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Health Medical >Joint Commission Critical Aspects

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Post One:

Pick 2 of the six Joint Commission’s six critical aspects of emergency response. Describe them and provide supporting documentation on why they are defined as critical by the Joint Commission.

Communication (EM.02.02.01)

In this aspect, we will be looking at two vital functions that will make the response succeed or fail. First, Interorganizational communication is the type of communication necessary to perform the plans set up by the organization’s leaders. In the case of a health care emergency management, the CEO and the emergency management team will write down their plans for emergency events, but to execute these plans and getting everyone involved and informed of their role in the response, communication means must be planned and made available at all times. Additionally, documenting all the information and updates that’ll come up when communicating is crucial to the viability of the response as well as to dodge any legal issues in the future. Moreover, transferring patients between hospitals during a crisis will require communication units to be well prepared in all the participating facilities, that’s why it is important to have a backup communication plan. Second, the communication unit in a health care facility must have a valid procedure on how to communicate to the public important messages during a calamity. Either through the Healthcare incident Command System or by disseminating information directly from the hospital staff. A useful suggestion would be to have a prewritten public service announcement ready to be broadcasted in times of disasters.

Utility Management (EM.02.02.09)

Keeping the facility’s systems up and running at all times is essential for all operation especially those that take place during a disaster. The communication aspect success depends on successful utilization of the institution’s resources. That’s why FEMA has provided a very comprehensive and detailed plan that must be rewritten and applied to every institution where people study or work etc., to keep your operation flowing and working smoothly, planning must take into consideration managing the utilities within the health care facility. A small problem like no electricity in one suite inside one of the hospitals building will disturb the whole hospital and might have an effect on operations throughout the whole hospital.

References:

Medford-Davis, L. N., & Kapur, G. B. (2014). Preparing for effective communications during disasters: lessons from a World Health Organization quality improvement project. International journal of emergency medicine, 7(1), 15.

Future of Emergency Care in the United States Health System Staff, Board on Health Care Services Staff, Institute of Medicine Staff, National Academy of Sciences, Board on Health Care Services, Committee on the Future of Emergency Care in the United States Health System, . . . Institute of Medicine. (2007). Hospital-based emergency care: At the breaking point. Washington, D.C: National Academies Press.

What is Continuity of Operations? Elements of a Viable … (n.d.). Retrieved from https://www.fema.gov/pdf/about/org/ncp/coop_brochu…

Post Two:

According to McNew (2018), it is essential to integrate the six critical aspects of emergency response into the phases of emergency management in healthcare, and these vital aspects include communication, utility management, safety and security, patient clinical and support activities, staff responsibilities and resources and assets. The element known as patient clinical and support activities refers to the hospital’s requirement to en

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sure that patient safety is maintained when an emergency or disaster strikes by ensuring that a plan is in place to track patients on the site. They need to ensure that patients’ needs are addressed during the emergency period, including during extreme conditions, and then creating plans to get them transferred and ensure that life is protected and preserved, and disability prevented. The next critical aspect to discuss is resources and assets.

Following the resources and assets aspect, they are required to ensure that provisions like food, sleeping materials and vendor and community services among others are available in order to take care of the patients. The two aspects discussed are considered critical because they provide a glimpse into the specific manner that hospitals are expected to manage emergency situations. Hospitals are then allowed to have a perspective on what to prioritize and how to navigate seemingly impossible situations in an adaptive way.

References

McNew. (2018). Emergency Department Compliance Manual, 2018 Edition. Alphen aan den Rijn, Netherlands: Wolters Kluwer Law & Business.

HIM445 Wk3 Ashford university Customer service and critical pathways

HIM445 Wk3 Ashford university Customer service and critical pathways

Critical Pathway

Using the Gantt chart and timeline developed in Week Three for your clinic, determine the critical pathway. What are the factors that contribute to the critical pathway? Identify tasks that could be done simultaneously and if so redo the Gantt chart in preparation for the Final Project. If you cannot identify any tasks that could be done simultaneously, explain why.

Part 1 Assignment

Customer Service

By Day 1 of Week One, your instructor will assign each student an option. Assume you are working on a project to improve customer service. Create a Pareto chart based on the information in the assigned option. Use the Pareto chart template (available in the online classroom) or use Excel to produce a Pareto chart that looks like the Pareto chart in Chapter 8 of the course textbook. Include three detailed actions to take to address the customer complaints.

Option 1:

Customer Complaint Frequency/Week
Customer is on hold too long 41
An appointment is not available within 48 hours 35
Wait time in the exam room exceeds 20 minutes 98
Co-pay amount is incorrectly calculated by staff 75

Option 2:

Customer Complaint Frequency/Week
Signage is difficult to follow within the facility 120
Hallway service is difficult to walk on between facility sections 89
Walls and baseboards are dented, scraped or otherwise marred 57
Soap and/or paper towels not available in bathroom 15

Option 3:

Customer Complaint Frequency/Week
Customer is on hold too long 95
Customer gets transferred to the wrong area or cut off 25
Service rep cannot answer customer’s question 125
Service rep does not follow through as promised 45

Option 4:

Customer Complaint Frequency/Week
Room temperature is too cold 70
Room temperature is too hot 45
Room is not clean 35
Sheets are stained/have holes 95

Part 2 of assignment

  • Includes the Pareto chart with title, X and Y-axis labels, and the line chart to show cumulative percentage. A sample Pareto chart you may use is available in the online classroom.
  • Includes three detailed actions to take to address the customer complaints and includes the rationale for the priority of the actions.

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  • Must be two double-spaced pages in length (not including title and references pages) and formatted according to APA style as outlined in the Ashford Writing Center (Links to an external site.)Links to an external site..
  • Must include a separate title page with the following:
    • Title of paper
    • Student’s name
    • Course name and number
    • Instructor’s name
    • Date submitted
  • Must document all sources in APA style as outlined in the Ashford Writing Center.
  • Must include a separate references page that is formatted according to APA style as outlined in the Ashford Writing Center.

