Planning for Collaboration: CMS Emergency Preparedness
When the Centers for Medicare and Medicaid Services (CMS) drafted emergency preparedness regulations, one of their stated goals was to address the “patchwork of federal, state, and local laws and guidelines” for emergency planning. The CMS emergency preparedness rule is designed to put all healthcare facilities on the same page, so that they can more easily coordinate communication, resources, shelter and services.
Planning ahead for collaboration with other organizations during disaster response is a critical aspect of each of the core elements in the CMS emergency preparedness rule:
- Risk assessment
- Policies and procedures
- Training and testing
1. Collaboration and its effect on all-hazards risk assessment
Opportunities for collaboration can mitigate the severity of a facility’s risk assessment and Hazard Vulnerability Analysis (HVA). The acuity of each risk and vulnerability will partially depend on the availability of shared resources, expertise and specialty equipment across networks or coalitions — and the ability to coordinate an effective emergency response.
Location will often be a factor. For example, a rural hospital may have specific challenges with finding alternate sites to care for patients or ensuring transportation, while an urban hospital will have readier access to more city, county, state and other government agencies to work with. A facility in an area with diverse cultural communities may need to anticipate working in a multilingual environment.
2. Policies and procedures to support continuity of operations
The first goal of CMS guidelines for emergency preparedness policies and procedures is providing continuity for patient care. That can include anything from having alternate power sources and food storage to tracking patients and activating an evacuation.
Key collaborative elements in this section include:
- Having patient medical records available to share in the event of an evacuation or relocation
- Ensuring that staff and patient whereabouts can be shared with other emergency responders and agencies
- Creating procedures for receiving patients from other facilities
- Establishing clear guidelines for working with community volunteers and other non-staff in the event of a medical surge
3. Communication plan for collaboration
A CMS-compliant communication plan will prepare a facility to stay in contact with its own staff as well as service providers, volunteers, and federal, state, tribal, regional, and local emergency management agencies during disaster response. Planning for multiple modes of communication is required by CMS, in the event that standard communication sources are disrupted.
The communication plan must also prepare organizations to share information about current occupancy and resources, such as whether they are lacking supplies or have room to provide assistance. Sharing HAvBed status or equipment needs with the wider healthcare community helps response teams redirect patients and resources to ensure continuity of patient care.
Finally, a communication plan needs to be flexible enough for alternative staff roles and quick changes in hierarchy. If the hierarchy of facilities or agencies changes as the response team grows, leadership will need fast access to a log of events and communications that have already happened, updates on the status of personnel and resources, and easily accessible contact information for all stakeholders.
4. Testing and training for emergency preparedness
CMS requires that all healthcare facilities participate in at least one full-scale community exercise annually, if available. (What constitutes community for any given facility is up to emergency managers to decide based on their risk assessment.) Though facilities in very remote areas can substitute testing confined to the facility itself, most healthcare facilities will need to participate in and document exercises involving collaboration with other community members. Annual updates to the Emergency Operations Plan (EOP) or Continuity of Operations Plan (COOP) should be made based on After Action Reports following these training events, closing any gaps in the plans for improved response across organizations in the future.
Many larger healthcare facilities are already involved with community emergency preparedness exercises. For smaller facilities, the full-scale community requirement may be something new. One bright spot is that CMS allows separately certified healthcare facilities that operate within a larger healthcare system to work within the system’s unified emergency preparedness program. In addition to improving care coordination, this arrangement also helps mitigate the costs of testing and training programs for smaller facilities.
Facilitating the ability to coordinate with other facilities and government agencies should be a priority at every step of the emergency preparedness process. In today’s wired world, any healthcare facility can improve communication and collaboration for a more agile response.
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Read the LiveProcess Emergency Manager datasheet.
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:
- Are You Ready for the CMS Emergency Preparedness Final Rule?
- Start Here: Hospital CMS Emergency Preparedness
- CMS Emergency Preparedness Regulations Overview
- All-Hazards Approach: Risk Assessment for CMS Rule
- Hospital Readiness for Likely Threats: CMS Emergency Preparedness
- Policies and Procedures for Continuity: CMS Emergency Preparedness Rule
- Communication Plan, Collaboration and Continuity: CMS Emergency Preparedness Rule
- Emergency Preparedness Training and Testing: CMS Rule
- Planning for Collaboration: CMS Emergency Preparedness
- CMS Home Health Emergency Preparedness