All-Hazards Risk Assessment: CMS Emergency Preparedness Rule

by | Jan 15, 2019

Original publication date: April 3 2017. Updated January 15, 2019

all-hazards-approach-hurricane-502159069-200x133This post continues our blog series on how to comply with the CMS emergency preparedness rule (PDF), specifically the requirement to use an all-hazards approach to risk assessment.

CMS requires an all-hazards approach

A fundamental requirements of the CMS emergency preparedness rule is the approach to risk assessment. CMS requires that healthcare facilities employ an all-hazards approach. 

“An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters.”  (S&C:17-17-ALL)

Key aspects of an all-hazards approach to risk assessment include:

  • Developing plans that are flexible and scalable enough to adapt to a wide variety of disasters
  • Focusing on the continuity of essential services that must remain consistent regardless of the disaster
  • Assessing the risks most likely to affect an individual facility and community

That last point is key: during the comment phase of CMS emergency preparedness rulemaking, some healthcare leaders expressed concern that an all-hazards approach to emergency preparedness would be too broad. Writing a detailed plan for every single possible emergency would be too much work for any facility, with little benefit.

It’s important to note that the all-hazards approach applies to risk assessment, not to drafting policies and procedures. The emergency management team analyzes possible scenarios and develops a plan based on the areas of highest risk. A coastal Florida hospital doesn’t need to prepare for a blizzard, and a Minnesota long-term care facility doesn’t have to worry about hurricanes.

Assessing risk means both examining the likelihood of particular scenarios—severe weather disasters as well as pandemics or terrorist attacks—and evaluating the extent to which they will impair a facility’s operations and essential services.

A Hazard Vulnerability Analysis (HVA) looks at facility’s current level of emergency preparedness and the human, property, and business impact of multiple hazards. The hazard vulnerability analysis can help quantify the level of risk and the severity of impact, so preparedness efforts address the most important potential emergencies.

Continuity of operations and community collaboration

Other requirements related to risk assessment necessitate that emergency preparedness plans address continuity of operations, in both the healthcare facility and the community. Key criteria include:

Other key elements of risk assessment for CMS emergency preparedness compliance

CMS also calls out the need to focus on at-risk patient populations when creating an emergency plan. That group includes patients who are medically at risk, such as people with disabilities, pregnant women, children, and senior citizens, and patients who are at risk for non-medical reason. The latter group would include patients from distinct cultural or religious backgrounds, as well as patients with limited English proficiency. This emphasis on unique patient populations underscores the importance of each healthcare facility developing an emergency management plan tailored to its location and its role in the wider community.

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Next steps

Some hospitals and healthcare facilities will already have some of these plan elements in an Emergency Operations Plan (EOP), especially where there is overlap with Joint Commission guidelines. Others facilities may need more help. In either case, templates and tools designed for emergency management planning can make compliance with the CMS emergency preparedness rule easier.

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terry-zysk-100x100Terry Zysk, CEO of LiveProcess, has more than two decades of experience in leading organizations that provide innovative solutions to the healthcare industry.