All-Hazards Approach: Risk Assessment for CMS Rule
The clock has started ticking for healthcare facilities to comply with the requirements of the Centers for Medicare and Medicaid Services (CMS) emergency preparedness rule. This post continues our series where we take a closer look at the CMS emergency preparedness rule (PDF), specifically an all-hazards approach to risk assessment.
CMS risk assessment requires an all-hazards approach
One of the fundamental requirements of the CMS emergency preparedness rule is the approach to risk assessment. CMS now requires that 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 rulemaking, some healthcare leaders expressed concern that an all-hazards approach 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 preparedness and the human, property, and business impact of multiple hazards. The HVA 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 changes related to risk assessment require that plans address continuity of operations, in both the facility and the community. Key criteria include:
- Addressing the essential services that will be provided by the facility in an emergency in the written plan
- Documenting the chain of command and responsibility, including succession and delegation planning
- Establishing a process for cooperation and collaboration with local, tribal, regional, state and federal emergency preparedness officials, to facilitate integration during large-scale events
Other key elements of CMS risk assessment
CMS also called out the need to focus on at-risk patient populations when creating an emergency plan. That group includes both 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 facility developing a plan tailored to its location and its role in the wider community.
The next steps
Some hospitals and healthcare facilities will already have some of these elements in the Emergency Operations Plan (EOP), especially where there is overlap with Joint Commission guidelines. Others may have more catching up to do. In either case, templates and tools designed for emergency planning can make compliance with CMS emergency preparedness rule easier.
Get our Checklist for CMS Emergency Preparedness Compliance for Hospital Preparedness Coordinators for an easy-to-follow guide to get started or adjust your current plans.
Next blog post: Hospital Readiness for Likely Threats: CMS Emergency Preparedness.
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