Communication Plan, Collaboration and Continuity: CMS Rule

by | May 22, 2017

Ensuring continuity of healthcare services in a disaster and having a common framework for collaborative emergency response are two of the motivations for the CMS emergency preparedness rule. Achieving these two goals requires hospitals and other healthcare facilities to have an emergency communication plan. This blog post, which is part of our series on the CMS emergency preparedness rule, looks at four vital pieces that your communication plan should have to comply with the CMS emergency preparedness rule.

Of all the elements of the CMS emergency preparedness rule, the communication plan may be the most important — and the most difficult.

In an emergency, conditions change rapidly. Job assignments and resources may need to be redistributed. The locations of staff and patients may evolve due to evacuation and disruptions to transportation. Your healthcare facility may need to request resources, to tell staff to stay home if it is unsafe to travel, or to reach out to other facilities in your hospital network or to coalition partners to house patients temporarily. Your hospital may need to work with unfamiliar volunteers and officials from local, state or federal agencies. You may need to make adjustments to the responsibilities of individuals and to the chain of command — on the fly.

You’ll need to adapt as the situation unfolds. A communication plan allows you to coordinate with others and to adjust dynamically to changes brought on by a situation. Your people need to know who to contact, what their contact can do, how to reach them, and when to do so. These are key parts of a communication plan.

Knowing who to reach, when, where, and how is a whole process in itself — and then layer onto that the need to keep a contact database up-to-date, have reliable ways to reach the right people, know that every message was received, and keep track of the status and content of every response. These are essential elements of an emergency communication and coordination system.

What’s more, through all this uncertainty, hospitals and other healthcare facilities are tasked by CMS with keeping patient information available and complying with HIPAA information-sharing rules.

Although the communication plan may have some overlap with the policies and procedures also described in the CMS emergency preparedness rule, the significance of communication capabilities makes it a stand-alone consideration for any emergency preparedness plan.

Four vital pieces of a communication plan for CMS emergency preparedness compliance

When designing a communication plan in compliance with the CMS rule, healthcare facilities should keep in mind the primary purpose of these plans:

“Patient care [that is] well-coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management agencies.”

With that goal at the fore, CMS wants the following four vital pieces covered in the communication plan:

1. Contact information for all relevant stakeholders

CMS specifies contact information for staff, physicians, other hospitals and entities providing services, and volunteers as a mandatory part of the communication plan, as well as contact information for federal, state, tribal, regional, and local emergency management agencies. This may seem obvious, but keep in mind that this information, in order to be useful, must be always up-to-date, and must be accessible to every constituent organization that is involved in an emergency response across a geographic region where it could be needed.

A central information source that provides flexible updates for all departments and satellite locations ensures that an offsite staff person isn’t out of the loop for want of current contact information. It can also facilitate one-touch group notification, so all parties can mobilize quickly based on the same up-to-date information.

2. Primary and alternate means of communication for staff and agencies

An all-hazard risk assessment for emergency preparedness should identify the most likely types of communication disruption. In general, facilities should prepare for inoperable landlines and overwhelmed cellular service. Although CMS does not make any specific recommendations, the rule notes that pagers, Internet, cable, walkie-talkies, ham radio and other options may be part of a facility’s plan.

Given that staff, leadership and volunteers may be in different circumstances depending on the type of emergency, a communication system that allows individuals to use multiple modes of communication could minimize interruptions of continuity.

3. A means of sharing patient information while maintaining privacy

At the most basic level, this requirement means including in the communication plan what type of patient information is releasable and who is authorized to release it. This could include a plan to share information with disaster relief efforts in order to notify families of the location and condition of family members. It may be helpful to establish a timeline of cues for when sharing information is necessary.

Many commenters on the CMS emergency preparedness rule pointed out that sharing information will be very difficult given the disparity in recordkeeping methods. Some facilities do not have digitized medical records and are not prepared to receive medical information digitally, such as through an EHR. Collaboration with community partners or healthcare coalitions will likely be an important part of developing this part of the communication plan. Whatever your facility decides, your tools or methods must be HIPAA-compliant.

4. A means of sharing resource information with other facilities

Most critically, healthcare facilities need to be prepared to provide information about their current occupancy, their resource needs, and their ability to provide assistance. The ability to share accurate information about available beds, medical supply inventory, and other resources is central to effective collaboration and continuity of care.

Review and update your hospital’s communication plan at least annually

All healthcare organizations will be required to review and update the communication plan annually. Keeping continuity and collaboration in mind as the ultimate goals will help ensure that your communication plan supports both the CMS emergency preparedness rule and the mission of your healthcare facility.

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What’s next?

Download the case study Public Health Emergency Preparedness Agencies Connect on the Fly for Metro Drill for a real-world example of how an emergency management system can facilitate communication between healthcare facilities and with emergency management agencies in a disaster or drill.

Upcoming: Our ongoing series on compliance with the CMS emergency preparedness rule will focus on training and testing.

Read the LiveProcess Emergency Manager datasheet.

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.