The Centers for Medicare & Medicaid Services (CMS) has published the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers rule. Tipping the scales at 651 pages there is no doubt it is a federal document. I was thinking what would have happened if my mom gave me a rule 651 pages long….I would still be grounded.
In reading through the estimated hours predicted for various facilities to develop the required documents it makes me question what the intent of the rule really is. I have no doubt organizations will come up with written documentation to meet the rule so they are in compliance. I also have little doubt that the documents produced in many cases will not actually enhance preparedness in the community.
This chart outlines the FEMA recommended process to follow in developing a plan (also listed in the rule as a helpful reference). If we compare the chart with the anticipated body of planning work to accomplish to meet the new rule it does not really match up well.
On the other hand I would look at this as an opportunity to boil the 651 pages down to what is necessary and more importantly what makes sense in enhancing preparedness of an organization among the whole community. In my experience there is an inverse relationship between the thickness of an organization’s (state and federal government included) plans, policies and procedures and their ability to actually implement them. It is possible to over plan and that should be avoided. In the CMS rule they point out four core elements to focus on. They are:
- Risk Assessment and Emergency Planning
- Policies and Procedures
- Communication Plan
- Training and Testing
Over the years one of the most common reasons I heard why emergency preparedness programs were disliked in healthcare facilities is that the training and exercises were so disruptive of daily operations. No one objected to one poor soul writing a plan to make them “compliant”, but the issues started when the author actually tried to implement change and ensure competency. The reality is that a well designed preparedness program and sound understanding of the Hospital Incident Command System (HICS) can actually simplify life within your organization. Both on a day to day basis and when emergencies arise. My suggested keys to building a successful program are:
- Implementable Planning – Boiler-plate plans are going to be popping up and tempting many organizations to make them “CMS compliant” yet they are seldom a good fit for any facility. Many consulting firms love them because they are easy to develop and therefore profitable to sell. They may allow you to check the box necessary to meet a grant deliverable but they will most likely fail in a real event. Developing plans that actually work may take more up front effort but make your life much easier in managing the event. Keep in mind after an event you will be judged based on your plans, polices and procedures and training records. If you can’t actually accomplish something you’ve documented in your plan you are setting yourself up for misery and liability.
- Practical Training – I consider education to be a key factor in how people will perform under stress. Canned courses are like boiler-plate plans. Usually longer than they need to be and a good portion of the content is is irrelevant to your organization or performance expectations. I am often accused during my courses of making people think. It’s not rocket science stuff. I simply give them material which is relevant to their current situation, aligns with organizational expectations and is focused on need to know material.
- Realistic Exercising – Properly designed and facilitated, exercising is where we can evaluate the results of our planning and training components. Part of exercising is the evaluation component and developing a Plan of Improvement. These findings go into the next evolution of planning and training effort. Exercising without incorporating what we have learned is a waste of effort and resources. For additional information on ideas for a good exercise program click on the link.
While the intent of the ruling is to raise the bar of emergency preparedness in individual facilities, the final outcome should be a better prepared community. You may be able to find assistance from other members of the healthcare or emergency management organizations in your area. Regardless of the route you take to meet the ruling, internal work effort, other community partner agencies or a consultant, make sure your preparedness program passes this common sense test.
- If a predictable event(contained in your Hazard Vulnerability Analysis) occurs, does your staff understand their role in ensuring the safety of all staff, clients and visitors? This includes staff on campus as well as working at remote locations.
- Does your organization utilize the HICS to manage events and trained staff have demonstrated competency in its use? If efficiency in operations and effectiveness in outcomes is desired, spend time learning how to use the HICS and not just spell it out.
- Has your organization developed sufficient documentation (plans, polices, procedures, initial Incident Action Plans) for staff to understand how they will provide for the continuity of patient care in emergencies? This may require coordination with other community partners as necessary and appropriate.
- Is organizational leadership 100% engaged in the preparedness process?
I would love to hear from organizations and how they are intending to proceed in order to meet the intent of the rule.