CMS Home Health Emergency Preparedness

by | Jul 27, 2019

cms-home-health-emergency-preparedness-plan-requirements-healthcareThis post was originally published Sept. 20, 2017. It has been updated to reflect revisions proposed September 2018.

When discussion began around the Centers for Medicare and Medicaid (CMS) emergency preparedness rule, home healthcare providers were quick to respond with concerns that some of the requirements would be especially difficult to meet before the November 2017 deadline. Because home health agencies (HHAs) have not had CMS home health emergency preparedness requirements in the past, many agency administrators feel at a disadvantage. Home health care agencies are expected to reach the finish line for CMS compliance at the same time as other healthcare facilities, even if starting from the back of the pack.

That doesn’t mean it’s time to panic. Responding to diverse, geographically dispersed public healthcare needs is completely in the wheelhouse of home health agencies. This is an area of strength that HHAs can build on. Moreover, as home healthcare continues to expand as an industry—driven by both a rising patient population and value-based payments that emphasize proactive care—the strategies and tools that home health care agencies use to manage growth are also applicable to home health emergency preparedness.

CMS home health emergency preparedness requirements: exceptions

The requirements for hospitals form the basis of the CMS emergency preparedness rule, and much of the discussion around the rule has focused on hospital emergency readiness. Most CMS emergency preparedness requirements for hospitals apply to all types of facilities. [Learn more about CMS emergency preparedness requirements in our blog series.] Some exceptions to the CMS rule apply to home health care agencies, but they have a limited scope.

For home health emergency preparedness, HHAs are not required to:

  • Plan to meet subsistence needs or take responsibility for home healthcare patients or staff who must shelter in place
  • Identify or act as an alternate care site
  • Provide evacuation for patients or track their location during an emergency

However, a key goal of the CMS rule is to standardize emergency preparedness guidelines to facilitate smoother collaboration. In several cases, CMS responded to comments regarding the special circumstances of home health emergency preparedness with the admonition that HHAs were expected to find a solution and comply by the deadline. This included challenges such as:

  • Ensuring adequate technological resources to provide both primary and backup communication options
  • Participating in community emergency preparation planning, especially given the historical exclusion of specialized healthcare providers from these programs
  • Communicating patient’s needs, condition and health history to appropriate agencies, officials or alternate care providers as needed (in compliance with HIPAA)

Communication, continuity and collaboration for home health emergency preparedness

As home health care agencies address these specific challenges in emergency preparedness planning, it will help to remember that the following Three Cs are the drivers behind the CMS requirements:

Communication means having an emergency preparedness communication plan for swift, efficient contact with staff, families, other healthcare providers, and federal, state, tribal, regional, and local emergency agencies. Home health agencies will need to:

  • Maintain up-to-date, readily accessible contact lists. Classifying contacts by location, certification, department and other essential categories can help ensure that relevant information reaches the right group.
  • Adopt multiple modes of communication to provide consistent contact regardless of phone outage or cellular overload. Some agencies may find that a Bring Your Own Device (BYOD) approach helps maintain communication coverage without a lot of new hardware or training on new devices.
  • Follow up with all patients following an emergency to determine needed services, and inform officials about on-duty staff and patients who could not be reached. This requirement is instead of the tracking requirement that most inpatient facilities must follow. Home healthcare agencies will need a reliable method of tracking and logging communications, including the status of messages not received or responded to, to ensure no one is missed.

Continuity means ensuring necessary services will be provided in the event of a disaster or emergency. Home health care agencies will need to:

  • Establish a home health emergency preparedness plan for each patient. Ideally patient plans were already created as part of the initial assessment, and can be minimally adapted to include assessment of risks and essential contacts.
  • Develop policies and procedures to inform state and local officials about home healthcare patients whose medical or psychiatric conditions will require evacuation. Though home health agencies are not responsible for establishing arrangements for evacuation or transfer of care, they play a critical role in communicating that need.
  • Utilize event logs and training exercises to identify the gaps in emergency preparedness plans and annually update plans to address them.

Collaboration means putting plans, tools and strategies in place that allow community healthcare providers to coordinate communication, resources, shelter and services during a disaster or emergency. Home health agencies will need to:

  • Create a plan for communicating with local authorities or the incident command center regarding the home healthcare agency’s needs and ability to provide assistance. This is in place of a hospital’s requirement regarding occupancy.
  • Participate in an annual full-scale community exercise, and conduct an annual tabletop exercise. If a community-based exercise is not available, the home health agency must coordinate its own full-scale exercise. If proposed revisions to the CMS Final Rule are accepted, agencies may only need to complete one emergency preparedness exercise annually.
  • Work with other community members, such as hospitals, state and local public health departments, and emergency management agencies, to create a communication plan to ensure consistent patient care. Some commenters suggested that home healthcare agencies have found inclusion difficult in community emergency preparedness plans. CMS responded that home healthcare agencies must document their efforts to participate and create an independent process for collaboration.

Getting started with planning for home health emergency preparedness

It may help to consider that several of these elements are efficiencies that will be beneficial in daily use, such as structured contact groups, multiple modes of communication, and communication logging. For some other items — emergency preparedness training and testing, sharing patient records, and community-response planning—home health care agencies can also elect to be part of a larger healthcare system’s emergency preparedness program. Although the home healthcare agency will also be surveyed individually for compliance with the CMS rule, a system-wide plan for communication and training offers home health care agencies potential time and costs savings, in both planning and execution.

Healthcare communication tools such as LiveProcess Communicator can help home health agencies meet CMS emergency preparedness requirements confidently, while also supporting care coordination, staffing, workflow management and other daily needs.

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Healthcare communication tools such as LiveProcess Communicator can help home health agencies meet CMS emergency preparedness requirements confidently, while also supporting care coordination, staffing, workflow management and other daily needs.

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Next steps

This post is part of a series on the CMS emergency preparedness rule. If you’ve missed any part of the series, I encourage you to explore the following:

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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.