Disaster Managing Efforts Discussion Board Question

Disaster Managing Efforts Discussion Board Question

Image source: www.ucdenver.edu Emergency Management Update Team 2016- 1 © Copyright, The Joint Commission Emergency Management Debrief Lessons Learned Planning & Leadership Emergency Program Emergency Management Update Team 2016- 2 © Copyright, The Joint Commission EMERGENCY MANAGEMENT CHAPTER OUTLINE  Foundation for the Emergency Operations Plan [EM.01.01.01]  The Emergency Operations Plan (EOP) General Requirements [EM.02.01.01]  Specific Requirements  Six Critical Areas [EM.02.02.01-EM.02.02.11]  Disaster Volunteers [EM.02.02.13-EM.02.02.15]  Evaluation Evaluating the planning activities [EM.03.01.01]  Evaluating the Emergency Operations Plan through exercises [EM.03.03.03]  Emergency Management Update Team 2016- 3 © Copyright, The Joint Commission  1. Communication [EM.02.02.01] 2. Resources & Assets [EM.02.02.03] 3. Safety & Security [EM.02.02.05] 4. Staff responsibilities [EM.02.02.07] 5. Utilities Management [EM.02.02.09] 6. Patient, clinical & support activities [EM.02.02.11] Emergency Management Update Team 2016- 4 © Copyright, The Joint Commission SIX CRITICAL AREAS 2016 Emergency Management Update Team The Joint Commission © Copyright, The Joint Commission WHAT HAS THE JOINT COMMISSION BEEN UP TO? EMERGENCY MANAGEMENT TEAM  Cross-divisional team  Review of large-scale events  Improvement  Field and surveyor education  Survey process and standards Emergency Management Update Team 2016- 6 © Copyright, The Joint Commission  Debriefs  Lessons learned  Education and process improvement DEBRIEFS WITH HEALTH CARE ORGANIZATIONS  Hurricane Sandy  West Texas Fertilizer Explosion  West Virginia Water Contamination  Boston Marathon Bombing  Ebola Outbreak  Baltimore Civil Unrest  San Bernardino Terrorist Event  Ferguson Civil Unrest Emergency Management Update Team 2016- 7 © Copyright, The Joint Commission  South Carolina Flooding LESSONS LEARNED – PLANNING/PREPAREDNESS  Establish relationships w/law enforcement & back-up security agencies  Joint education, drills, etc.  Activate ICS early in incident to support situational awareness  Plan / drill for escalating events  Mass shooting plus bomb threat. Emergency Management Update Team 2016- 8 © Copyright, The Joint Commission  Communication. LESSONS LEARNED – PLANNING/PREPAREDNESS  Identify & reach out to staff living in hot  e.g., laundry service  Know actual usage of utilities on ‘normal’ day, in evening, on weekends. Emergency Management Update Team 2016- 9 © Copyright, The Joint Commission zones during unrest to identify support needs in advance.  Consider supply chain and alternate service providers during water contamination. LESSONS LEARNED – PLANNING/PREPAREDNESS  Plan for most emerging infectious diseases rather than new ‘outbreak of the week’ plan.  IC plan, surge plan, all hazards plan, decon plan, pan-flu plan  Don’t overlook common risks that could go on the HVA in community or region  CBRNE: Fertilizer storage facilities throughout the region that could pose risk of combustion/explosion. Emergency Management Update Team 2016- 10 © Copyright, The Joint Commission  Risks LESSONS LEARNED – PLANNING/PREPAREDNESS  Planning for civil unrest focused primarily on:  Communications (with staff, patients, community incident command, the public/media)  Security  Transit (to the facility for patients and staff) Emergency Management Update Team 2016- 11 © Copyright, The Joint Commission  Reviewing EOP annually  Policies addressing utility disruption, including approach to clinical interventions  Water LESSONS LEARNED – PLANNING/PREPAREDNESS  Don’t overlook home care, outpatient services and other ancillary providers home care providers were held back from entering certain communities where there were clients with chronic conditions – care arrangements can be addressed proactively. Emergency Management Update Team 2016- 12 © Copyright, The Joint Commission  During unrest LESSONS LEARNED – GENERAL RESPONSE hospital & campus to identify flood issues early.  Divert spontaneous volunteers (even clinical) from ED to avoid congestion during trauma response.  Community-based & mobile services (e.g., addiction services) need to choose their locations during unrest to preserve safety of staff/patients. Emergency Management Update Team 2016- 13 © Copyright, The Joint Commission  Conduct frequent tours (every 2 hours) of LESSONS LEARNED – COMMUNICATIONS command/control, staff, patients/families, media & the public.  Don’t presume that all staff have smart phones or use social media; use redundant methods of staff communication.  Manage staff stress and access to misinformation via proactive staff communication strategy. Emergency Management Update Team 2016- 14 © Copyright, The Joint Commission  Have separate lines of communication for LESSONS LEARNED – COMMUNICATIONS with cell phone during response and recovery.  Proactive media/social media outreach plan mitigates intrusions from reporters that consume leaders’ time during response.  Regular joint calls with local providers, city & state support situational awareness during unrest. Emergency Management Update Team 2016- 15 © Copyright, The Joint Commission  Carry extra batteries and/or chargers along  During unrest:  Monitor social media used/sponsored by protest groups to anticipate crowd movement and potential impact on transit or emergency/urgent care.  Reinforce with staff – verbally and in written messaging/scripts used as needed in patient/family interactions – values of diversity and role to care for all people to help mitigate safety concerns or racial tension impacting community. Emergency Management Update Team 2016- 16 © Copyright, The Joint Commission LESSONS LEARNED – COMMUNICATIONS LESSONS LEARNED – SECURITY  Definition of ‘lock-down’ with response partners  Security forces have one meaning, hospitals may vary  Civil unrest response from small community hospital & secured it’s perimeter – closed all off-site locations  Security to central site  Moved vehicles  Removed from public access items that could be removed/damaged Emergency Management Update Team 2016- 17 © Copyright, The Joint Commission  Reduced LESSONS LEARNED – SECURITY  Reinforced with staff use of de-escalation techniques during civil unrest.  Train/exercise with local law enforcement  During terrorist shooting over 40 officers were onsite in minutes Conducted bomb search and provided essential support. No need to arm hospital security.  Separate ED waiting area for injured police officers & their families during unrest Emergency Management Update Team 2016- 18 © Copyright, The Joint Commission  LESSONS LEARNED – STAFF  Senior leadership  Prioritize time and resources for staff training Emergency Management Update Team 2016- 19 © Copyright, The Joint Commission  Weather/natural disasters  Prepare for staff rotations & shift relief  Designated sleeping areas, adequate meals  Shuttle system to/from homes LESSONS LEARNED – STAFF  Monitor local/county/state agencies  Road closures, curfews, etc. that impact staff movement to & from work community conditions change  Place Critical Incident Stress management staff in EOC  Provide real-time support & guidance to chain of command during unrest Emergency Management Update Team 2016- 20 © Copyright, The Joint Commission  Adjust shifts, allow sheltering in place as LESSONS LEARNED – PATIENT CARE  Flooding  Review IC plan to assess patient risk for HAI. Emergency Management Update Team 2016- 21 © Copyright, The Joint Commission  Water contamination  Home health & DME partners proactively monitor at-risk patients  Facilitate patient education on O2 concentrators, CPAP machines, & water sourcing. LESSONS LEARNED – EXERCISES  Stress & test system, staff, leaders with escalating complications & patients with different functional needs.  Train & practice staff in active shooter response with in-house security & law enforcement. Emergency Management Update Team 2016- 22 © Copyright, The Joint Commission  Joint exercise LESSONS LEARNED – LEADERSHIP  Leaders met frequent w/staff to discuss quality of care and safety during flood response/recovery.  Leaders facilitated visible presence of security in and around building during unrest  Increased sense of security. managerial assistance; identified & addressed staff morale/support needs in process after terrorist attack. Emergency Management Update Team 2016- 23 © Copyright, The Joint Commission  Leaders rounded & provided hands-on LESSONS LEARNED – PSYCHOSOCIAL SUPPORT/COPING  Reinforced w/staff & community role of hospital as safe zone for all injured. Emergency Management Update Team 2016- 24 © Copyright, The Joint Commission  Civil unrest/recovery  Town hall meetings for information & support and to dispel myths/rumors  Made available EAP & pastoral care  Routed routine monthly prayer walk through vulnerable community.  During unrest response & recovery  Invited staff discussion (individual or small group) on racial tension  Sense of safety at home in impacted community  Need for safety tips or security/transit support (alter work hours, shelter at hospital, etc.). Emergency Management Update Team 2016- 25 © Copyright, The Joint Commission LESSONS LEARNED – PSYCHOSOCIAL SUPPORT/COPING LESSONS LEARNED – INFECTIOUS DISEASE  Plan, train, & exercise for infectious disease emergencies:  initial screening of PPE, including don and dof  safe patient flow (entry point to isolation)  iterative training of care teams  dedicated equipment  safe transfer of patients  disposal & transport of waste Emergency Management Update Team 2016- 26 © Copyright, The Joint Commission  use LESSONS LEARNED – UTILITIES  Water  Processes for cleaning water systems after loss of water  Supply for systems management  Potable vs. non-potable • Equipment use, i.e. sterile processing • Human consumption Emergency Management Update Team 2016- 27 © Copyright, The Joint Commission  Fuel  Increase run time through load-shedding LESSONS LEARNED – HEALTH CARE PARTNERS  Water contamination:  Ambulatory dialysis company deployed water tanker truck to supply hospital  Dialysis biochemist supported hospital in sampling & testing water Emergency Management Update Team 2016- 28 © Copyright, The Joint Commission  Nursing home destroyed in industrial blast:  Other homes contacted hospital to offer beds  Hospital worked with case manager, behavioral health staff and home care to place patients 2 weeks post-disaster LESSONS LEARNED – HEALTH CARE PARTNERS  Maintain access to care  Chronic care patients  Medications from pharmacies outside of impacted area of emergency • Civil unrest, weather emergencies, etc. Emergency Management Update Team 2016- 29 © Copyright, The Joint Commission  Reinforce IC preparedness  Affiliated clinics and physician offices where at-risk patients may be seen.  Screening, use of PPE and other precautions LESSONS LEARNED – EVACUATION  Practice evacuation drills using evacuation equipment: equipment is required?  Where will equipment be deployed (which units, floors, etc.)?  Who needs to be trained in its use? Emergency Management Update Team 2016- 30 © Copyright, The Joint Commission  How much LESSONS LEARNED – RECOVERY  Recovery  Ancillary / offsite / support departments that were impacted by event or that contribute to resiliency.  Business continuity  Timely engagement with FEMA and insurers Emergency Management Update Team 2016- 31 © Copyright, The Joint Commission  Leadership engagement  Avoid fatigue and silos  Accountability Link: http://www.jointcommission.org/emergency_management.aspx Emergency Management Update Team 2016- 32 © Copyright, The Joint Commission EMERGENCY MANAGEMENT PORTAL 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page i HEALTH CARE EMERGENCY MANAGEMENT PRINCIPLES AND PRACTICE Editors Michael J. Reilly, DrPH, MPH, NREMT-P Director, Graduate Program in Emergency Preparedness Assistant Director, Center for Disaster Medicine Assistant Professor, Public Health Practice New York Medical College School of Health Science and Practice Valhalla, New York and David Markenson, MD, FAAP, FACEP, EMT-P Medical Director and Vice President Disaster Medicine and Regional Emergency Services Westchester Medical Center Director, Center for Disaster Medicine Associate Professor, Public Health Practice Professor of Pediatrics New York Medical College Valhalla, New York 55133_FMxx_Reilly:Achorn Int’l World Headquarters Jones & Bartlett Learning 40 Tall Pine Drive Sudbury, MA 01776 978-443-5000 info@jblearning.com www.jblearning.com 5/21/10 1:36 AM Page ii Jones & Bartlett Learning Canada 6339 Ormindale Way Mississauga, Ontario L5V 1J2 Canada Jones & Bartlett Learning International Barb House, Barb Mews London W6 7PA United Kingdom Jones & Bartlett Learning books and products are available through most bookstores and online booksellers. To contact Jones & Bartlett Learning directly, call 800-832-0034, fax 978-443-8000, or visit our website, www.jblearning.com. Substantial discounts on bulk quantities of Jones & Bartlett Learning publications are available to corporations, professional associations, and other qualified organizations. For details and specific discount information, contact the special sales department at Jones & Bartlett Learning via the above contact information or send an email to specialsales@jblearning.com. Copyright © 2011 by Jones & Bartlett Learning, LLC All rights reserved. No part of the material protected by this copyright may be reproduced or utilized in any form, electronic or mechanical, including photocopying, recording, or by any information storage and retrieval system, without written permission from the copyright owner. This publication is designed to provide accurate and authoritative information in regard to the Subject Matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the service of a competent professional person should be sought. Production Credits Publisher: Michael Brown Editorial Assistant: Catie Heverling Editorial Assistant: Teresa Reilly Production Manager: Tracey Chapman Associate Production Editor: Kate Stein Senior Marketing Manager: Sophie Fleck Manufacturing and Inventory Control Supervisor: Amy Bacus Composition: Achorn International Art: diacriTech Associate Photo Researcher: Sarah Cebulski Cover Design: Kristin E. Parker Cover Image: Top left: Courtesy of Andrea Booher/FEMA; Top Right: Courtesy of Win Henderson/FEMA; Bottom left: Courtesy of Jocelyn Augustino/FEMA; Bottom right: Courtesy of Cynthia Hunter/FEMA Printing and Binding: Malloy, Inc. Cover Printing: John Pow Company Library of Congress Cataloging-in-Publication Data Health care emergency management : principles and practice / [edited by] Michael J. Reilly and David S. Markenson. p. ; cm. Includes bibliographical references and index. ISBN-13: 978-0-7637-5513-3 (pbk.) ISBN-10: 0-7637-5513-3 (pbk.) 1. Emergency medical services. 2. Emergency management—Planning. 3. Hospitals—Emergency services. I. Reilly, Michael J. II. Markenson, David S. [DNLM: 1. Disaster Planning—organization & administration. 2. Emergencies. 3. Emergency Service, Hospital—organization & administration. WX 185 H4336 2011] RA645.5.H38 2011 362.18068—dc22 2010001554 6048 Printed in the United States of America 14 13 12 11 10 10 9 8 7 6 5 4 3 2 1 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page iii Dedication MICHAEL REILLY I dedicate this text to my family and friends who have supported me throughout this project. I especially thank my parents, who have provided their unwavering advice and support throughout my life and career. I also dedicate this text to my professional mentors Dr. Linda Degutis and Dr. Robyn Gershon, who continue to give me invaluable guidance throughout my professional development. Finally, I dedicate this book to my coauthor David, who has provided me with the opportunity to pursue academic emergency and disaster medicine professionally, and who continues to encourage and support my development as a scientist and scholar in this evolving area of medicine and public health. DAVID MARKENSON This text is dedicated to my parents, who have always guided, supported, and encouraged me, and who, as physicians, have shown me through their work that providing care to others in a compassionate and knowledgeable way can be a rewarding endeavor. This text is also dedicated to my brothers, sister, and sisters-in-law, who are a constant source of advice, support, and energy; without their help and involvement in my life none of my efforts could have been accomplished. Most importantly this text is dedicated to my wife Heidi and my wonderful children, Emily, Rachel, and George, who not only support me but who were willing to give of their time with me to allow me to write this text. iii 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page iv iv | Dedication MICHAEL REILLY AND DAVID MARKENSON Lastly, this text is dedicated to all healthcare providers, emergency managers, and those in their care. Healthcare providers and emergency managers work each day in an environment that is unpredictable, often dangerous, and constantly challenging. They have become champions in changing the system to become better prepared. They dedicate their lives to aid the sick and the injured and prepare for any disaster, terrorism event, or public health emergency, driven only by their care for others and their devotion to this profession we call healthcare emergency management. We salute all of you in your professionalism and dedication. Also, we dedicate this to our patients who, in allowing us the privilege to provide them care, teach us each day about humanity. 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page v Contents About the Authors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix Contributors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xix Section I Chapter 1 Chapter 2 Principles of Emergency Management for Healthcare Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Introduction to Hospital and Healthcare Emergency Management. . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Michael J. Reilly, DrPH, MPH, NREMT-P and David S. Markenson, MD, FAAP, FACEP, EMT-P Healthcare Incident Management Systems . . . . . . . . . . . . . 21 Arthur Cooper, MD, MS v 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page vi vi | Contents Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 II Chapter 8 Section Chapter Chapter 9 10 Section III Chapter 11 Chapter 12 Improving Trauma System Preparedness for Disasters and Public Health Emergencies . . . . . . . . . . . . . . . . . . . . . 47 Michael J. Reilly, DrPH, MPH, NREMT-P Legal Issues and Regulatory Compliance . . . . . . . . . . . . . 67 Doris R. Varlese, JD Developing the Hospital Emergency Management Plan . . . 89 Nicholas V. Cagliuso, Sr., MPH; Nicole E. Leahy, RN, MPH; and Marcelo Sandoval, MD Introduction to Exercise Design and Evaluation . . . . . . . . 111 Garrett T. Doering, MS, EMT-P, CEM, MEP Integration with Local and Community Resources . . . . . . 143 Isaac B. Weisfuse, MD, MPH Hospital Workforce Issues . . . . . . . . . . . . . . . . . . . . . . . . 161 Education and Training . . . . . . . . . . . . . . . . . . . . . . . . . . 163 Sean M. Kelly, MA, CCEMT-P and Lindsey P. Anthony, MPA, CEM, CHEC-III Functional Roles of Hospital Workers in Disasters and Public Health Emergencies . . . . . . . . . . . . . . . . . . . . 187 Tony Garcia, RN, CCEMT-P Credentialing and Management of Volunteer Health Professionals . