Making the Case for Emergency Preparedness

What Is Emergency Preparedness?

Emergency Preparedness is the driving force behind disaster management. Also known as Emergency Management, it is an “all hazards” approach that’s dedicated to planning and training staff for the disasters of tomorrow. Because this is a continually changing process, hospitals need to remain aware of threats and issues in their regions so they can continually train for them. As part of America’s critical infrastructure, hospitals play a key role in the nation’s emergency preparedness and response. It’s vital they remain open to save lives and care for the seriously injured during times of emergency, and this level of preparedness takes practice. An “emergency” is defined as a sudden, unexpected incident that does or could do harm to people, environment, resources or property. Preparedness is the quality or state of being prepared.

Why You Need It

Some of you may be asking why you should take preparing for emergencies in my healthcare organization seriously. We have been operating all this time without any incidents or issues. It seems like a waste of time to me and my organization. We will do just what we have to do to get by with our accreditation survey because we don’t have time or money for this stuff.  But is it really a waste of time……?

The world we live in is so unpredictable that you can’t help but wonder what can I, my team, my organization do during an emergency. The occurrence and frequency of emergencies are on the rise, making the role of hospitals and their emergency departments increasingly important. These emergencies can damage or pose severe threats to hospitals within their reach. 

In 2013, the Centers for Medicare & Medicaid Services (CMS) acknowledged hospitals’ role in meeting their community’s emergency needs when it issued a proposed Emergency Management Rule on the Federal Register titled [CMS-3178-P] “Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers.” According to the rule, “Disasters can disrupt the environment of health care and change the demand for health care services. This makes it essential that health care providers and suppliers ensure that emergency management is integrated into their daily functions and values.” CMS published the final rule on September 16, 2016; it was effective November 15, 2016; and had to be implemented by November 15, 2017. 

If you take a look back through the last several years, you would find a long list of deadly disasters and costly outcomes that supports CMS’ position:

• In 2011 –
  • Joplin Regional Medical Center in Joplin, Missouri, sustained damages from a major tornado (EF-5) that killed 158 people, injured another 1,150 and caused $2.8 million in damages.
  • A class-action lawsuit filed after Memorial Medical Center’s lack of preparedness and response to Hurricane Katrina resulted in 45 deaths at the hospital was settled for $25 million.
  • The Federal Emergency Management Agency (FEMA) had 242 declarations -- the highest number since its inception in 1979.

     

• In 2012 –
  • 11 extreme weather incidents in the U.S. each resulted in more than $1 billion of damage and had a total death toll of 349, according to NOAA. Those incidents were: 7 severe thunderstorm outbreaks, 2 hurricanes, the drought and wildfires.
  • It was the second costliest year since 1980. Hurricane Sandy alone will cost about $100 billion.

     

• In 2013 –
  • The year’s costliest natural disaster was the EF-5 tornado in Moore, Oklahoma, which killed 24, injured 353 and cost nearly $3.8 billion in economic losses. It also heavily damaged Moore Medical Center.

     

• In 2014 –
  • The cost of America’s natural disasters reached $25 billion “with certain regions of the country more prone to calamity than others,” according to a New York Times report published August 5, 2015. It noted that, “Every year, the United States foots a multi-billion dollar bill for the economic and insured losses incurred from natural disasters.”

     

• In 2015 –
  • The year presented a myriad of emergency situations that included: record snowfall in Boston that piled up 110.6 inches; a measles outbreak that started at Disneyland California; riots in Baltimore that cost the city $20 million; an Amtrak derailment near Philadelphia that killed 8 and injured more than 200; a toxic river event in Silverton, Colorado, caused by mine waste that could cost the U.S. up to $50 billion to clean up; a wildfire in Washington state that burned more than 300,000 acres and cost more than $1 billion in federal funds to combat; a once-every-1,000-years flood in South Carolina that killed at least 19 and resulted in damages expected to exceed $1 billion; and the strongest hurricane to date in U.S. history -- Hurricane Patricia, a Category 5 storm with winds of 214 miles per hour.
  • U.S. experiences 355 mass shootings in 336 days, according to Danielle Brennan’s article on Today.com.

     

• In 2016 –
  • In June, the Pulse nightclub terrorist attack became the nation’s deadliest mass shooting at that point in time. The nightclub was less than half a mile from Orlando Health Orlando Regional Medical Center.
  • In October, Hurricane Matthew claimed more than 1,600 lives across the nation. Although Central Florida did not take a direct hit from the tropical system, it posed numerous financial and logistical issues for Orlando Health.

• In 2017 –
  • An unparalleled year that included terrorist attacks, active shooter incidents and major natural disasters resulting in deaths and injuries.
  • 25 million Americans, almost 8 percent of the U.S. population, were affected by disasters.
  • Hurricanes Harvey, Irma and Maria made this the second -costliest hurricane season since 2005.

    So the question is: How well could your organization stand up during and after a major emergency such as these? Will you still be there or will you be shut down? Think about how this will affect you, your family and your community. Now is the time to act. It is a matter of when not if something will happen in your community.

     

    Where Do I Even Begin To Understand Healthcare Emergency Preparedness/Management?

    There are many things you can do to get started. But the bottom line is don’t wait and don’t be afraid to get started. Don’t let naysayers fool you into fear. It can be done. Every effort you take does make a difference.

