Earthquakes in Japan, floods in Ohio and Illinois, wildfires in Texas, tornadoes in too many states to count, and with the Atlantic hurricane season shortly upon us, the healthcare sector has to be prepared for any kind of disaster that may come its way.
Focus on hospital disaster preparedness and emergency management came to light following Hurricane Katrina in 2005. The Katrina aftermath stressed the importance of healthcare institutions developing a living, flexible emergency preparedness plan and, more importantly, following the plan when a disaster strikes. Since Katrina, The Joint Commission (TJC) and CMS set new accreditation requirements and structured distinct performance standards around emergency preparedness. Too, for institutions that put their plans on the shelf until a disaster strikes or do not follow their plan, legal liability may ensue should any injury or death occur during the emergency. Many healthcare facilities formed dedicated emergency management departments following Katrina to focus on the development, education and implementation of their plans, not just to meet the accreditation requirements, but to protect the patients and the facilities in times of disasters. Best in Class facilities drill their plans several times each year, conduct after action plans and improve their plans on an ongoing basis.
Several agencies make up the alphabet soup that governs emergency preparedness: CMS; National Hospital Preparedness Program (NHPP); Homeland Security Exercise and Evaluation Program (HSEEP); National Incident Management System (NIMS); Hospital Incident Command Systems (HICS); Occupational Safety & Health Administration (OSHA); and Center for Disease Control and Prevention (CDC). Depending on the emergency, each of these agencies, in addition to TJC and individual state regulatory bodies, have specific requirements that an emergency management program must address. CMS includes as part of its Conditions of Participation the following emergency preparedness requirements for hospitals:
- Assuring medical staff has written policies and procedures for appraisal of emergencies and needs anticipated by the facility;
- Developing and implementing emergency plans to ensure the safety and well-being of staff and patients during emergency situations;
- Meeting applicable standards of the National Fire Protection Association and Life Safety Code.
The hospitals may comply with these requirements by conducting exercises semi-annually that test the elements of their emergency plans. CMS also recommends that the hospital take corrective action on any deficiencies it identifies from the exercise.
Two years ago, TJC added a separate standard chapter on emergency management, highlighting the adverse threats a disaster can have on patient safety and the hospital's ability to provide care, treatment and services for an extended length of time. Power failures, water and fuel shortages, flooding and communications breakdown are hazards that need to be contemplated when preparing the emergency management plan. TJC recognizes the four phases of emergency management as mitigation, preparedness, response and recovery which all occur over the duration of the disaster. The plan must address each of these phases. Drills to test the plan are expected with corrective action being taken to improve performance after each exercise.
The NHPP provides funds to individual states and local jurisdictions that meet their requirements. Those jurisdictions then distribute the funding to hospitals and may require those facilities to provide certain deliverables as a condition of receiving funding. This funding has gradually lessened over the last few years but is still available in some areas. NHPP mandates NIMS compliance which requires the use of HICS as part of an emergency management program. NIMS and HICS provide preparedness fundamentals that not only comply with NHPP funding but are best practices for managing disaster events. OSHA has additional guidance related to preparedness to protect staff during disasters.
It is important for facilities to be ready to respond to any disaster. It is not a matter of if, but when, an event will strike, and no one is completely protected. The Best in Class programs regularly assess hazard vulnerabilities, develop a plan around those hazards, drill the plan in a variety of scenarios and improve the plan as needed, with engagement of all levels of leadership.