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205 Deborah Viola, PhD, MBA and Peter Arno, PhD Hospital Operations During Disasters and Public Health Emergencies . . . . . . . . . . . . . . . . . . . . . . . 221 Quantitative Planning for Epidemic and Disaster Response: Logistics and Supply Chain Considerations . . . . . . . . . . . 223 Nathaniel Hupert, MD, MPH; John A. Muckstadt, PhD; and Wei Xiong, PhD, MS Risk Communication and Media Relations . . . . . . . . . . . . 233 Linda C. Degutis, DrPH, MSN and Lauren Babcock-Dunning, MPH 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page vii Contents | vii Chapter 13 Chapter 14 Chapter 15 Chapter 16 IV C h a p t e r 17 Section Chapter 18 V C h a p t e r 19 Section Chapter 20 Chapter 21 Chapter 22 Security and Physical Infrastructure Protections. . . . . . . . . 271 Robert Michael Schuler, BGS, NREMT-P and Veronica Senchak Snyder, MHS, MBA Hospital Decontamination and Worker Safety . . . . . . . . . . 299 Michael J. Reilly, DrPH, MPH, NREMT-P Pharmaceutical Systems Management in Disasters. . . . . . 317 David S. Markenson, MD, FAAP, FACEP, EMT-P Laboratory Preparedness. . . . . . . . . . . . . . . . . . . . . . . . . 331 Ramon Rosal, PhD Clinical Considerations. . . . . . . . . . . . . . . . . . . . . . . . . . . 339 Principles of Disaster Triage . . . . . . . . . . . . . . . . . . . . . . . 341 E. Brooke Lerner, PhD and Richard B. Schwartz, MD Managing an Infectious Disease Disaster: A Guide for Hospital Administrators . . . . . . . . . . . . . . . . . 353 Ariadne Avellino, MD, MPH Special Topics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 369 Vulnerable Populations and Public Health Disaster Preparedness. . . . . . . . . . . . . . . . . . . . . . . . . . . 371 Elizabeth A. Davis, JD, EdM; Rebecca Hansen, MSW; and Jennifer Mincin, PhD (ABD) Altered Standards of Care in Disasters and Public Health Emergencies . . . . . . . . . . . . . . . . . . . . . . . 401 John Rinard, BBA, MSCPI Mass Fatality Management . . . . . . . . . . . . . . . . . . . . . . . 423 Barbara A. Butcher, MPH and Frank DePaolo, RPA-C Research in Emergency and Disaster Medicine . . . . . . . . 447 Kobi Peleg, PhD, MPH and Michael Rozenfeld, MA Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .463 Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .469 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page viii 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page ix About the Authors MICHAEL J. REILLY, DRPH, MPH, NREMT-P Dr. Michael Reilly is currently the Assistant Director of the Center for Disaster Medicine at New York Medical College in Valhalla, New York. Additionally, he is an Assistant Professor of Public Health Practice and the Director of the Graduate Program in Emergency Preparedness at the School of Health Science and Practice. Dr. Reilly has over a decade of multidisciplinary experience in emergency preparedness, public safety, intergovernmental relations, public health, and emergency management. He has been published in the world’s leading disaster medicine and public health preparedness journals, and received international awards and recognition for his work on trauma systems and health systems in the context of disaster and public health preparedness. Dr. Reilly is an internationally recognized expert in the areas of emergency medical services, and health system preparedness and response, with direct experience in responding ix 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page x x | About the Authors to mass casualty events and public health emergencies. Dr. Reilly is frequently called upon to provide expert consultation, subject matter expertise, and to evaluate healthcare systems preparedness, emergency planning, and drills and exercises. Dr. Reilly has designed numerous educational curricula and training programs for a variety of preparedness functional roles for public health, emergency management, and public safety audiences at the professional and graduate levels. He is a senior lecturer for multiple federal agencies including the Department of Justice, Department of Homeland Security, and the Occupational Safety and Health Administration. Additionally, he is an active member of several state and national committees on homeland security and emergency management programs. He received his undergraduate education at Northeastern University in paramedic technology and health science. He earned his Masters of Public Health from Yale University, and a doctorate in public health from New York Medical College. Dr. Reilly remains active as a paramedic in the Metro New York City region and maintains numerous specialty and technical certifications and instructor credentials in the areas of emergency medical services, worker safety, environmental health, hazardous materials emergency response, emergency management, counterterrorism, and weapons of mass destruction preparedness and response. DAVID SAMUEL MARKENSON, MD, FAAP, FACEP, EMT-P Dr. David Markenson is a board-certified pediatrician with Fellowship training in both pediatric emergency medicine and pediatric critical care. He is the Vice President and Medical Director of Disaster Medicine and Regional Emergency Services at the Westchester Medical Center and Maria Fareri Children’s Hospital. In addition, he is the Director of the Center for Disaster Medicine and the Interim Chair of Epidemiology and Community Health at the School of Health Sciences and Practice at New York Medical College. Dr. Markenson is also a Professor of Pediatrics and an Associate Professor of Public Health at the School of Health Sciences and Practice at New York Medical College in Valhalla, New York. He is an active member of, and has served in leadership positions within, multiple professional societies, including the American Academy of Pediatrics (AAP), the American College of Emergency Physicians, the Society of Critical Care Medicine, the American College of Physician Executives, and the National Association of EMS Physicians. Dr. Markenson has been actively involved with the American Red Cross for over 20 years and currently serves as the National Chair of the Advisory Council which oversees disaster health, preparedness, and health and safety. In this role he directs the scientific and technical as- 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xi About the Authors | xi pects of all programs and products in these areas including their development, implementation, and research. Prior to coming to Westchester Medical Center and New York Medical College he was the Deputy Director of the National Center for Disaster Preparedness at the Mailman School of Public Health, Columbia University, and was also the Director of the Program for Pediatric Preparedness of the National Center, a program dedicated to improving the care children receive in times of disasters or acts of terrorism. His career has been dedicated to improving the approach to pediatric care, disaster medicine, EMS, and emergency medicine. He is the principal investigator on several federal grants related to pediatric disaster medicine, including Model Pediatric Component for State Disaster Plans and National Consensus Conference on the Needs of Children in Disasters. He has also addressed the needs of other special and vulnerable populations and directed a federal grant to develop the first and only national guidelines for emergency preparedness for persons with disabilities. In addition to this, he has conducted research on healthcare preparedness and healthcare provider and student education. In this area he was the principal investigator for a federal grant which developed the first competencies for all healthcare students in emergency preparedness and then piloted this set of competencies in a medical, dental, public health, and nursing school. Dr. Markenson has been recently appointed to the FEMA National Advisory Council as the In-Patient Medical Provider representative. The FEMA NAC is comprised of emergency management and law enforcement leaders from state, local, and tribal government and the private sector to advise the FEMA Administrator on all aspects of disaster preparedness and management to ensure close coordination with all partners across the country. He is a frequent presenter and lecturer at medical conferences across the country, serves in editorial roles for multiple professional scientific journals, and has authored numerous articles and books on pediatric care, disaster medicine, and prehospital medicine. His work in disaster medicine started during his college career when he worked in disaster services in upstate New York providing direct services and education to other disaster services workers on behalf of the local Red Cross and county office of emergency management. Dr. Markenson is a graduate of Albert Einstein College of Medicine in the Bronx, New York. 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xii 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xiii Contributors Lindsey P. Anthony, MPA, CEM, CHEC-III Operational Medicine Education Coordinator Center for Operational Medicine Medical College of Georgia Augusta, Georgia Peter Arno, PhD Professor Department of Health Policy and Management New York Medical College School of Health Sciences and Practice Valhalla, New York xiii 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xiv xiv | Contributors Ariadne Avellino, MD, MPH Research Associate Center for Disaster Medicine New York Medical College Valhalla, New York Lauren Babcock-Dunning, MPH Research Associate Center for Transportation Safety, Security and Risk Rutgers, The State University of New Jersey New Brunswick, New Jersey Barbara A. Butcher, MPH Chief of Staff Office of the Chief Medical Examiner City of New York New York, New York Nicholas V. Cagliuso, Sr., MPH Corporate Director Emergency Management Continuum Health Partners, Inc. New York, New York Arthur Cooper, MD, MS Professor of Surgery Columbia University College of Physicians & Surgeons Director of Trauma and Pediatric Surgical Services Harlem Hospital New York, New York Elizabeth A. Davis, JD, EdM Principal EAD & Associates, LLC Brooklyn, New York Linda C. Degutis, DrPH, MSN Associate Professor of Surgery (Emergency Medicine) and Public Health Director, Center for Public Health Preparedness Yale University School of Medicine New Haven, Connecticut 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xv Contributors | xv Frank DePaolo, RPA-C Director Special Operations Division Office of the Chief Medical Examiner City of New York New York, New York Garrett T. Doering, MS, EMT-P, CEM, MEP Director of Emergency Management Westchester Medical Center Valhalla, New York Tony Garcia, RN, CCEMT-P Training Specialist Texas Engineering Extension Service Texas A&M University System College Station, Texas Rebecca Hansen, MSW Senior Project Manager EAD & Associates, LLC Brooklyn, New York Nathaniel Hupert, MD, MPH Associate Professor of Public Health and Medicine Weill Cornell Medical College New York, New York Sean M. Kelly, MA, CCEMT-P Lecturer New York Medical College School of Health Sciences and Practice Valhalla, New York Nicole E. Leahy, RN, MPH Manager Burn Outreach and Professional Education New York-Presbyterian Hospital / Weill Cornell Medical Center New York, New York 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xvi xvi | Contributors E. Brooke Learner, PhD Associate Professor Department of Emergency Medicine Department of Population Health Medical College of Wisconsin Milwaukee, Wisconsin David S. Markenson, MD, FAAP, FACEP, EMT-P Medical Director and Vice President Disaster Medicine and Regional Emergency Services Westchester Medical Center Director, Center for Disaster Medicine Associate Professor, Public Health Practice Professor of Pediatrics New York Medical College Valhalla, New York Jennifer Mincin, PhD (ABD) Senior Project Manager/Director EAD & Associates, LLC Brooklyn, New York John A. Muckstadt, PhD Acheson/Laibe Professor Business Management and Leadership Studies School of Operations Research and Industrial Engineering Cornell University Ithaca, New York Kobi Peleg, PhD, MPH Director, Israel National Center for Trauma and Emergency Medicine Gertner Institute for Epidemiology and Health Policy Research Sheba Medical Center Co-chair, The Multi-disciplinary Program for Emergency and Disaster Management School of Public Health Tel-Aviv University Tel-Aviv, Israel Michael J. Reilly, DrPH, MPH, NREMT-P Director, Graduate Program in Emergency Preparedness Assistant Director, Center for Disaster Medicine Assistant Professor of Public Health Practice New York Medical College School of Health Sciences and Practice Valhalla, New York 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xvii Contributors | xvii John Rinard, BBA, MSCPI Milano, Texas Ramon Rosal, PhD Chemical Response Director Public Health Laboratory New York City Department of Health and Mental Hygiene New York, New York Michael Rozenfeld, MA Researcher National Center for Trauma & Emergency Medicine Research Gertner Institute for Epidemiology and Health Policy Research Sheba Medical Center Tel Hashomer, Israel Marcelo Sandoval, MD Faculty, Department of Emergency Medicine Co-Chair, Emergency Management Committee Beth Israel Medical Center / Petrie Division New York, New York Robert Michael Schuler, BGS, NREMT-P Training Coordinator Texas Engineering Extension Service The Texas A&M University System College Station, Texas Richard B. Schwartz, MD Chair and Professor Department of Emergency Medicine Medical College of Georgia Augusta, Georgia Veronica Senchak Snyder, MHS, MBA Emergency Management Coordinator Emergency Management Services Geisinger Health System Geisinger Medical Center Danville, Pennsylvania Doris R. Varlese, JD Visiting Lecturer New York Medical College School of Health Sciences and Practice Valhalla, New York 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xviii xviii | Contributors Deborah Viola, PhD, MBA Associate Professor of Public Health Practice Department of Health Policy and Management New York Medical College School of Health Sciences and Practice Valhalla, New York Isaac B. Weisfuse, MD, MPH Deputy Commissioner Division of Disease Control New York City Department of Health and Mental Hygiene New York, New York Wei Xiong, PhD, MS Instructor in Public Health Weill Cornell Medical College New York, New York 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xix Acknowledgments he material contained in this text reflects the contributions of many authors, editors, emergency managers, healthcare providers, reviewers, and others who provided assistance and valuable suggestions. While here we acknowledge them, our sincere appreciation for all of their efforts is truly hard to express in this limited space. In addition, we could not possibly acknowledge all those who participated in this important endeavor, and so we would like to also extend our sincere appreciation to every person who helped with this project, whether listed by name or not. Many talented people at Jones & Bartlett Learning have been involved in developing and producing this new text. As authors and editors, we turned our manuscript to the exceptional editorial staff and publishers at Jones & Bartlett Learning to create this finished product. We are fortunate to have been able to work with this team of people, who have contributed so much and had such a tremendous impact on T xix 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xx xx | Acknowledgments the quality of the textbook you now have in your hands. Specifically Michael Brown, Publisher, assisted by Catie Heverling and Kate Stein, has been our support at Jones & Bartlett Learning. As Publisher, Mike is committed to publishing quality books; his energy, intelligence, patience, and helpful efforts have enabled us to create an exceptional product. With the additional day-to-day support and guidance of both Catie Heverling and Kate Stein we were able to keep our project on track and ultimately produce this important text. A significant amount of coordinating and operational support in moving this project forward would not have been possible without the tireless work of our administrative assistant Patience Ameyaw. We thank her for her hard work and support of this project along with Geordana Roa, Nina Luppino, and our numerous disaster medicine interns over the past several years. Components of this text have been based on the exceptional work of the Center for Disaster Medicine at the New York Medical College, School of Health Sciences and Practice for which we serve as the Director and Assistant Director. Without the support of our Center, the prior research and models developed, and the strong and supportive academic environment of New York Medical College, this work would not have been possible. We would like to specifically thank Dean Robert Amler of the New York Medical College, School of Health Sciences and Practice, who in his own right is an internationally recognized expert in public health and healthcare preparedness, for providing his personal expertise and his leadership in creating an academic environment where work such as this text is not only encouraged but supported, and for his continued dedication to providing education to improve emergency preparedness. We would like to also acknowledge the Westchester Medical Center and its Maria Fareri Children’s Hospital, which serves as the regional center for healthcare emergency preparedness. The source and realworld testing of many of the theories and models in this text come from the preparedness efforts of this institution, which is recognized as not only a regional but as a national leader in emergency preparedness. We would like to thank the leadership of this institution for allowing us to use the wonderful preparedness work they have done as models for others to follow. While not being able to list all, we would like to acknowledge the members of the senior leadership who day in and day out support the preparedness activities: Mr. Michael Israel, Mr. Gary Brudnicki, Dr. Renee Garrick, Dr. Michael Gewitz, Ms. Marsha Casey, and Mr. Anthony Costello. Lastly, we would especially like to thank the institution’s Director of Emergency Management and chapter contributor Mr. Garrett Doering for sharing his professional insight and experience with us as we completed this project. 