• You can read one of the many books that are out there on healthcare emergency preparedness.
• You can study your accreditation manual’s Emergency Management sections.
• You can attend one of the many classes that are available free of charge (Center for Domestic Preparedness is an outstanding source - https://cdp.dhs.gov/find-training/healthcare/course/AWR-900).
• You should take the NIMS (National Incident Management System) classes available by FEMA at https://training.fema.gov/is/crslist.aspx (IS-100, IS-200, IS-700, IS-800 series classes).There are 300 and 400 level courses that are also available by several entities.
• You can become certified as a healthcare emergency manager through several associations.
• You can talk to your peers in similar organizations, in your local healthcare coalition and your local Office of Emergency Management.
• You can reference the Department of Health and Human Services ASPR TRACIE website and materials (https://asprtracie.hhs.gov/).

   

  These are just some of the many options available to you. All can provide you and your organization with a baseline on preparedness. This baseline is a great starting point to building the Emergency Management program within your organization. The program isn’t merely a one-time obligation, but part of the journey toward being better prepared for the next major emergency/disaster. It takes consistent, dedicated efforts that act as building blocks; every step taken is another building block in constructing a program that enables your organization to better prepare, respond, recover and mitigate emergencies. 

   

  Are There Any Regulatory and Statutory Requirements For Emergency Preparedness/Management?

  Our hospital system is accredited by The Joint Commission, and its standards contain an entire chapter for Emergency Management (EM.01.01.01 – EM.03.01.03). This chapter lists several pages of requirements and includes 3 standards with direct impact. Failure to comply or meet direct impact standards could result in the hospital losing its license or Denial of Accreditation, which makes it ineligible for Medicare/Medicaid reimbursement funds. On June 25, 2013, The Joint Commission released new and revised elements of performance addressing leadership accountability for hospital emergency management, which took effect January 1, 2014. The Joint Commission determined that a clearer description of leadership-level oversight was necessary. 

   

  Our hospital system is required by Florida’s Agency for Health Care Administration (AHCA), pursuant to s. 395.1055, Florida Statutes, and Chapter 59A-3, Florida Administrative Code, to complete the Emergency Management Planning Criteria for Hospitals crosswalk. This consists of approximately 6 pages of requirements. In accordance with this crosswalk, the hospitals must submit annually for approval a Comprehensive Emergency Management Plan (CEMP) to their respective County Emergency Management Agency. AHCA could take punitive action(s), including fines against the facility(s), for any that do not comply. Although each state is different, it’s recommended that you contact your state department of health to learn the requirements for your organization.

   

  As a Level One Trauma Center, ORMC must adhere to the state’s DOH trauma center criteria, which includes a system evaluation in accordance with the 2009 Florida statute Chapter 395. Emergency Preparedness is part of this survey. Failure to comply and achieve the survey criteria would result in removal of the facility’s trauma center status. If your state agency does not have trauma criteria, look to the American College of Surgeons (ACS) verification process, which does include emergency preparedness efforts. Additionally, the American Burn Association (ABA) verification process also includes an Emergency Management section.

   

  If your organization has a rehabilitation institute or provides rehab services, it may be accredited by the Commission on Accreditation for Rehabilitation Facilities (CARF). There are emergency preparedness procedures and exercise requirements associated with CARF standards. Also, if your organization has a transplant capability, it may fall under the FACT accrediting body for transplant, which also has emergency/disaster components.

   

  The National Fire Protection Association has an entire chapter for healthcare facilities emergency management titled NFPA 99 2018, Health Care Facilities Code: Chapter 12, and it provides criteria for developing an emergency management program. In Florida, AHCA has adopted this chapter as part of its annual life safety re-licensure surveys of healthcare facilities, and we are held accountable to these criteria as well.

  How Do I Get Started?

  There are many steps that can and should be taken to get your program underway. They include:

• Gather a good understanding of your organization and the services it provides.
• Collaborate with internal and external representatives who are key stakeholders in preparedness, response, recovery and mitigation to and for your organization. Continue to network and build collaborative bridges with them.
• Assemble an internal team that will meet with external community partners (i.e. law enforcement, fire rescue, emergency management, health department, etc.) to conduct a hazard vulnerability analysis (HVA).
• Establish an emergency management council and charter; the council should meet on a frequent basis and provide input into the program.In each of the council meetings conduct a small mini scenario (drill if you will) with the team to ensure they always are thinking about how they will respond to emergencies.
• Establish Emergency Management policy and procedures (P&Ps) within the organization that are established and approved by subject matter experts and your already established council.Write a CEMP for the organization.
• Train to the P&Ps and CEMP, and conduct emergency preparedness exercise sequences on the top hazards identified in the HVA.
• Learn from the areas of improvement that are identified in exercises or real incident by completing a full after action report (AAR) / improvement plan (IP).
• Make improvements to the program based on the learnings from the AAR/IP.
• If and where possible, it is highly recommended that healthcare organizations hire a full-time, dedicated Emergency Management professional who will continually look for ways to improve preparedness.

In Closing

Although the regulatory and state requirements are extensive and can affect significantly your healthcare organization, implementing a successful emergency preparedness program is essential given the frequency of natural and man-made disasters in our modern world. The goal in Emergency Preparedness should be to far exceed any requirements so yours can be one of the predominant hospital systems not only in the state but the United States. Learn, grow, participate, develop, train, exercise and update.  In other words, keep striving for better and do more in hopes of providing better quality care to patients, their families and your employees not just during “blue sky” normal days but also during emergency situations.