June 1, 2019
Emergency Preparedness- Updates to Appendix Z of the State Operations Manual (SOM)
When the Centers for Medicare and Medicaid (CMS) adapted its emergency preparedness rule for long-term care (LTC) facilities including nursing homes, it made a few changes. Many skilled nursing facilities (SNFs) and other facilities under the LTC facility umbrella offer a high-level of care on a 24-hour basis, meaning that they have many of the same continuity-of-operations needs as a traditional hospital. Thus, for example, of 16 different types of healthcare facilities distinguished in the CMS emergency preparedness rule, only long-term care facilities share the hospital requirement to maintain emergency and standby power systems.
CMS also noted a critical difference between long-term care facilities such as nursing homes, and hospitals: a LTC facility is the home of many patients, because of their length of stay. The facilities’ relationship with patients and and their families is shaped by this unique circumstance, and as a result facilities have a special responsibility to their clients.
Therefore in the final rule, the CMS emergency preparedness requirements for long-term care facilities are the same as for hospitals except for one critical provision: LTC facilities such as nursing homes are required to track patients and on-duty staff during and after an emergency, whether they have sheltered in place or been evacuated to an alternate care site. The tracking needs to be documented in a way that is easily communicated, as appropriate, with each patient’s family, friends or other representatives, and with emergency response systems.
Most LTC facilities such as nursing homes will already have emergency operation plans (EOP) and/or continuity of operation plans (COOP) in place, but many will not have a formal written communication plan containing the elements CMS requires.
In response to comments on the proposed rule, CMS made clear that long-term care facilities will have maximum flexibility to choose which information should be shared with the patient’s families or representatives, and on what timeline. That flexibility extends to both the emergency plan itself and the status of patients during or after a crisis that actuates the emergency plan. What’s essential is that LTC facilities such as nursing homes develop and maintain a method of their choosing to share the information.
The requirement for tracking patient location during and after an emergency has two aspects. First, patient location must be accurately tracked and readily updated as circumstances change. Second, that information must be accessible and easy to release to the appropriate recipients.
Many long-term care facilities may already be part of a healthcare system. While that doesn’t obviate the need to develop a facility-specific emergency and communication plan, it can minimize some of the obstacles to ensuing smooth, speedy sharing of information. As the CMS deadline approaches, independent and system-based LTC facilities may also want to cast a wider net to discern the possibility of working within a community-based healthcare coalition. Sharing the effort of planning, writing and testing a strong emergency and communication plan that will work together can save lives, time and money.
The number of skilled nursing and other LTC facilities in a given area should also factor in to emergency planning, starting with the risk assessment stage and at every other part of the planning process. In May 2017, Modern Healthcare reported that there are four times as many nursing homes as hospitals. Suppliers, hospitals, transportation vendors and emergency response agencies could easily become overwhelmed in a crisis, making planning for this risk, and collaborative testing and training, a crucial part of meeting the CMS regulations for emergency preparedness.
HT: Live Process