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xxi Acknowledgments | xxi Finally, we are extremely grateful to the numerous healthcare providers, emergency managers, educational consultants, and members of the preparedness academic community who carefully critiqued the manuscript to ensure that the information in this text would be both relevant and appropriate. Many more dedicated professionals than we could name here gave unstintingly of their own time and expertise. Their enthusiastic participation has been a motivating force behind this project, and they received no compensation beyond the knowledge that they were helping to create a greatly needed resource. We hope the final product lives up to their efforts, hopes, and expectations. Our warmest and kindest regards, Michael and David 55133_FMxx_Reilly:Achorn Int’l 5/21/10 1:36 AM Page xxii 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 1 Section I Principles of Emergency Management for Healthcare Facilities 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 2 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 3 Chapter 1 Introduction to Hospital and Healthcare Emergency Management Michael J. Reilly, DrPH, MPH, NREMT-P and David S. Markenson, MD, FAAP, FACEP, EMT-P Photo by Jocelyn Augustino/FEMA News Photo Learning Objectives ■ Describe the need for and responsibilities of healthcare emergency management. ■ Describe the role of the hospital emergency manager. ■ Identify the activities performed by healthcare emergency management. Emergence and Growth of Healthcare Emergency Management The concept of healthcare emergency management is not entirely new, but may seem strange and foreign to those who have worked in healthcare or emergency management and, until recently, have not known anyone working in this profession. If one looks back more than 30 years, it would be almost impossible to find a hospital role called hospital 3 55133_CH01_Reilly:Achorn Int’l 4 | Chapter 1 5/13/10 12:08 PM Page 4 Introduction to Hospital and Healthcare Emergency Management emergency management or even a position for a healthcare emergency manager in a hospital or medical center.Yet healthcare emergency management responsibilities have always been addressed by hospitals, such as fire safety, backup power, and the ability to handle victims from a mass casualty event. A fundamental tenet of emergency management is that institutions must prepare for events that may rarely occur while taking protective actions to mitigate any likelihood that they will occur at all. Due to the low frequency of events testing the health system’s ability to respond to a disaster, an act of terrorism, or a public health emergency, the ability to evaluate the strengths and weaknesses of hospital emergency preparedness is limited. In addition, the public has strong expectations of the roles hospitals should play during times of disaster. Healthcare institutions are expected to provide both emergency care and continuance of the day-to-day healthcare responsibilities regardless of the volume and demand. Recently, they have also become sites of community refuge, bastions of safety in a threatening and dangerous environment. The public believes that hospitals will have light, heat, air conditioning, water, food, and communications capabilities, regardless of the fact that the institution may itself be affected by the calamity. During the terrorist attacks in the fall of 2001 and the Northeast Blackout of 2003, the public flocked to hospitals, even when they did not require medical care. Furthermore, with increased intelligence of the vulnerabilities of the healthcare infrastructure and the desire of terrorists to exploit this, institutions have been forced to focus limited resources on safety and security rather than on comprehensive emergency management efforts. A major change in the way hospitals plan for hazards and vulnerabilities includes less planning for specific single issues or threats but rather the adoption of an all–hazards comprehensive emergency management planning process. Additionally, hospitals need to look beyond their emergency department doors and engage community stakeholders to assist in this process, reaching out to local and regional emergency planners to assist in larger communitywide emergency preparedness planning. The interest of nonhospital entities in health system emergency preparedness can be seen through several examples, including emergency management and public health initiatives on mass vaccination, pandemic planning, increasing hospitals’ ability to perform decontamination of casualties contaminated with hazardous materials, etc. Recent reflection of the role of the hospital in emergency management and population health can been seen in revised laws, regulations, and even accreditation standards. An example of this is The Joint Commission on the Accreditation of Healthcare Organizations’ (JCAHO) change from placing emergency preparedness standards in the Environment 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 5 Emergence and Growth of Healthcare Emergency Management | 5 of Care section to placing the standards in a separate and distinct section with specific goals and requirements, as well as the release of the Occupational Safety and Health Administration (OSHA) document Best Practices for Hospital-Based First Receivers.1–3 Over the past eight years we have embarked on an interesting marriage of these two separate disciplines—health care and emergency management—whose common ground has historically been brought together in the street or on the disaster scene by emergency medical services workers, or sometimes brought into the emergency departments of hospitals and trauma centers across the country. Both disciplines have separate roles and responsibilities, but where the seemingly disparate goals of these fields come together is the reduction of morbidity and mortality following disasters, acts of terrorism, and public health emergencies. Emergency management agencies have traditionally been responsible for bringing first responders, government agencies, and community stakeholders together to assist with comprehensive emergency planning or disaster response and recovery. A common cornerstone of emergency management has been to protect life, then property, then the environment. As a result, when conducting emergency planning activities, the health and medical needs of the population are among the most significant and are considered with basic public health and human needs including sheltering, mass care, sanitation, environment health, food and water, and other essential services. In addition, as public health professionals, we also believe that population health activities include the mitigation of increased morbidity and mortality during and following a disaster, act of terrorism, or public health emergency. In healthcare delivery, we attempt to meet the health and medical needs of the community by providing a place for individuals to seek preventative medicine, care for chronic medical conditions, emergency medical treatment, and rehabilitation from injury or illness. While a healthcare institution serves the community, this responsibility occurs at the level of the individual. Each individual expects a thorough assessment and treatment if needed, regardless of the needs of others. This approach is different than that practiced by emergency managers, whose goal is to assist the largest number of people with the limited resources that are available. As such, emergency management principles are focused on the needs of the population rather than the individual. When either planning for a disaster or operating in a disaster response mode, the hospital should be prepared at some point to change its focus from the individual to the community it serves and to begin weighing the needs of any individual patient versus the most good for the most patients with scarce resources. Moving from the notion of doing the most for each individual to doing the best for the many is a critical shift in thinking 55133_CH01_Reilly:Achorn Int’l 6 | Chapter 1 5/13/10 12:08 PM Page 6 Introduction to Hospital and Healthcare Emergency Management for healthcare institutions considering a program of comprehensive emergency management. While the initial planning for emergencies by hospitals is focused on maintaining operations and handling the care needs of actual or potential increased numbers of patients and/or different presentations of illness or injury than is traditionally seen, there is also the need to recognize that at some point during a disaster, act of terrorism, or public health emergency there may be an imbalance of need versus available resources. At this point the approach to delivering healthcare will need to switch from a focus on the individual to a focus on the population. This paradigm shift is one of the core unique aspects of hospital emergency management that allows the hospital to prepare to maximize resources in disasters and then to know when to switch to a pure disaster mode of utilizing its limited and often scant resources to help the most people with the greatest chance of survival. The healthcare delivery system is vast and comprised of multiple entry points at primary care providers, clinics, urgent care centers, hospitals, rehabilitation facilities, and long-term care facilities. The point of entry for many individuals into the acute healthcare system is through the emergency department (ED). Since the late 1970s, the emergency medical services (EMS) system has allowed victims of acute illness and injury to receive initial stabilization of life-threatening medical conditions on the way to the emergency department. Among the many strengths of the ED is the ability to integrate two major components of the healthcare system: prehospital and definitive care. The emergency department maintains constant communications with the EMS system and serves as the direct point of entry for prehospital providers into the hospital or trauma center. Emergency physicians represent a critical link in this process by anticipating the resources that ill and injured patients will need upon arrival at the ED, and initiating appropriate life-saving medical care until specialty resources become available.4–11 In this context, the healthcare system is an emergency response entity. Healthcare Emergency Management Activities Hospital emergency management activities vary and can be categorized in many ways, however some common areas of focus within healthcare emergency management include the following areas: ■ ■ ■ ■ ■ ■ ■ communication surge capacity volunteer management security issues hazmat/CBRNE preparedness collaboration and integration with public health education and training 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 7 Healthcare Emergency Management Activities | 7 ■ ■ ■ ■ ■ equipment and supplies worker safety drills and exercises emergency department disaster operations trauma centers COMMUNICATION Communication issues in disaster preparedness and response are cited throughout the literature as a major source of frustration and inadequacy for coordinating and executing disaster operation plans.4–5,8,11–16 By identifying the vulnerabilities in the existing system of healthcare communication systems, we can take steps to address these issues and further increase our health system preparedness. Addressing the vulnerabilities in communication systems and planning how to overcome them is an essential responsibility of a hospital emergency manager. Many of the criticisms of the current state of health systems’ communication systems center around the inability to communicate easily with external agencies and share critical information. Disaster after-action reports and exercise improvement plans almost universally cite poor communication as one of the problems associated with incident management and the event being reviewed. Infrastructure support is an important consideration when examining whether adequate safeguards are in place to support the systems we will rely upon during a disaster. On September 11, 2001, while one New York City hospital was preparing to treat a large number of (anticipated) casualties from the disaster, they experienced a loss of their computer and information systems.17 This unplanned event arose because the communication system line that supported their system’s infrastructure ran beneath the World Trade Center.17 Additionally, other reports have cited problems with battery failure and the lack of a prolonged power supply as limiting communication systems’ abilities during an event.14 This example illustrates a major point in emergency communication systems: hospitals need the ability to connect all significant parties during a disaster or other emergency and the system should be based on a redundant infrastructure.5 Clearly, from a planning perspective, this would be a desirable option. However, the reality remains that investing in communication systems is a significant financial burden on already underfunded hospitals and healthcare systems. Risk communication is often overlooked during the planning phase of an event, and this can lead to frustration and confusion during disaster operations. Risk communication is sometimes the only way for the public to gain an understanding of the scope and severity of an incident. Additionally, risk communication information provided by hospitals may be used to help families of disaster victims find information about 55133_CH01_Reilly:Achorn Int’l 8 | Chapter 1 5/13/10 12:08 PM Page 8 Introduction to Hospital and Healthcare Emergency Management their loved ones’ condition. Reviews of risk communication have shown that a predesignated public information officer (PIO), who will liaise with the media and the public and who has specific training and experience in giving briefings and fielding questions, should perform all risk communication tasks during disaster operations.13 Specific elements of risk communication that may be conveyed to the public may include information on evacuations, scope and breadth of the event, where and how to obtain assistance if needed, whom to call for specific information, location of postexposure prophylaxis or vaccination clinics, and what to expect over the next several hours and/or days of the event. This is discussed in more detail in Chapter 12. SURGE CAPACITY The General Accounting Office (GAO), which changed its name to the Government Accountability Office (GAO) in 2004, finalized reports during 2003 on the public health and hospital preparedness for bioterrorism and emerging infectious diseases.9,16 These reports found that most hospitals in the United States do not have the means to care for a surge of patients during a public health emergency.9,16 They stated that, based on the national emergency department diversion rates in urban and suburban areas, shortages in the healthcare workforce, and the general lack of available supplemental medical equipment and supplies in hospitals, the medical community is not prepared to handle a patient surge caused by an infectious disease outbreak or bioterrorism related event.9,16 Emergency departments are being utilized more often as urgent care centers because the growing population utilizes the ED as their point of primary care. This increasing phenomenon is contributing to ED overcrowding and diversionary status (hospital EDs asking that ambulances refrain from bringing patients to their facility for a period of time) in virtually every healthcare and trauma system in the country. The current state of affairs in the nation’s EDs makes it very difficult to prepare for surge capacity when many hospitals cannot effectively handle their daily patient volume.18 Referral patterns of patients presented to medical facilities will vary in terms of how they arrive at the facility (EMS or self-transport) as well as which facilities they access (hospital ED or physician’s office), depending on the type of disaster or public health emergency. In cases of natural disasters, explosions, and acute catastrophic events where there is a clear and defined “scene,” many patients will be triaged, treated, and perhaps transported to hospitals or trauma centers by EMS personnel. In cases of bioterrorism or infectious disease outbreaks, patients would normally exhibit minor signs and/or symptoms of an illness (e.g., fever, rash, flu-like symptoms, etc.). These patients may be 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 9 Healthcare Emergency Management Activities | 9 presented to their primary care physician or an urgent care center to receive initial diagnosis and treatment. The patients that can be expected to arrive at the ED in these cases would be those who could not access a private physician, those too acutely ill to seek care in an office setting, those referred to the ED by their physicians, and those patients who called EMS for assistance. This latter group would yield the least number of ED arrivals.19–20 Incidents of chemical and biological terrorism as well as pandemic or epidemic incidents of infectious diseases may arguably produce the most significant burden on the healthcare system.9,13,16,18,21 A main reason for this is the unpredictable referral patterns of patients who fall victim to a chemical or biological hazard. Although some disaster after-action reports do suggest that even victims of conventional disasters will self-refer to medical facilities, the issues of delayed onset of symptoms, cross-contamination, and person-to-person disease transmission that are associated with a chemical, biologic, or radiologic incident call for more detailed contingency plans. An example of hospital referral patterns after a chemical agent event can be seen in the post-event summary of the sarin attack in the Tokyo subways in March of 1995.22 In this incident 12 people were killed, but more than 5000 people sought medical attention, and only 688 of them were medically transported to area hospitals.22 At some point during the evolution of a disaster or other public health emergency, patients will converge on acute care hospitals. Studies have consistently shown that despite rigorous planning initiatives, hospitals and emergency departments are not prepared to handle the mass influx of patients that a bioterrorism event or infectious disease outbreak would produce.9,16,19–20 During the sarin attack on the Tokyo subway in 1995, the nearest hospital had 500 patients in the first hour after the incident and more than 20% of its staff was secondarily contaminated.22 It is important that planners additionally recognize that in certain catastrophic disasters involving bombings, building collapse, etc., mass injuries and a patient surge may not occur as anticipated because of the high rate of mortality.17,23 The hospital emergency manager and all those involved in hospital emergency management must ensure that their hospital has adequate plans for the surge of patients that will arrive during a disaster, terrorism event, or public health emergency. VOLUNTEER MANAGEMENT The use of volunteers in disasters and public health emergencies presents a unique set of considerations for the hospital emergency manager. Volunteers can be utilized in several ways to assist in disaster relief services. However, the problems of volunteer management, credentialing, 55133_CH01_Reilly:Achorn Int’l 10 | Chapter 1 5/13/10 12:08 PM Page 10 Introduction to Hospital and Healthcare Emergency Management safety, and security often preclude their utility in the acute disaster environment unless significant pre-planning for their use has occurred and their arrival is through a pre-defined system. Cone et al. describe “convergent volunteerism” (the influx of citizens and/or health providers to a major incident) as a “critical problem” in disaster management.24 Intuitively, you may think that the outpouring of community support to assist in rendering aid during a disaster or other public health emergency is a welcome show of support for disaster victims. However, the reality is that convergent volunteerism brings with it security, resource, and worker safety problems that require personnel and critical resources to manage. In their discussion of convergent volunteerism in the September 11 terrorist attacks in NYC, Cone and colleagues discuss the myriad of additional challenges and problems that the unsolicited and often intrusive behavior of “Good Samaritans” imposed on the NYC responders. Issues included the unsupervised practice of medicine and paramedicine; credential verification of certified and/or licensed personnel; the