CHUG: The Ever-Evolving Evolution of Emergency Preparedness in Healthcare
CHUG: The Ever-Evolving Evolution of Emergency Preparedness in Healthcare by Connie Polke
After the devastating effects of Hurricane Katrina in 2005, the Office of Inspector General (OIG) examined how prepared long-term care organizations were for emergencies. The results of the OIG report in 2006 were eye-opening.
According to the OIG report, "In some cases, problems can be tied to a lack of effective emergency planning or failure to properly execute the emergency plans." (Levinson, 2006). The report mentioned that long term care experienced problems with evacuation or sheltering-in-place, resources, a lack of collaboration with government emergency entities, and ineffective planning for provisions in the event of a disaster or emergency.
To proactively address these issues, the OIG made recommendations through the Centers for Medicare and Medicaid Services (CMS) to improve nursing home emergency preparedness by strengthening plan standards. The OIG also encouraged improved communication between local, state, and federal emergency entities and nursing homes during emergencies.
It wasn't until 2015, 10 years after Hurricane Katrina, that CMS proposed compliance changes to healthcare emergency preparedness programs. These suggestions would impact 17 healthcare providers and suppliers. The final rule became effective in November 2016, but implementing and endorsing the rule is still a work in progress. The major components of the Emergency Preparedness Requirements are:
Hazardous Risk Assessment
Communication Internal and External Plans
Emergency Preparedness Policies and Procedures
Training and Exercise Program
CMS is responsible for implementing a final rule. However, each state's Department of Public Health's responsibility is to ensure that provider surveys are conducted and comply with the Federal requirements. If the organization is non-compliant with the protocols or rules, the organization will receive a citation. The organization must then respond with a plan of correction based on the citation.
According to CMS, "Deficiencies are based on violations of the regulations, which are to be based on observations of the nursing home's performance or practices" (CMS, 2016). If the organizations do not provide a plan of correction, the organization could suffer fines and even lose participation with Medicare and Medicaid. Loss of participation from Medicare and Medicaid can significantly impact the financial stability of the organization.
To address the OIG's suggestion to strengthen the communication between emergency entities, the U.S. Department of Health and Human Services, Office of the Assistant Secretary for Preparedness and Response, implemented the Healthcare Coalition to support healthcare organizations during emergency response and recovery. A vital element of the Healthcare Coalitions is to promote collaboration of healthcare organizations and integrate Coalition members into the broader community response to an emergency or disaster.
Between 2019 and 2020, Life Safety, in collaboration with the Department of Public Health and CMS, became responsible for surveying Long Term Care for Emergency Preparedness in addition to Fire Safety. The survey is based on Appendix Z of the CMS Emergency Preparedness Program. There are 24 Emergency preparedness E-tags (deficiencies) that can impact an organization, as well as adherence to the Fire Safety (K-tags) Federal requirements.
In addition to the changes to the Life Safety Survey, there was also a change to how an organization must respond to a plan of corrections. Currently, an organization must now provide the emergency preparedness policies and procedures and the supporting documentation of training and participation in exercises within their plan of corrections that address each deficiency (E-tag).
During this duration, the Collaborative Healthcare Urgency Group (CHUG) saw a colossal change in healthcare emergency preparedness deficiencies. CHUG assisted their members through consulting and their response with their Plan of Corrections.
CHUG addressed E-tags by:
Revising the Emergency Operation Plan (EOP) templates
Creating a CHUG CHECK (cross-walk) to assess the organizations' compliance
Adding further training and exercises annually to assist organizations with federal, state, and Joint Commission requirements.
CHUG provides these services to most of the 17 healthcare providers and suppliers of the CMS emergency preparedness rule.
In 2020, there was an abrupt halt to Life Safety Surveys due to the impact of COVID-19 on healthcare facilities, especially on nursing homes and hospitals. During COVID, healthcare organizations were hit with the implementation of ever-evolving guidelines that seemed like a revolving door.
Healthcare organizations have to stay current with pandemic planning and ensuring patients' safety through proper personal protective equipment (PPE). They have to stay updated on infection control guidelines, lab testing practices, the CMS training program mandate for long-term care, and now, vaccine rollout. The healthcare community is already one of the most highly regulated organizations. Adding more requirements puts a higher burden on the already tormented system.
As healthcare marches on in 2021, COVID persists, and Life Safety Surveys have resumed. CHUG is seeing an increase in membership and consulting services requests as life goes on.
In a recent conversation with a Public Health official, he encouraged CHUG to continue providing best practice guidance, training, and exercises for healthcare organizations so that they can succeed in keeping patients safe with high and proficient performance and practices.
Connie Polke, Collaborative Healthcare Urgency Group (CHUG) Founder
References:
Centers for Medicare and Medicaid. (2016, November). Nursing Homes. Retrieved January 20, 2021, from https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes
Levinson, D. R. (2006, August). Nursing Home Emergency Preparedness And Response During Recent Hurricanes. Retrieved January 20, 2021, from http://ltcrisklegalforum.com/uploads/OIGNHEmergPrepAug2006-50283.pdf