Emergency planning is crucial to safeguarding the well-being of individuals in long-term care settings during unforeseen events. By being proactive and implementing comprehensive plans, facilities can minimize risks, ensure continuity of care, and protect residents and staff members. But are we doing enough?
Developing emergency preparedness programs
The Centers for Medicare & Medicaid Services enacted a final rule in 2016 on Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers, which was updated in 2019.
Since the enactment of these regulations, long-term care facilities have done much to become better prepared for emergencies, but there is still more work to be done. The core elements of CMS’ Emergency Preparedness Rule provide a good foundation for individual facilities to develop their emergency preparedness programs.
Risk assessment and planning. Healthcare providers must conduct a comprehensive risk assessment to identify potential emergencies that could affect their facility. An emergency plan must then be developed with community partners to address the specific risks and outline strategies for preparedness, response and recovery.
Policies and procedures. Providers must establish and maintain essential emergency preparedness policies and procedures for a range of areas, including communication, patient tracking, staff responsibilities, medical documentation and patient care continuity. Emerging infectious diseases, missing residents and other current rising issues should also be considered (e.g., cybersecurity).
Communication plan. Providers must develop and maintain a communication plan that ensures timely and effective communication during emergencies. The plan should include strategies for communication with staff, patients, volunteers, external emergency response agencies and the public. Alternate means of communication must be established in case traditional systems are unavailable.
Training and testing. Along with training staff on the emergency plan, providers are required to conduct regular drills and exercises to test the plan, evaluate its effectiveness and identify areas for improvement.
Emergency power and utilities. Contingency plans must be established to ensure the continuity of essential utilities (e.g., power, water, HVAC) during emergencies. Facilities should have alternative sources of power and maintain the equipment necessary to support patient care and safety; local and state regulations may be more stringent than CMS Standards.
Tracking and reporting. Providers are required to implement systems for tracking the location and well-being of patients, both within the facility and during transfers or evacuations. Necessary information must be reported to relevant authorities, such as state and local emergency management agencies.
Develop partnerships
Crisis management in skilled nursing and long-term care facilities is an incredibly complex endeavor that involves the cooperation of risk management, the executive suite, vendors, suppliers and the community. To ensure an effective response and recovery, long-term care facilities should consider developing partnerships with other corporate and government entities.
Corporate assistance. Healthcare corporations play a critical role in responding to disasters, as they can leverage their resources, expertise and networks to support affected facilities. Corporate entities’ response plans should be similar to the facility plans within the organization and include activation levels, processes, incident command functions, and procedures for assembling responders. These corporate plans should also be trained on and tested regularly.
Local/regional/state emergency management, first responders (fire, police, EMS) and public health. Long-term care facilities must coordinate their emergency preparedness efforts with local, state, tribal and regional emergency management agencies. This includes participating in community-wide emergency exercises. During large events, however, these partners may have competing priorities and limited bandwidth to help individual facilities with non-emergent consequences.
Emergency Support Function 8. An Emergency Support Function is a key component of a Comprehensive Emergency Management Plan that provides a framework for organizing specific capabilities, resources and services during emergency response and recovery efforts. ESFs are typically used in the United States as part of the National Response Framework and National Incident Management Assistance Teams system at federal, state, regional, county and/or local levels.
ESF-8 is responsible for coordinating public health and medical response activities during emergencies and disasters. Often activated by local, regional and state emergency operations centers, ESF-8 entities can be partners in planning and response for long-term care. Because the above-mentioned entities are often tasked with supporting many different groups, all stakeholders, including LTC, may need to be prioritized when there is limited or high demand for resources.
Be part of the process
The investigative report Left in the Dark, developed by the Majority staff of the U.S. Senate Committee on Finance and the Senate Special Committee on Aging, recommends that “CMS, the Department of Homeland Security, states and local governments should ensure that older adults, people with disabilities, and residents of long-term care facilities are substantially involved in emergency planning, response, mitigation, management and recovery.”
Long-term care facilities and organizations can no longer sit back and ask for a seat at the table. Instead, LTC leadership and facility staff need to demand to be part of that process. There are at least two paths for getting involved.
Healthcare coalitions. A healthcare coalition is a group of healthcare organizations in a specified geographic area that agree to work together to enhance their response to emergencies or disasters. The coalition’s response objectives will vary depending on how the coalition is constructed in a particular area. HCCs also vary when it comes to how they are set up, their financing and their geographical boundaries. The U.S. Department of Health & Human Services provides a listing of healthcare coalitions across the United States and U.S. territories.
The four core members of HCCs are hospitals, emergency management, emergency medical services and public health. Other healthcare providers are “encouraged” to participate in these coalitions. Long-term care facilities, specifically, should be actively involved in the planning and response work of these coalitions. Ultimately, hospitals need to be able to discharge to LTC facilities during surges, and LTC facilities need to be able to evacuate their patients to hospitals when they have nowhere else to go.
Long-term care mutual aid plans. A long-term care mutual aid plan establishes a course of action and an agreed commitment among participating long-term care facilities and organizations to assist each other in the event of a disaster. Other healthcare entities such as assisted living, ICF/ID homes, and hospitals may also be involved.
The foundation of these plans is that they are facilities helping like facilities, thus “mutual aid.” Plans usually include a core Memorandum of Understanding, which is a voluntary agreement that pre-establishes how the plan is activated, how facilities report bed availability, what equipment or vehicles may be shared, and most importantly, how facilities will get paid for receiving evacuated residents.
Many reports and lessons learned from emergency events like Hurricane Katrina and the COVID-19 pandemic have reinforced the importance of establishing relationships with other healthcare providers and suppliers to ensure mutual aid and resource-sharing during emergencies.
To that effect, many facilities across the United States have joined together to develop highly effective regional, statewide or countywide mutual aid plans. For example, Connecticut, Massachusetts and Rhode Island established statewide mutual aid plans that serve facilities across three states. Another stand-out example is the San Diego County Area LTC mutual aid plan.
Take proactive actions now
Long-term care facilities need to take proactive actions now to prioritize emergency preparedness and engage in collaborative emergency planning and response.
This could include joining a local healthcare coalition, starting a long-term care mutual aid plan in the area or joining other healthcare-focused planning and response groups (e.g., ESF-8’s, Public Health Groups) in your area. By acting now and implementing robust emergency preparedness measures, long-term care facilities can better protect the safety and well-being of their residents in the event of a disaster.
Nick Gabriele is the Global Service Line Leader for Health Care Emergency Management at Jensen Hughes, and retired Fire Chief from the State of Connecticut. With nearly 40 years’ experience in healthcare code compliance, fire protection and emergency management, Nick has led teams across North America and the globe to provide life safety and emergency management services to regional and state healthcare entities, including healthcare systems, hospitals, ambulatory surgery centers and long-term care. Nick is a Certified Fire Protection Specialist (CFPS) and currently chairs the NFPA 99 Technical Committee on Health Care Emergency Management and Security. He is also a Primary Member of the NFPA 101®: Life Safety Code® Board and Care Facilities Technical Committee.
The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.
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