performance of search and rescue operations by lay responders; the need to feed, shelter, and provide sanitary facilities for volunteers; potential injury and illness to volunteers who were unsupervised and lacked proper personal protective equipment; and personal vehicle congestion on scene access and egress.24 Many of these concerns may seem trivial to some who view a community response to a disaster as being the quintessential demonstration of altruism and support for fellow citizens. However, as mentioned by Cone and colleagues, untrained and unauthorized volunteers can ultimately put themselves and others in danger, and deplete emergency response resources by attempting to provide assistance at disaster scenes. This was most poignantly illustrated during the 1995 bombing of the Alfred P. Murrah Federal Building in Oklahoma City, when an untrained and unprotected volunteer nurse was crushed by falling debris while trying to assist with urban search and rescue operations.24 SECURITY ISSUES Hospitals frequently overlook the need to maintain adequate security of the healthcare facility and overall medical operations as part of both daily operations and emergency planning. The concept of “locking down” or restricting access to a healthcare facility is often contradictory to the typical hospital design and approach of open access to both patients and their families and other visitors. But during a disaster this type of control is essential for many reasons, which include but are not limited to: control of the flow of patients to the areas where care will be provided; access to the facility only by authorized staff; accounting for staff and patients 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 11 Healthcare Emergency Management Activities | 11 in time of evacuation; prevention of potentially contaminated patients entering the hospital from contaminating staff, other patients, and facilities; and prevention of acts of terrorism. Security resources generally vary among hospitals. Some hospitals and trauma centers have sworn police officers present in their facilities 24 hours a day, and others may hire a private security firm to maintain safety or simply serve a concierge or customer service role. Security concerns during disasters and public health emergencies can become significant when considering the potential vulnerabilities associated with the chaotic response environment.15,17,24–25 Specifically cited issues with security during the response to a disaster or public health emergency include access control to medical facilities; credentialing of employees, responders, and volunteers; crime scene and evidence preservation; infrastructure and resource protection; and crowd control.15,17,24–25 HAZMAT/CBRNE PREPAREDNESS There is no question that in the current state of health system and public health preparedness the medical community is ill-prepared to deal with an incident that involves the management and treatment of multiple potentially contaminated victims, including those from chemical, biological, radiological, nuclear, and explosive (CBRNE) events. Multiple recent reports of hospital preparedness cite decontamination capabilities as a serious weakness of disaster readiness plans.4–5,8–9,11,15–16,26–27 One study cites as few as 6% of Level I trauma centers as having the necessary equipment on hand to safely decontaminate a single patient.26 Planning for these events has traditionally centered around the fallacy that patients will be decontaminated at the scene by first responders and then be triaged, treated, and transported to the ED. The decontamination process serves a dual purpose. First, it removes the potential agent that is causing harm to the patient, and second, it prevents the spread of secondary contamination to other patients and hospital staff. We have come to realize from recent incidents involving victim contamination that many ambulatory victims will leave the scene and bypass EMS decontamination and triage, seeking medical care on their own.11,15,19–20 The reality of dealing with an intentional release of chemical, biological, or radiological agent is that by the time acute care facilities can be made aware that an event has taken place, they may have already been contaminated themselves.22 The specifics of hospital decontamination and worker safety are discussed in Chapter 14. Throughout the nation, trauma systems, acute care hospitals, and first responders are unprepared for handling an event involving the release of a nuclear, biological, or chemical (NBC) agent.8,15,26 Largely, this is due to ineffective planning and relying on resources that may not be available 55133_CH01_Reilly:Achorn Int’l 12 | Chapter 1 5/13/10 12:08 PM Page 12 Introduction to Hospital and Healthcare Emergency Management during a disaster or public health emergency.15 The most often cited weaknesses are an overall lack of training, lack of personal protective equipment (PPE), lack of resources and equipment to rapidly and reliably perform preliminary agent detection, and lack of appropriate medical facilities, equipment and supplies to effectively isolate infectious patients and manage them through the course of their illnesses.8,15,21–22,26 COLLABORATION AND INTEGRATION WITH PUBLIC HEALTH In order for disaster preparedness and response to be successful, it must involve interagency resources and consider the 3C’s of emergency response planning: Collaboration, Cooperation, and Coordination. Response plans cannot be designed and implemented in a vacuum. Disaster response and recovery operations will certainly consist of a multiagency response at the local, state, and federal levels. In order to ensure that the response plan is valid, and will operationally integrate with other key responding agencies, the planner must collaborate with fellow agencies and develop plans that involve aspects of interagency response. Interagency planning groups, such as the Local Emergency Planning Committee (LEPC), operate under the assumption that if a hazardous event occurs, all key public safety and health agencies will respond in a unified approach with common goals to protect the welfare and safety of the community. These principles of collaboration, cooperation, and coordination among the agencies that will likely respond to a disaster or other public health emergency will minimize unnecessary redundancy in response plans and create partnerships with agencies that can provide expertise and resources during the public health emergency response. In a large-scale disaster or act of terrorism, such as the World Trade Center attacks in 1993 and 2001, the Oklahoma City bombing in 1995, and the 1994 and 1995 sarin attacks in Tokyo, continuous medical monitoring and follow-up of the survivors, responders, and participants in these events is needed to detect the associated long-term health effects. With the exception of large academic medical institutions that may perform epidemiologic analysis on specific cohorts of individuals, the public health community must recruit and maintain a database of affected individuals so they can study the long-term impact of these events on the health of the population. It is important to note that although the imminent threat of danger may no longer be present, the need for medical care, disease surveillance, and follow-up studies is essential to the completion of the public health role in a disaster or other public health emergency. Additionally, public health agencies at the federal, state, and local levels have the responsibility under the National Response Framework (NRF) to coordinate and serve as the lead agency for disasters involv- 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 13 Healthcare Emergency Management Activities | 13 ing mass care. This may include assisting both hospitals and communities to establish alternate care sites (ACS) where patients can be directed to receive medical treatment during a public health emergency, which will allow a hospital to use its resources to treat higher acuity patients and remain open to handle routine emergencies during a pandemic or other public health emergency. EDUCATION AND TRAINING Reports have suggested that healthcare workers lack the knowledge to detect and manage a patient who has been exposed to a chemical or biological agent.6,27–28 The Health Resources and Services Administration (HRSA) survey helped to illustrate the lack of training and education among trauma center and hospital staff by reporting that only eight states required employees to be trained in disaster-related topics, two states required training in biological agent topics, and two states required training for chemical-related topics.8 Additionally, training for EMS personnel was equally poor because only six states required prehospital providers to have education on disaster-related topics, only one state required biological agent training, and three states required education on chemical agents.8 EQUIPMENT AND SUPPLIES In the GAO’s report of hospital preparedness in August 2003, they reported several findings on hospital equipment and supply resources. The survey showed that for every 100 beds, 50% of hospitals had fewer than 6 ventilators, fewer than 3 PPE suits, fewer than 4 isolation beds, and could only handle fewer than 6 patients per hour through a 5-minute decontamination shower, given their current state of preparedness.9 Additionally, the GAO reports that most first responders lack a reliable means to detect chemical and/or biological agents in the field, and do not typically have the proper PPE to protect themselves from agent exposure.9 The HRSA evaluation of state trauma systems showed that the availability of PPE for healthcare workers was significantly lacking among states because only one state (Ohio) had enough PPE resources immediately available for its EMS personnel, and only one state (New Jersey) had enough PPE resources immediately available for its hospital personnel if a chemical or biological agent release occurred.8 In addition to PPE issues, hospitals and trauma centers often lack the inventory of equipment and supplies necessary to effectively treat an influx of potentially affected patients.8–9,14–16,26 Many hospitals, in a strategy to reduce overall costs, replenish their central supply on a “just-in-time” basis, clearly ineffective in preparing to treat a mass 55133_CH01_Reilly:Achorn Int’l 14 | Chapter 1 5/13/10 12:08 PM Page 14 Introduction to Hospital and Healthcare Emergency Management influx of patients.18 Pharmaceutical access is another concern among healthcare facilities. As demonstrated in the fall 2001 anthrax scare, hundreds of postal and healthcare workers required postexposure prophylaxis after potential exposure to the agent. Maintaining an adequate pharmaceutical stock of essential antibiotics, antidotes, and specialty medications in case of a disaster is often viewed as cost prohibitive due to the shelf life and daily usefulness of certain drugs.18 Although this has improved slightly over the past 6 years, hospitals around the country still struggle to build the internal capacity necessary to perform emergency decontamination of patients from hazardous substance incidents and properly protect their staff, patients, and visitors from secondary contamination. WORKER SAFETY A report released by HRSA on the national state of the trauma system and EMS preparedness for disasters and mass causality events showed that only one state in the country thought that its hospital workers would be adequately protected in the event of a biological (but not chemical) agent attack.8 Additionally, only one state reported that its EMS system would have access to PPE in the event of a bioterrorism event.8 Similar research has underscored a general lack of protection for the public health workforce against any type of chemical, biological, or radiological contamination in the event of a disaster.8 A major role for the public health community during an event is to ensure the health and safety of all disaster workers.13,15 DRILLS AND EXERCISES Criticisms regarding drills and exercises are notable throughout the preparedness literature.6,9,11,15,21,26 Comments include statements that exercises are not realistic, drills tend to be conducted with advanced warning on shifts with favorable staffing levels, and with equipment and resource levels at their best, etc. Therefore, the drills bias any useful results from the exercise.15 The purpose of conducting drills and exercises (besides remaining in compliance with accrediting bodies) is to assess whether or not a facility is adequately prepared to handle an incident with relatively low probability, but with extremely significant impact on the health system, and to identify areas that need improvement on an operational and planning level.15 Exercises that simply go through the motions or are conducted with limited realism, under optimal conditions, or are simply haphazardly conducted to meet regulatory or legal requirements are futile and worthless assessment tools that will only perpetuate a hospital’s state of unpreparedness.15 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 15 The Role of the Hospital/Healthcare Emergency Manager | 15 EMERGENCY DEPARTMENT DISASTER OPERATIONS The importance of the ED’s role in disaster and emergency preparedness is discussed in several sources.4–12 The American College of Surgeons mentions that the ED is a major strength of a trauma center.12 They refer to the ED staff as “highly competent” and often “experts” in the medical management of chemical, biological, and radiological casualties.12 Among the many strengths of the ED is the ability to integrate two major components of the trauma system: prehospital and definitive care. The emergency department maintains constant communications with the EMS system and serves as the direct point of entry for prehospital providers into the hospital or trauma center. Emergency physicians represent a critical link in the chain of survival by anticipating the resources that ill and injured patients will need upon arrival at the ED, and initiating appropriate lifesaving medical care until specialty resources become available.4–11 TRAUMA CENTERS The roles of trauma centers during a disaster or public health emergency are consistent with their daily activities in the treatment of injured patients. Triage and treatment of injured victims after a disaster is frequently discussed as a central role of the trauma center in the aftermath of a disaster.6,8–11,13,15–16,18,23,25–29 It is well documented that trauma centers are adept at the care of the injured victim, and are viewed as the best choice for the triage and treatment of disasterrelated injured victims.4–10,12,14,17,23,25–31 Trauma care is identified most frequently as the major strength of the trauma center and the trauma system. Another expectation is that trauma centers and acute care hospitals will be able to treat mass numbers of affected patients as well, including the rapid triage and treatment of all casualties (including those from CBRNE events), decontamination and/or isolation, and quarantine of contaminated or potentially infectious patients. Trauma centers are also expected to have access to essential equipment, supplies, and pharmaceutical agents.4–6,8,14–15,17,23,27–29,32 The Role of the Hospital/Healthcare Emergency Manager What then, is a hospital or healthcare emergency manager? A hospital or healthcare emergency manager is an individual employed by a healthcare organization whose job is to coordinate the emergency management functions of the hospital. This may include many responsibilities 55133_CH01_Reilly:Achorn Int’l 16 | Chapter 1 5/13/10 12:08 PM Page 16 Introduction to Hospital and Healthcare Emergency Management depending on the hospital or healthcare system, the location of the facility, the size and type of facility or organization, and specific local issues or threats and activities. While there may be variation in the role, almost universally the hospital/healthcare emergency manager will perform hazard vulnerability analysis, planning activities, coordination of the hospital’s disaster and other emergency management planning groups or committees, design and conduct training programs, perform drills and exercises, interact with other agencies and organizations involved in healthcare emergency management (e.g., local public health department, local office of emergency management, EMS, local law enforcement, and state agencies), and maintain compliance with regulatory agencies and accreditation organizations such as the JCAHO. Many hospital or healthcare emergency managers are individuals who have these duties in addition to their normal occupational roles in the healthcare organization. Typical positions within healthcare organizations that also perform emergency preparedness activities include nursing managers, educators, administrators, security managers, environmental health and safety administrators, facilities or physical plant directors, or emergency medical services coordinators. Few hospitals have taken the initiative to hire a full-time emergency preparedness coordinator for several reasons. First, there is no direct revenue return on investment in hospital preparedness. Emergency management is rather a fixed but necessary operating cost. In the United States, hospitals and healthcare organizations need to generate a profit. Even in not-for-profit hospitals, CEOs need to be able to show that profit increased in order to justify growth and add services for their patients. Activities that cannot improve the profitability of the organization often remain unfunded. Second, there is a shortage of qualified individuals to fill these positions. As mentioned before, most hospitals have added the duties and responsibilities of preparedness onto an existing full-time employee and this individual had to teach themselves how to perform these added duties. Most individuals who serve in full-time hospital emergency manager positions have a public safety background or a clinical background and have had to learn the discipline of emergency management. Until recently there have been few higher educational opportunities for people who wish to learn the discipline of healthcare emergency management. In 2010, the Federal Emergency Management Agency’s (FEMA) Higher Education Program listed only 10 undergraduate and graduate programs combined that focus on both healthcare and emergency management. Many of these are new programs that have only been in existence for a few years. There have been degree programs in general emergency management, but only a few that apply this discipline to the public health or hospital environment. 