labor Act (EMTALA). The 1135 waiver authority applies only to specific federal requirements and does not apply to any state requirements, including licensure.
Training and Exercise Planning
Bioterrorism Preparedness Training and Assessment Exercises for Local Public Health Agencies, 2005, by the RAND Corporation, Dausey, D. J., Lurie, N., Alexis, D., Meade, B., Molander, R. C., Ricci, K. A., Stoto, M. A., and Wasserman, J. This report was intended as a resource to train public health workers to detect and respond to bioterrorism events and to assess local public health agencies’ (LPHAs) levels of preparedness over time. It is also a useful resource for hospitals and other healthcare facilities to train their own healthcare workers.
Homeland Security Exercise and Evaluation Program (HSEEP) April 2013, provides guidance to organizations in conducting an annual training and exercises and developing a multi-year training and exercise plan.
Tabletop Exercise for Pandemic Influenza Preparedness in Local Public Health Agencies, 2006, by the RAND Corporation, by Dausey, D.J., Aledort, J.E., and Lurie, N. This report is designed to provide state and local public health agencies and their healthcare and governmental partners with exercises in training, building relationships, and evaluation. These exercises were pilot tested at three metropolitan-area local public health agencies in three separate states from August through November 2005.
The Health Care Provider After Action Report/Improvement Plan (AAR/IP) template can be found at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Templates-Checklists.html. Scroll down to click on the download entitled, Health Care Provider Voluntary After Action Report/Improvement Plan Template and Instructions for Completion. This voluntary, user-friendly tool for health care providers can be used to document their performance during emergency planning exercises and real emergency events to make recommendations for improvements for future performance. Thorough completion of the template complies with CMS requirements for provider exercise documentation, however, it is not required that you use this template.
Protecting Healthcare Workers During an Emergency
Resources to aid providers and suppliers in developing policies and procedures to protect healthcare workers during an emergency:
Recovery of Operations Planning
Continuity Guidance Circular 1 (CGC 1), and Continuity Guidance for Non-Federal Entities (States, Territories, Tribal, and Local Government Jurisdictions and Private Sector Organizations)
Delivering Effective Mental Health and Substance Abuse (Behavioral Health) response to disasters can be found at the Substance Abuse and Mental Health Services Administration’s (SAMHSA) Substance Abuse and Mental Health Services Administration’s (SAMHSA) Disaster Technical Assistance Center (DTAC).