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 17 References | 17 If you don’t seek out a formal degree, how do you become knowledgeable in hospital emergency planning? Initially, it begins with your current role. If you are a healthcare worker who needs to learn the finer points of emergency planning, drills and exercises, and incident management, then you could benefit from FEMA’s independent study program or professional development series. On the other hand, if you are an emergency management professional with little knowledge of the healthcare environment, you may benefit from continuing education in health and medical issues such as the strategic national stockpile, emerging infectious diseases and pandemics, the health and medical impact of terrorism and weapons of mass destruction, and the health impact on populations displaced as the result of disasters. This text is designed specifically for individuals who wish to learn the applied discipline of healthcare emergency management, and for all other personnel in a hospital or from other disciplines who will work with either a hospital or any other aspect of a healthcare system in planning for and responding to disasters, terrorism, and public health emergencies. Whether you are a college or graduate student learning the fundamentals of public health or healthcare emergency management, or a current healthcare professional looking to increase your current knowledge in order to apply emergency management principles to your trade, this book is designed to meet your needs. There is a lot to learn, and this text is just the beginning. This emerging field is exciting, challenging, and rewarding. We wish you luck on your journey! References 1. 2. 3. 4. 5. 6. U.S. Department of Labor, Occupational Safety and Health Administration. Best Practices for Hospital-Based First Receivers of Victims from Mass Casualty Incidents Involving the Release of Hazardous Substances. Washington, DC: OSHA; 2005. OSHA publication 3249–08N. Joint Commission Resources. Emergency management standards. Environ Care News. 2007;10(12):2–8. Joint Commission Resources. Preparing for catastrophes and escalating emergencies. Environ Care News. 2008;11(1):1–3, 11. American College of Surgeons. Resources for Optimal Care of the Injured Patient: 1999. Chicago: American College of Surgeons; 1999. American Trauma Society and U.S. Department of Transportation, National Highway Traffic Safety Administration. Trauma System Agenda for the Future. National Highway Traffic Safety Administration; October 2002. Report #3P0138. American College of Surgeons. [ST-42] Statement on disaster and mass casualty management [by the American College of Surgeons]. American College of Surgeons Web site. http://www.facs.org/fellows_info/statements/st-42.html. Published 2003. Accessed December 28, 2009. 55133_CH01_Reilly:Achorn Int’l 18 | Chapter 1 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 5/13/10 12:08 PM Page 18 Introduction to Hospital and Healthcare Emergency Management Bledsoe BE, Porter RS, Cherry RA. Essentials of Paramedic Care. Upper Saddle River, New Jersey: Brady/Prentice Hall Health; 2003. U.S. Department of Health and Human Services, Health Resources and Services Administration. A 2002 National Assessment of State Trauma System Development, Emergency Medical Services Resources, and Disaster Readiness for Mass Casualty Events. Washington, DC: Health Resources and Services Administration; 2002. U.S. General Accounting Office. Hospital Preparedness: Most Urban Hospitals Have Emergency Plans but Lack Certain Capacities for Bioterrorism Response. Washington, DC: U.S. General Accounting Office; August, 2003. Report GAO-03-924. Frykberg ER. Disaster and mass casualty management: a comment on the ACS position statement. Bulletin of the American College of Surgeons. 2003;88(8):12–13. White SR. Hospital and emergency department preparedness for biological, chemical, and nuclear terrorism. Clin Occup Environ Med. 2002;2(2):405–425. Trunkey DD. Trauma centers and trauma systems. JAMA. 2003;289:1566–1567. Landesman LY. Public Health Management of Disasters: The Practice Guide. Washington, DC: American Public Health Association; 2001. May AK, McGwin G Jr, Lancaster LJ, et al. The April 8, 1998 tornado: assessment of the trauma system response and the resulting injuries. J Trauma. 2000; 48(4):666–672. Rubin, JN. Recurring pitfalls in hospital preparedness and response. J Homeland Security. January, 2004. http://www.homelanddefense.org/journal/Articles/ rubin.html. Accessed August 18, 2009. U.S. General Accounting Office. SARS Outbreak: Improvements to Public Health Capacity Are Needed for Responding to Bioterrorism and Emerging Infectious Diseases. Washington, DC: U.S. General Accounting Office; May 7, 2003. Publication GAO-03-769T. Feeney J, Parekh N, Blumenthal J, Wallack MK. September 11, 2001: a test of preparedness and spirit. Bulletin of the American College of Surgeons. 2002;87(5). Barbera JA, Macintyre AG, DeAtley CA. Ambulances to nowhere: America’s critical shortfall in medical preparedness for catastrophic terrorism. In: Howitt AM, Pangi RL, eds. Countering Terrorism: Dimensions of Preparedness. Cambridge, MA: MIT Press; 2003:283–297. Reilly MJ, Markenson D. Hospital emergency department referral patterns in a disaster. Prehosp Disast Med. 2009;24(2):s29–s30. Reilly MJ. Referral patterns of patients in disasters—who is coming through your emergency department doors? Prehosp Disast Med. 2007;22(2):s114–s115. Kellerman A. A hole in the homeland defense. Modern Healthcare. 2003;33(16):23. U.S. Department of Defense, Army, SBCCOM, Federal Domestic Preparedness Program. NBC Domestic Preparedness Senior Officials’ Workshop (SOW) [CD-ROM]. SBCCOM; 1999. Cushman JG, Pachter HL, Beaton HL. Two New York City hospitals’ surgical response to the September 11, 2001, terrorist attack in New York City. J Trauma. 2003;54:147–155. Cone DC, Weir SD, Bogucki S. Convergent volunteerism. Ann Emerg Med. 2003;41(4):457–462. Feliciano DV, Anderson GV Jr, Rozycki GS, et al. Management of casualties from the bombing at the Centennial Olympics. Am J Surg. 1998;176(6):538–543. Ghilarducci DP, Pirallo RG, Hegmann KT. Hazardous materials readiness of United States Level 1 trauma centers. J Occup Environ Med. 2000;42(7):683–692. 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 19 References | 19 27. 28. 29. 30. 31. 32. American College of Surgeons. Disasters from biological and chemical terrorism—what should the individual surgeon do?: a report from the Committee on Trauma. American College of Surgeons Web site. http://www.facs.org/ civiliandisasters/trauma.html. Accessed December 30, 2009. American College of Surgeons. Statement on unconventional acts of civilian terrorism: a report from the Board of Governors. American College of Surgeons Web site. http://www.facs.org/civiliandisasters/statement.html. Accessed December 30, 2009. Jacobs LM, Burns KJ, Gross RI. Terrorism: a public health threat with a trauma system response. J Trauma. 2003;55(6):1014–1021. MacKenzie EJ, Hoyt DB, Sacra JC, et al. National inventory of hospital trauma centers. JAMA. 2003;289:1515–1522. Mann NC, Mullins RJ, MacKenzie EJ, Jurkovich GJ, Mock CN. Systematic review of published evidence regarding trauma system effectiveness. J Trauma. 1999; 47(3);S25–S33. Peterson TD, Vaca F. Commentary: Trauma systems: a key factor in homeland preparedness. Ann Emerg Med. 2003;41(6):799–801. 55133_CH01_Reilly:Achorn Int’l 5/13/10 12:08 PM Page 20 55133_CH02_Reilly:Achorn Int’l 5/13/10 1:15 PM Page 21 Chapter 2 Healthcare Incident Management Systems Arthur Cooper, MD, MS Photo by Jocelyn Augustino/FEMA News Photo Learning Objectives ■ Discuss the fundamental principles of healthcare incident management systems. ■ Describe the incident command system structure and its application to the healthcare environment. ■ Discuss the importance of interagency cooperation and collaboration when managing disasters and public health emergencies that impact the healthcare system. Overview Making method out of madness The aim of this chapter is to arm the busy healthcare staff, clinician, or emergency manger with a basic understanding of incident management 21 55133_CH02_Reilly:Achorn Int’l 22 | Chapter 2 5/13/10 1:15 PM Page 22 Healthcare Incident Management Systems systems as applied to the healthcare and hospital environment, including the Hospital Incident Command System (HICS), not as a substitute, but as a rationale for incident management training and the need to understand the application to a hospital or healthcare system. This chapter will cover the fundamental principles of healthcare incident management systems, including one system modified specifically for the hospital, the Hospital Incident Command System. Such systems are vital to the management of disasters, acts of terrorism, and public health emergencies involving healthcare organizations because, without the effective coordination of resources achieved through use of a healthcare incident management system, chaos, rather than order, will prevail. After a concise introduction to set the stage, the chapter will consider the historical background, foundational principles, incident leadership, command structures, HICS organization, training systems, HICS implementation, logistic concerns, practical concerns, and interagency relationships essential to successful healthcare incident management, before delivering its conclusions. Case Study A Cloud in the Midnight Sky You are the administrator on duty (AOD) when you are called by the physician in charge of the emergency department, who reports that numerous arriving patients are exhibiting spasms of severe coughing triggered by “something in the air.” While you consider your next steps, your spouse calls to tell you there has been a large explosion at a nearby tank farm adjacent to a large industrial facility. Television reports document widespread panic at the scene and in the immediate vicinity of your hospital, which is located about two miles (three kilometers) east of the site. It is past midnight; only caretaker staff are on duty (except in your critical and acute care units) and hospital staff await your orders. The following questions race through your mind. How would you begin to answer them? ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Does a bona fide disaster exist? Should I declare a disaster now? Should I seek additional information before declaring a disaster? Should I implement the hospital’s emergency operations plan? Should I activate the hospital’s command center? How will I ensure the safety of staff and patients? Should I mobilize additional hospital staff? Should I lock down the facility? Should all emergency patients be decontaminated? Should public health agencies be notified? 55133_CH02_Reilly:Achorn Int’l 5/13/10 1:15 PM Page 23 Historical Background | 23 ■ ■ ■ Who should I ask for necessary additional resources? Are there potential threats to the hospital itself? How will I coordinate and supervise all the staff? The decisions are yours to make. The answers may be found in this chapter. Introduction “Who’s in charge? They’re all in charge!”1 Understanding the Incident Command System (ICS) applied during disasters may prove a daunting task, even for healthcare executives experienced in interpreting complex tables of organization that baffle other managers, clinicians accustomed to solving and treating complex medical problems, and staff prepared to work in the complex healthcare environment. However, as recently stated so eloquently by Lieutenant Thomas Martin of the Virginia State Police in the illuminating video, The Many Hats Of Highway Incident Command (http://cts .virginia.edu/incident_mgnt_training.htm), the principles of incident command are fundamentally no different from the everyday manners children learn as youngsters, as elegantly and clearly described in the poignant work by author Robert Fulghum, All I Really Need To Know I Learned In Kindergarten.1,2 Within this simple framework, the responsible healthcare emergency manager can readily answer the question, “Who’s in charge?” The answer, of course, is that they’re all in charge, of what they’re in charge of—because all those involved in the disaster response are responsible for their immediate tasks, their communication with others, and first and foremost, their own and others’ safety. Historical Background “The best way to predict the future is to create it.”3 Modern incident command grew from the experience of firefighters in combating the California wildfires of the mid 1970s. Inadequate communication and ineffective collaboration between the numerous agencies battling these natural disasters led to the deaths of many firefighters whose lives need not have been lost. The subsequent after-action reports identified numerous critical weaknesses in the organization and delivery of many responders’ agencies and efforts, including lack of accountability, barriers to communication, poor planning processes, 55133_CH02_Reilly:Achorn Int’l 24 | Chapter 2 5/13/10 1:15 PM Page 24 Healthcare Incident Management Systems overloaded incident commanders, and absent response integration. The dawning realization that deficient and defective command and control were mostly responsible for these tragic fatalities led California fire chiefs to develop an “interoperable” system for emergency response, whereby all the involved agencies could communicate with one another and collaborate in the field, based upon a common organizational structure that all such agencies could understand and apply. This new system, called FIRESCOPE (Firefighting Resources of California Organized for Potential Emergencies), was based upon principles gleaned from military experience and management theory, especially the management by objectives concepts introduced in 1954 by Peter F. Drucker in his classic work, The Practice of Management.4 Its core purpose was to provide a standardized, on-scene, all-hazard incident management dogma that allowed its users to quickly implement an integrated organizational structure that was not impeded by jurisdiction boundaries, and was flexible and scalable enough to match the needs and resources for single, expanding, multiple, and complex incidents, despite their special circumstances and unique demands. It rapidly evolved into the Incident Command System (ICS) that has gradually been adopted by most fire and emergency services nationwide, the purposes of which are to ensure the (1) safety of responders and others, (2) achievement of tactical objectives, and (3) efficient use of resources. As a result, ICS was subsequently designated for use throughout the United States by the federal Superfund Amendments and Reauthorization Act (SARA) of 1986 (PL 99-499), Occupational Health and Safety Administration (OSHA) rule 1910.120, and, most recently, Homeland Security Presidential Directive 5 (HSPD 5),5 in addition to numerous other state and local regulations. Its early success also led the California Emergency Medical Services Authority to adapt and periodically revise it for use in all disasters involving hospitals, such that it now serves as the basis of the Hospital Incident Command System (HICS) used by most hospitals in the Americas and, increasingly, worldwide. Specific instruction in HICS is available through both the California Emergency Medical Services Authority HICS Web site (http://www.emsa.ca.gov/HICS/default.asp), and the Emergency Management Institute’s Web site (http://training .fema.gov), within the independent study ICS courses IS-100.HC and IS-200.HC revised in 2007 for healthcare providers.6 Foundational Principles “Management by objectives”4 The three key strategies of the disaster response, in order, are to (1) protect and preserve life, (2) stabilize the disaster scene, and (3) protect and preserve property. Healthcare providers intuitively understand the first 55133_CH02_Reilly:Achorn Int’l 5/13/10 1:15 PM Page 25 Incident Leadership | 25 purpose, and intellectually understand that the third purpose is essential to the first because healthcare providers cannot perform their lifesaving tasks without the appropriate facilities, equipment, and resources. The second purpose, however, may be less obvious. This is because an organized disaster response can occur only within the context of a stable work environment—an environment that is difficult to achieve in the first minutes after disaster strikes, when chaos is the rule, even in greatly complex work environments, such as hospitals, that are highly self-regulated. Thus, an incident management system is needed to bring order to the chaos, the sine qua non of which is an incident command structure characterized by the three key tactics that must underlie all of incident command—unity of command, span of control, and clarity of text. Unity of command refers to the principle that sharing of information among all personnel involved in a disaster response is vital, but such individuals receive formal orders from, and make formal reports to, a single supervisor in order to preserve the viability of the chain of command. Span of control refers to the principle that in a high stress environment, no line supervisor can effectively coordinate the efforts of more than three to seven, and ideally no more than five, subordinate personnel. Clarity of text refers to the principle that all communications, written and spoken, must be transmitted in the simplest, most generic language possible, avoiding the use of words or jargon likely beyond the understanding of many emergency responders, so as to ensure that all personnel involved in the disaster response understand both the general strategy of the Emergency Operations Plan (EOP) and the special tactics being applied to combat the disaster. Incident Leadership “Coordination, Communication, Cooperation”1 Healthcare incident management systems achieve their goals by ensuring what have been termed the “3 Cs” of incident command: coordination, communication, and cooperation, of which the most important is cooperation, because it makes coordination and communication feasible. However, effective incident management requires not only universal education in disaster management appropriate to the functional job description of the individual healthcare employee—awareness, technical, and professional—but also frequent drilling in the implementation of the hospital disaster plan, especially its incident command structure. Most texts and training rightly emphasize that the individuals designated to fulfill specific functional job descriptions must be appropriately trained to do so; therefore, hospital executives who perform similar tasks during routine hospital business must step aside and yield these responsibilities to those who have been trained 55133_CH02_Reilly:Achorn Int’l 26 | Chapter 2 5/13/10 1:15 PM Page 26 Healthcare Incident Management Systems to do so. However, this notion ignores long-established realities of human behavior—the boss is still the boss, even if untrained in disaster management—so every effort should be made by senior executives to ensure that all hospital executives receive training in disaster management and incident command that will enable supervisors to function in their assigned roles even when disaster strikes. Physicians commonly presume that because the first key purpose of incident management is to protect and preserve life, they should be in charge of emergency operations. However, physicians often overlook the fact that while they must clearly be in charge of all aspects of medical care, they generally comprise no more than approximately 10% of the total number of hospital personnel. Typically, the healthcare needs of the hospitalized patient require an average of 10 other personnel to support the treatments prescribed and the operations performed by a single physician or surgeon. Moreover, the physician’s expertise—and most valuable contribution to the hospital disaster response—lies in the medical care of the hospitalized patient, rather than its operational, logistical, or planning support. Command Structure “[ICS is] the system to achieve the coordination necessary to carry out an effective and efficient response.”7 Two basic c

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ommand structures, and variations thereof, are utilized worldwide: (1) the Hospital Incident Command System (HICS), developed by the California Emergency Medical Services Authority and promulgated both by its originator (http://www.ems…
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Writing >The Joint Commission Discussion essay

Writing >The Joint Commission Discussion essay

Respond to each of the two posts with two paragraphs and use at least one reference for each answer. ((APA citation))

the two posts of students who answered the following question (“Is being Joint Commission compliant enough to be able to prepare, respond and recover from a disaster? Explain your answer and review the JC Lessons Learned. What lesson learned resonated with you? Why?”)

First Post (1)

Through accreditation the Joint Commission accreditation, organizations have been able to engage in the development and implementation of comprehensive emergency management plans (Wagner, McDonald, & Castle, 2012). However, while there have been gains in quality measures including patient safety and physical restraint use, being compliant to the Joint Commission is not enough to engage in effective preparation, response, and recovery in case disaster strikes. Lam et al. (2018) found that even though Joint Commission hospitals display better results in patient outcomes, the difference with non-JC accredited hospitals is negligible which might be a consequence of competition within local and regional markets which characterizes hospitals. Wagner, McDonald, and Castle (2012) point out that the Joint Commission’s frequent assessments dull the process of emergency management and lessen its impact. Increasing competition and establishing incentives for risk management can contribute to disaster response management too.

The Joint Commission lesson learned

Among the lessons that the Joint Commission learned, one lesson that resonated with me was the one on planning, training and exercising for infectious disease emergencies. This includes training on the process of initial screening as well as the utility of PPE. Care teams also receive iterative training and learn how to carry out safe patient flow from the entry point to isolation as well as ensuring that patients are transferred safely. Training on the use of dedicated equipment and disposal and transport of waste is also important. This resonated with me because all the activities that are outlined within the lesson are all geared towards equipping management teams with patient care skills during emergencies and ensuring favorable patient outcomes.

References

Lam, M. B., Figueroa, J. F., Feyman, Y., Reimold, K. E., Orav, E. J., & Jha, A. K. (2018). Association between patient outcomes and accreditation in US hospitals: an observational study. BMJ, 363(8179), 1-10. doi:10.1136/bmj.k4011

Wagner, L. M., McDonald, S. M., & Castle, N. G. (2012). Joint Commission Accreditation and Quality Measures in U.S. Nursing Homes. Policy, Politics, & Nursing Practice, 13(1), 8-16. doi:10.1177/1527154412443990

Second post (2)

To a large extent, being the joint commission compliance is what it would take to prepare, respond and recover from a disaster. Focusing on the mission of the organization, its culture and how committed it is to constantly improve the safety and quality of care offered it is enough to manage disasters. The organization is assigned the task of accrediting and certificating hospitals and individuals, checking on performance and measuring the standards of services provided by nurses (Joint Commission on Accreditation of Healthcare Organizations., & Joint Commission Resources, 2006).

The organization equips nurses with skills on preparedness to emergency response, and it provides tools that can be used. The Joint Commission International has a wide scope of operation. It has emergency detecting and alerting devices. It holds campaigns to educate the public about basic safety rules in case of any disaster. It allocates finances for the operations, and it has invested in modern technology to help manage disasters. I am convinced that being the Joint Commission compliance is enough to prepare, respond and recover from disasters, through personal commitment also matters a lot.

The lesson that resonated me was “Transparency at all levels” and “putting the patients’ lives the priority.” The primary responsibility of nurses is to save lives. The work culture requires ethics when handling clients. Transparency would help us attain satisfaction. Putting the patients’ safety the priority is another lesson that has been recurring in my education process. It touched me when I realized that there might be individuals whose lives depend on the patient and when one life is lost, other lives that depend on the deceased suffer. Saving one life is saving many lives. This lesson helped me to be passionate and careful when handling patients.

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It is with a deep concern that I thought “what if I am involved in a disaster and then I am not treated well?” In short, there is a special and less special life. Treating and caring for victims as I could like to be treated and cared will be my key concern. Someone’s situation today would be my situation tomorrow. To conclude, nurses must remain loyal to offering the best services to patients because this is their primary role and responsibility (Joint Commission Resources, 2012).

References

Joint Commission on Accreditation of Healthcare Organizations & Joint Commission

Resources, Inc. (2006). Meeting the Joint Commission’s 2007 National Patient Safety Goals. Oakbrook Terrace, IL: Joint Commission Resources.

Joint Commission Resources, Inc. (2012). Emergency management in health care: An all-

hazards approach. Oakbrook Terrace, IL: Joint Commission Resources.

>HCM481 Educational Flyer Help Strategic Planning Approaches

HCM481 Educational Flyer Help Strategic Planning Approaches

Scenario: You are the Director of Strategic Planning for a large hospital. In three weeks, the senior leadership team will embark on its annual strategic planning cycle. The CEO has decided that the team needs a “refresher” on two important topics: Internal Factor Evaluation and Internal–External Matrix. She has asked you to develop a one-page “flyer” that compares them in a side-by-side format. The flyer should describe each tool and bullet the following items: How the tool is used, strengths of the tools, limitations of the tools, and challenges that organizations usually face in trying to use the tools.

The flyer should be well organized and written and meet the following requirements:

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  • One page in length (excluding reference list, which is required)
  • Include at least three current references from the peer-reviewed articles.

Here are some resources for information about developing flyers:

  • https://business.tutsplus.com/articles/10-design-tips-to-make-a-professional-business-flyer–cms-26226 (Links to an external site.)Links to an external site.
  • https://designshack.net/articles/graphics/how-to-design-an-awesome-flyer-even-if-youre-not-a-designer/ (Links to an external site.)Links to an external site.
  • Make a Flyer using Word (Links to an external site.)Links to an external site.

HCM 481 University of Alabama Value Chain analysis

HCM 481 University of Alabama Value Chain analysis

How can analysis of the value chain be used to assess strategic alternatives? How does this approach differ from the market structure and the resource-based views? Provide examples to support your position.

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CMC Rule In Healthcare Emergency Management Discussion

CMC Rule In Healthcare Emergency Management Discussion

Vol. 81 Friday, No. 180 September 16, 2016 Part II Department of Health and Human Services mstockstill on DSK3G9T082PROD with RULES2 Centers for Medicare & Medicaid Services 42 CFR Parts 403, 416, 418, et al. Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\16SER2.SGM 16SER2 63860 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services 42 CFR Parts 403, 416, 418, 441, 460, 482, 483, 484, 485, 486, 491, and 494 [CMS–3

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178–F] RIN 0938–AO91 Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Centers for Medicare & Medicaid Services (CMS), HHS. ACTION: Final rule. AGENCY: This final rule establishes national emergency preparedness requirements for Medicare- and Medicaid-participating providers and suppliers to plan adequately for both natural and man-made disasters, and coordinate with federal, state, tribal, regional, and local emergency preparedness systems. It will also assist providers and suppliers to adequately prepare to meet the needs of patients, residents, clients, and participants during disasters and emergency situations. Despite some variations, our regulations will provide consistent emergency preparedness requirements, enhance patient safety during emergencies for persons served by Medicare- and Medicaid-participating facilities, and establish a more coordinated and defined response to natural and man-made disasters. DATES: Effective date: These regulations are effective on November 15, 2016. Incorporation by reference: The incorporation by reference of certain publications listed in the rule is approved by the Director of the Federal Register November 15, 2016. Implementation date: These regulations must be implemented by November 15, 2017. FOR FURTHER INFORMATION CONTACT: Janice Graham, (410) 786–8020. Mary Collins, (410) 786–3189. Diane Corning, (410) 786–8486. Kianna Banks (410) 786–3498. Ronisha Blackstone, (410) 786–6882. Alpha-Banu Huq, (410) 786–8687. Lisa Parker, (410) 786–4665. SUPPLEMENTARY INFORMATION: mstockstill on DSK3G9T082PROD with RULES2 SUMMARY: Acronyms AAAHC Accreditation Association for Ambulatory Health Care, Inc. AAAASF American Association for Accreditation for Ambulatory Surgery Facilities, Inc. VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 AAR/IP After Action Report/Improvement Plan ACHC Accreditation Commission for Health Care, Inc. ACHE American College of Healthcare Executives AHA American Hospital Association AO Accrediting Organization AOA/HFAP American Osteopathic Association/Healthcare Facilities Accreditation Program ASC Ambulatory Surgical Center ARCAH Accreditation Requirements for Critical Access Hospitals ASPR Assistant Secretary for Preparedness and Response BLS Bureau of Labor Statistics BTCDP Bioterrorism Training and Curriculum Development Program CAH Critical Access Hospital CAMCAH Comprehensive Accreditation Manual for Critical Access Hospitals CAMH Comprehensive Accreditation Manual for Hospitals CASPER Certification and the Survey Provider Enhanced Reporting CDC Centers for Disease Control and Prevention CON Certificate of Need CfCs Conditions for Coverage and Conditions for Certification CHAP Community Health Accreditation Program CMHC Community Mental Health Center CMS Centers for Medicare and Medicaid Services COI Collection of Information CoPs Conditions of Participation CORF Comprehensive Outpatient Rehabilitation Facilities CPHP Centers for Public Health Preparedness CRI Cities Readiness Initiative DHS Department of Homeland Security DHHS Department of Health and Human Services DNV GL Det Norske Veritas GL—Healthcare DOL Department of Labor DPU Distinct Part Units DSA Donation Service Area EOP Emergency Operations Plans EC Environment of Care EMP Emergency Management Plan EP Emergency Preparedness ESAR–VHP Emergency System for Advance Registration of Volunteer Health Professionals ESF Emergency Support Function ESRD End-Stage Renal Disease FEMA Federal Emergency Management Agency FDA Food and Drug Administration FORHP Federal Office of Rural Health Policy FRI Federal Reserve Inventories FQHC Federally Qualified Health Center GAO Government Accountability Office HFAP Healthcare Facilities Accreditation Program HHA Home Health Agencies HPP Hospital Preparedness Program HRSA Health Resources and Services Administration HSC Homeland Security Council HSEEP Homeland Security Exercise and Evaluation Program PO 00000 Frm 00002 Fmt 4701 Sfmt 4700 HSPD Homeland Security Presidential Directive HVA Hazard Vulnerability Analysis or Assessment ICFs/IID Intermediate Care Facilities for Individuals with Intellectual Disabilities ICR Information Collection Requirements IDG Interdisciplinary Group IOM Institute of Medicine JPATS Joint Patient Assessment and Tracking System LEP Limited English Proficiency LD Leadership LPHA Local Public Health Agencies LSC Life Safety Code LTC Long Term Care MMRS Metropolitan Medical Response System MRC Medical Reserve Corps MS Medical Staff NDMS National Disaster Medical System NFs Nursing Facilities NFPA National Fire Protection Association NIMS National Incident Management System NIOSH National Institute for Occupational Safety and Health NLTN National Laboratory Training Network NRP National Response Plan NRF National Response Framework NSS National Security Staff OBRA Omnibus Budget Reconciliation Act OIG Office of the Inspector General OPHPR Office of Public Health Preparedness and Response OPO Organ Procurement Organization OPT Outpatient Physical Therapy OPTN Organ Procurement and Transplantation Network OSHA Occupational Safety and Health Administration PACE Program for the All-Inclusive Care for the Elderly PAHPA Pandemic and All-Hazards Preparedness Act PAHPRA Pandemic and All-Hazards Preparedness Reauthorization Act PCT Patient Care Technician PPE Personal Protection Equipment PHEP Public Health Emergency Preparedness PHS Act Public Health Service Act PIN Policy Information Notice PPD Presidential Policy Directive PRTF Psychiatric Residential Treatment Facilities QAPI Quality Assessment and Performance Improvement QIES Quality Improvement and Evaluation System RFA Regulatory Flexibility Act RNHCIs Religious Nonmedical Health Care Institutions RHC Rural Health Clinic SAMHSA Substance Abuse and Mental Health Services Administration SLP Speech Language Pathology SNF Skilled Nursing Facility SNS Strategic National Stockpile TEFRA Tax Equity and Fiscal Responsibility Act TFAH Trust for America’s Health TJC The Joint Commission TRACIE Technical Resources, Assistance Center, and Information Exchange E:\FR\FM\16SER2.SGM 16SER2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations TTX Tabletop Exercise UMRA Unfunded Mandates Reform Act UNOS United Network for Organ Sharing UPMC University of Pittsburgh Medical Center WHO World Health Organization mstockstill on DSK3G9T082PROD with RULES2 Table of Contents I. Overview A. Executive Summary 1. Purpose 2. Summary of the Major Provisions B. Current State of Emergency Preparedness C. Statutory and Regulatory Background II. Provisions of the Proposed Rule and Responses to Public Comments A. General Comments 1. Integrated Health Systems 2. Requests for Technical Assistance and Funding 3. Requirement To Track Patients and Staff B. Implementation Date C. Emergency Preparedness Regulations for Hospitals (§ 482.15) 1. Risk Assessment and Emergency Plan (§ 482.15(a)) 2. Policies and Procedures (§ 482.15(b) 3. Communication Plan (§ 482.15(c) 4. Training and Testing (§ 482.15(d) 5. Emergency Fuel and Generator Testing (§ 482.15(e) D. Emergency Preparedness Regulations for Religious Nonmedical Health Care Institutions (RNHCIs) (§ 403.748) E. Emergency Preparedness Regulations for Ambulatory Surgical Centers (ASCs) (§ 416.54) F. Emergency Preparedness Regulations for Hospices (§ 418.113) G. Emergency Preparedness Regulations for Psychiatric Residential Treatment Facilities (PRTFs) (§ 441.184) H. Emergency Preparedness Regulations for Programs of All-Inclusive Care for the Elderly (PACE) (§ 460.84) I. Emergency Preparedness Regulations for Transplant Centers (§ 482.78) J. Emergency Preparedness Regulations for Long-Term Care (LTC) Facilities (§ 483.73) K. Emergency Preparedness Regulations for Intermediate Care Facilities for Individuals With Intellectual Disabilities (ICF/IID) (§ 483.475) L. Emergency Preparedness Regulations for Home Health Agencies (HHAs) (§ 484.22) M. Emergency Preparedness Regulations for Comprehensive Outpatient Rehabilitation Facilities (CORFs) (§ 485.68) N. Emergency Preparedness Regulations for Critical Access Hospitals (CAHs) (§ 485.625) O. Emergency Preparedness Regulations for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services (Organizations) (§ 485.727) P. Emergency Preparedness Regulations for Community Mental Health Centers (CMHCs) (§ 485.920) Q. Emergency Preparedness Regulations for Organ Procurement Organizations (OPOs) (§ 486.360) VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 R. Emergency Preparedness Regulations for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) (§ 491.12) S. Emergency Preparedness Regulations for End-Stage Renal Disease (ESRD) Facilities (§ 494.62) III. Provisions of the Final Regulations A. Changes Included in the Final Rule B. Incorporation by Reference IV. Collection of Information V. Regulatory Impact Analysis VI. Waiver of Proposed Rulemaking I. Overview A. Executive Summary 1. Purpose We have reviewed existing Medicare emergency regulatory preparedness requirements for both providers and suppliers. We found that many providers and suppliers have emergency preparedness requirements, but those requirements do not go far enough in ensuring that these providers and suppliers are equipped and prepared to help protect those they serve during emergencies and disasters. Hospitals, for example, are currently required to have emergency power and lighting in some specified areas and there must be facilities for emergency gas and water supply. We believe that these existing requirements are generally insufficient in the face of the needs of the patients, staff and communities, and do not address inconsistency in the level of emergency preparedness amongst healthcare providers. For example, while some accreditation organizations have standards that exceed CMS’ current requirements for hospitals by requiring them to conduct a risk assessment, there are other providers and suppliers who do not have any emergency preparedness requirements, such as Community Mental Health Centers (CMHCs) and Psychiatric Residential Treatment Facilities (PRTFs). We concluded that current emergency preparedness requirements are not comprehensive enough to address the complexities of the actual emergencies. Over the past several years, the United States has been challenged by several natural and manmade disasters. As a result of the September 11, 2001 terrorist attacks, the subsequent anthrax attacks, the catastrophic hurricanes in the Gulf Coast states in 2005, flooding in the Midwestern states in 2008, the 2009 H1N1 influenza pandemic, tornadoes and floods in the spring of 2011, and Hurricane Sandy in 2012, our nation’s health security and readiness for public health emergencies have been on the national agenda. This final rule issues emergency preparedness requirements PO 00000 Frm 00003 Fmt 4701 Sfmt 4700 63861 that establish a comprehensive, consistent, flexible, and dynamic regulatory approach to emergency preparedness and response that incorporates the lessons learned from the past, combined with the proven best practices of the present. We recognize that central to this approach is to develop and guide emergency preparedness and response within the framework of our national healthcare system. To this end, these requirements also encourage providers and suppliers to coordinate their preparedness efforts within their own communities and states as well as across state lines, as necessary, to achieve their goals. 2. Summary of the Major Provisions We are issuing emergency preparedness requirements that will be consistent and enforceable for all affected Medicare and Medicaid providers and suppliers (referred to collectively as ‘‘facilities,’’ throughout the remainder of this final rule where applicable). This final rule addresses the three key essentials we believe are necessary for maintaining access to healthcare services during emergencies: safeguarding human resources, maintaining business continuity, and protecting physical resources. Current regulations for Medicare and Medicaid providers and suppliers do not adequately address these key elements. Based on our research and consultation with stakeholders, we have identified four core elements that are central to an effective and comprehensive framework of emergency preparedness requirements for the various Medicare- and Medicaidparticipating providers and suppliers. The four elements of the emergency preparedness program are as follows: • Risk assessment and emergency planning: We are requiring facilities to perform a risk assessment that uses an ‘‘all-hazards’’ approach prior to establishing an emergency plan. The allhazards risk assessment will be used to identify the essential components to be integrated into the facility emergency plan. An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters. This approach is specific to the location of the provider or supplier and considers the particular types of hazards most likely to occur in their areas. These may include, but are not limited to, care-related emergencies; equipment and power failures; interruptions in communications, including cyberattacks; loss of a portion or all of a E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 63862 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations facility; and, interruptions in the normal supply of essentials, such as water and food. Additional information on the emergency preparedness cycle can be found at the Federal Emergency Management Agency (FEMA) National Preparedness System Web site located at: https://www.fema.gov/threat-andhazard-identification-and-riskassessment. • Policies and procedures: We are requiring that facilities develop and implement policies and procedures that support the successful execution of the emergency plan and risks identified during the risk assessment process. • Communication plan: We are requiring facilities to develop and maintain an emergency preparedness communication plan that complies with both federal and state law. Patient care must be well-coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management agencies and systems to protect patient health and safety in the event of a disaster. The following link is to FEMA’s comprehensive preparedness guide to develop and maintain emergency operations plans: https://www.fema.gov/media-librarydata/20130726-1828-25045-0014/ cpg_101_comprehensive_preparedness _guide_developing_and_maintaining _emergency_operations_plans_2010.pdf. During an emergency, it is critical that hospitals, and all providers/suppliers, have a system to contact appropriate staff, patients’ treating physicians, and other necessary persons in a timely manner to ensure continuation of patient care functions throughout the facilities and to ensure that these functions are carried out in a safe and effective manner. • Training and testing: We are requiring that a facility develop and maintain an emergency preparedness training and testing program. A wellorganized, effective training program must include initial training for new and existing staff in emergency preparedness policies and procedures as well as annual refresher trainings. The facility must offer annual emergency preparedness training so that staff can demonstrate knowledge of emergency procedures. The facility must also conduct drills and exercises to test the emergency plan to identify gaps and areas for improvement. The Homeland Security Exercise and Evaluation Program (HSEEP), developed by FEMA, includes a section on the establishment of a Training and Exercise Planning Workshop (TEPW). The TEPW section provides guidance to organizations in conducting an annual TEPW and VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 developing a Multi-year Training and Exercise Plan (TEP) in line with the (HSEEP): http://www.fema.gov/medialibrary-data/20130726-1914-250458890/hseep_apr13_.pdf. Medicare and Medicaid participating hospitals and other providers and suppliers through the conditions of participation (CoPs) and conditions for coverage (CfCs) established by this rule. B. Current State of Emergency Preparedness As previously discussed, numerous natural and man-made disasters have challenged the United States over the past several years. Disasters can disrupt the environment of healthcare and change the demand for healthcare services; therefore, it is essential that healthcare facilities integrate emergency management into their daily functions and values. On December 27, 2013, we published a proposed rule titled, ‘‘Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers’’ (78 FR 79082). In this proposed rule we included a robust discussion about the current state of emergency preparedness and federal emergency preparedness activities that have established a foundation for the development and expansion of healthcare emergency preparedness systems. In addition, the December 2013 proposed rule included an appendix of the numerous resources and documents used to develop the proposed rule. We refer readers to the proposed rule for this background information. The December 2013 proposed rule included discussion of previous events, such as the 2009 H1N1 influenza pandemic, the 2001 anthrax attacks, the tornados in 2011 and 2012, and Hurricane Sandy in 2012. In 2014, the United States faced a number of new and emerging diseases, such as MERSCoV and Ebola, and a nationwide outbreak of Enterovirus D68, which was confirmed in 938 people in 46 states between mid-August and October 21, 2014 (http://www.cdc.gov/non-polioenterovirus/outbreaks/EV-D68outbreaks.html). We believe that finalizing the emergency preparedness rule is an important part of improving the national response to Ebola and any infectious disease threats. Healthcare providers have raised concerns about their safety when caring for patients with Ebola, citing the need for advanced preparation, effective policies and procedures, communication plans, and sufficient training and testing, particularly for personal protection equipment (PPE). The response highlighted the importance of establishing written procedures, protocols, and policies ahead of an emergency event. With the finalization of the emergency preparedness rule, this type of planning will be mandated for C. Statutory and Regulatory Background Various sections of the Social Security Act (the Act) define the types of providers and suppliers that may participate in Medicare and Medicaid and list the requirements that each provider and supplier must meet to be eligible for Medicare and Medicaid participation. The Act also authorizes the Secretary to establish other requirements as necessary to protect the health and safety of patients, although the wording of such authority differs slightly between provider and supplier types. Such requirements may include the CoPs for providers, CfCs for suppliers, and requirements for longterm care facilities. The CoPs and CfCs are intended to protect public health and safety and promote high quality care for all persons. Furthermore, the Public Health Service (PHS) Act sets forth additional regulatory requirements that certain Medicare providers and suppliers are required to meet in order to participate. The following are the statutory and regulatory citations for the providers and suppliers for which we are issuing emergency preparedness regulations: • Religious Nonmedical Health Care Institutions (RNHCIs)—section 1821 of the Act and 42 CFR 403.700 through 403.756. • Ambulatory Surgical Centers (ASCs)—section 1832(a)(2)(F)(i) of the Act and 42 CFR 416.2 and 416.40 through 416.52. • Hospices—section 1861(dd)(1) of the Act and 42 CFR 418.52 through 418.116. • Inpatient Psychiatric Services for Individuals Under Age 21 in Psychiatric Residential Treatment Facilities (PRTFs)—sections1905(a) and 1905(h) of the Act and 42 CFR 441.150 through 441.182 and 42 CFR 483.350 through 483.376. • Programs of All-Inclusive Care for the Elderly (PACE)—sections 1894, 1905(a), and 1934 of the Act and 42 CFR 460.2 through 460.210. • Hospitals—section 1861(e)(9) of the Act and 42 CFR 482.1 through 482.66. • Transplant Centers—sections 1861(e)(9) and 1881(b)(1) of the Act and 42 CFR 482.68 through 482.104. • Long Term Care (LTC) Facilities— Skilled Nursing Facilities (SNFs)— under section 1819 of the Act, Nursing Facilities (NFs)—under section 1919 of the Act, and 42 CFR 483.1 through 483.180. PO 00000 Frm 00004 Fmt 4701 Sfmt 4700 E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations • Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)—section 1905(d) of the Act and 42 CFR 483.400 through 483.480. • Home Health Agencies (HHAs)— sections 1861(o), 1891 of the Act and 42 CFR 484.1 through 484.55. • Comprehensive Outpatient Rehabilitation Facilities (CORFs)— section 1861(cc)(2) of the Act and 42 CFR 485.50 through 485.74. • Critical Access Hospitals (CAHs)— sections 1820 and 1861(mm) of the Act and 42 CFR 485.601 through 485.647. • Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services— section 1861(p) of the Act and 42 CFR 485.701 through 485.729. • Community Mental Health Centers (CMHCs)—section 1861(ff)(3)(B)(i)(ii) of the Act, section 1913(c)(1) of the PHS Act, and 42 CFR 410.110. • Organ Procurement Organizations (OPOs)—section 1138 of the Act and section 371 of the PHS Act and 42 CFR 486.301 through 486.348. • Rural Health Clinics (RHCs)— section 1861(aa) of the Act and 42 CFR 491.1 through 491.11; Federally Qualified Health Centers (FQHCs)— section 1861(aa) of the Act and 42 CFR 491.1 through 491.11, except 491.3. • End-Stage Renal Disease (ESRD) Facilities—sections 1881(b), 1881(c), 1881(f)(7) of the Act and 42 CFR 494.1 through 494.180. The proposed rule responded to concerns from the Congress, the healthcare community, and the public regarding the ability of healthcare facilities to plan and execute appropriate emergency response procedures for disasters. In the proposed rule, we identified four core elements that we believe are central to an effective emergency preparedness system and must be addressed to offer a more comprehensive framework of emergency preparedness requirements for the various Medicare- and Medicaidparticipating providers and suppliers. The four elements are—(1) risk assessment and emergency planning; (2) policies and procedures; (3) communication plan; and (4) training and testing. We proposed that these core components be used across provider and supplier types as diverse as hospitals, organ procurement organizations, and home health agencies, while attempting to tailor requirements for individual provider and supplier types to meet their specific needs and circumstances, as well as the needs of their patients, residents, clients, and participants. These VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 proposals are refined and adopted in this final rule. II. Provisions of the Proposed Rule and Responses to Public Comments In response to our December 2013 proposed rule, we received nearly 400 public comments. Commenters included individuals, healthcare professionals and corporations, national associations, health departments and emergency management professionals, and individual facilities that would be impacted by the regulation. Most comments centered around the hospital requirements, but could be applied to the additional provider and supplier types. We also received comments specific to the requirements we proposed for other individual provider and supplier types. In addition, we solicited comments on specific issues. We have organized our responses to the comments as follows: (1) General comments; (2) implementation date; (3) comments specific to hospitals and those that apply to the overall requirements of the regulation; and (4) comments specific to other providers and suppliers. A. General Comments We received the following comments suggesting improvement to our regulatory approach or requesting clarification of the resources used to develop our proposals: Comment: Most commenters supported our proposal to require Medicare and Medicaid participating facilities to establish an emergency preparedness plan. Many of these commenters noted that this proposal is timely and necessary in light of past emergencies and natural disasters. Response: We thank the commenters for their support. We continue to believe that our current regulations for Medicare and Medicaid providers and suppliers do not adequately address emergency preparedness planning and that emergency preparedness CoPs for providers and CfCs for suppliers should be implemented at this time. Comment: Several commenters disagreed with our proposal to establish emergency preparedness requirements for Medicare and Medicaid providers and suppliers. Some commenters were concerned that this proposal would place undue burden and financial strain on facilities. Most of these commenters stated that it would be difficult to implement additional regulations without additional payment through Medicare, Medicaid, or the Hospital Preparedness Program (HPP). The commenters also stated that facilities PO 00000 Frm 00005 Fmt 4701 Sfmt 4700 63863 would need more time to comply with the proposed requirements. A few commenters disagreed with our statement that hospitals should have emergency preparedness plans and stated that hospitals are already prepared for emergencies. A commenter objected to the statement that hospital leadership has not prioritized disaster preparedness. A commenter recommended that the proposed emergency preparedness requirements be reduced and simplified to reflect the minimum requirements that each provider type is expected to meet. Other commenters objected to the entire proposal and the establishment of additional regulations for healthcare facilities. Response: We disagree with the commenters who stated that the emergency preparedness regulations are inappropriate or unnecessary. Healthcare facilities in the United States have faced many challenges over the years including hurricanes, tornados, floods, wild fires, and pandemics. Facilities that do not have plans established prior to an emergency or a disaster may face difficulties providing continuity of care for their patients. In addition, without proper training, healthcare workers may find it difficult to implement emergency preparedness plans during an emergency or a disaster. Upon review of the current emergency preparedness requirements for providers and suppliers participating in Medicare and Medicaid, we concluded that the current requirements are not comprehensive enough to address the complexities of actual emergencies. We believe that, currently, in the event of a disaster, healthcare facilities across the nation will not have the necessary emergency planning and preparation in place to adequately protect the health and safety of their patients. In addition, we believe that the current regulatory patchwork of federal, state, and local laws and guidelines, combined with various accrediting organizations’ emergency preparedness standards, falls far short of what is needed for healthcare facilities to be adequately prepared for a disaster. Therefore, we proposed to establish comprehensive, consistent, and flexible emergency preparedness regulations that incorporate lessons learned from the past with the proven best practices of the present. Finalizing these proposals, with the modifications discussed later in this final rule, will help healthcare facilities be better prepared in case of a disaster or emergency. We note that the majority of the comments to the proposed rule agree with the establishment of some type of regulatory E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 63864 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations framework for emergency preparedness planning, which further supports our position that establishing emergency preparedness regulations is the most appropriate course of action. In response to comments that request additional time for compliance or additional funds, we refer readers to the discussion on the implementation date and further discussions on funding in this final rule. Comment: Some commenters stated that the term ‘‘ensure’’ was used numerous times in the proposed rule and that the term was over-used. Commenters stated that in some circumstances we stated providers and suppliers had to ‘‘ensure’’ elements of the plan that might be beyond their control during an emergency. A commenter suggested that we replace the word ‘‘ensure’’ with the term ‘‘strive to achieve.’’ Response: We used the word ‘‘ensure’’ or ‘‘ensuring’’ to convey that each provider and supplier will be held accountable for complying with the requirements in this rule. However, to avoid any ambiguity, we have removed the term ‘‘ensure’’ and ‘‘ensuring’’ from the regulation text of all providers and suppliers and have addressed the requirements in a more direct manner. Comment: Some commenters were concerned that the proposed emergency preparedness requirements duplicate existing requirements by The Joint Commission (TJC). TJC is a CMSapproved accrediting organization that has standards and survey procedures that meet or exceed those used by CMS and state surveyors. Facilities accredited under a Medicare approved accreditation program, such as TJC’s, may be ‘‘deemed’’ by CMS to be in compliance with the CoPs. Most of these commenters recommended that CMS rely on existing TJC standards. Other commenters noted that CMS used TJC manual citations from 2007 through 2008. The commenters noted that changes have been made since then and recommended that CMS refer to the most recent TJC manual. Response: We discussed TJC standards in the proposed rule as a point of reference for emergency preparedness standards that currently exist for healthcare facilities, absent additional federal regulations. We note that CMS has the authority to create and modify CoPs, which establish the requirements a provider must meet to participate in the Medicare or Medicaid program. Also, we note that facilities that exceed CMS’s requirements will still remain compliant. Comment: A few commenters stated that the proposal did not take into VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 account the differences that exist between individual facilities. The commenters noted that the proposal does not acknowledge the diversity of different facilities and instead requires a ‘‘one size fits all’’ emergency preparedness plan. The commenters recommended that CMS address the variation between facilities in the emergency preparedness requirements. Some commenters stated that the proposed requirements are inappropriate because they mostly apply to hospitals, and cannot be applied to other healthcare settings. A commenter noted that smaller hospitals with limited capabilities, like LTCHs, should be allowed to work with their local emergency response networks to develop emergency preparedness plans that reflect those hospitals’ limitations. Response: We believe our approach, with the changes to our proposal discussed later in this final rule, appropriately addresses the differences between the 17 provider and supplier types covered by these regulations. We believe that emergency preparedness regulations that are too specific may become outdated over time, as technology and the nature of threats change, and that emergency preparedness regulations that are too broad may be ineffective. Therefore, we proposed four main components that are consistent with the principles as set forth in the National Preparedness Cycle contained within the National Preparedness System (link (see: https:// www.fema.gov/national-preparednesssystem) that can be used across diverse healthcare settings, while tailoring specific requirements for individual provider and supplier types based on their needs and circumstances, as well as the needs and circumstances of their patients, residents, clients, and participants. We continue to believe that these four components, and the variations in the specific requirements of these components, appropriately address variation amongst provider and supplier settings and facilities with an appropriate amount of flexibility. We do not believe that we have taken a ‘‘one size fits all’’ approach in these regulations. We agree with the commenter who stated that smaller hospitals should be allowed to work with their local health department and emergency management agency to develop emergency preparedness plans and we encourage these facilities to engage in healthcare coalitions in their area for assistance in meeting these requirements. However, we note that we are not mandating that smaller facilities confer with local emergency response networks while PO 00000 Frm 00006 Fmt 4701 Sfmt 4700 developing their emergency preparedness plans. Comment: A few commenters stated that the proposed provisions were too specific and detailed. Some commenters believed that, like other CoPs, the proposal should include provisions that are more flexible. The commenters noted that more specificity should be included in CMS’ interpretive guidance documents (IGs). Response: We disagree with commenters. We believe that these regulations strike a balance between the specific and the general. We have not prescribed or mandated specific technology or tools, nor have we included detailed requirements for how emergency preparedness plans should be written. The regulations are broad enough that facilities can formulate an effective emergency preparedness plan, based on a facility-based and community-based risk assessment utilizing an all-hazards approach, that includes appropriate policies and procedures, a communication plan, and training and testing. In meeting the emergency preparedness requirements, providers can tailor specific details to their facilities’ and their patients’ needs. Facilities can also exceed the requirements in this final rule, if they believe it is in their patients’ and their facilities’ interests to do so. Comment: A few commenters suggested that CMS require facilities to include other entities, stakeholders, and individuals in their emergency preparedness planning. Specifically, a few commenters suggested that facilities include patients, their family members, and vulnerable populations, including older adults, people with disabilities, and those who are linguistically isolated, in their emergency preparedness planning. A few commenters also recommended that facilities include patients and their families in emergency preparedness education. A few commenters recommended that front line workers and their workers’ unions be included in the emergency preparedness planning. A commenter suggested that CMS emphasize the full continuum of emergency management activities and identify relevant national associations and resources for each provider type. A commenter noted that local emergency management officials are rarely included in emergency planning. The commenter recommended adding a requirement that would require facilities to submit their emergency preparedness plan to their local emergency management agency for review and assessment, and for assistance on sheltering and evacuation procedures. E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations Response: In the proposed rule, we proposed to require certain facilities to develop a method for sharing information from the emergency plan that the facility determines is appropriate with patients/residents and their families or representatives. A facility may choose to involve other entities in the development of an emergency preparedness plan or they can provide emergency preparedness education to patients’ families and caregivers. During the development of the emergency plan, facilities may also choose to include patients, community members and others in the process. However, we are not mandating these actions as we believe such a requirement would impose an excessive burden on providers and suppliers; instead, we encourage and will allow facilities the discretion to confer with entities and resources that they consider appropriate while creating an emergency preparedness plan and strongly encourage that facilities include individuals with disabilities and others with access and functional needs in their planning. Comment: A commenter recommended that emergency preparedness plans should account for children’s special needs during an emergency. The commenter stated that emergency preparedness plans should include children’s medication and medical device needs, challenges regarding patient transfer for neonatal and pediatric intensive care patients, and issues involving behavioral health and family reunification. A commenter recommended that CMS collaborate closely with the Emergency Medical Services for Children (EMSC) program administered by the Health Resources and Services Administration (HRSA). The commenter noted that this program focuses on improving the pediatric components of the EMS system. Response: We appreciate the commenter’s concerns. As required in § 482.15(a)(1), (2), and (3), when a provider or supplier develops an emergency preparedness plan, we will expect that the provider/supplier will use a facility-based and communitybased risk assessment to develop a plan that addresses that facility’s patient population, including at-risk populations. If the provider serves children, or if the majority of its patient population is children, as is the case for children’s hospitals, we will expect the provider to take into account children’s access and functional needs during an emergency or disaster in its emergency preparedness plan. VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 Comment: A few commenters questioned CMS’ definition of an emergency. A commenter disagreed with the proposed rule’s definition of ‘‘emergency’’ and ‘‘disaster.’’ The commenter stated that the proposed rule definitions exclude internal or smaller disasters that a hospital may declare. Furthermore, the commenter noted that the definitions should include mass casualty incidents and internal emergencies or disasters that a facility may declare. Another commenter requested clarification as to whether the regulation applies to external or internal emergencies. Response: In the proposed rule, we defined an ‘‘emergency’’ or ‘‘disaster’’ as an event affecting the overall target population or the community at large that precipitates the declaration of a state of emergency at a local, state, regional, or national level by an authorized public official such as a Governor, the Secretary of the Department of Health and Human Services (HHS), or the President of the United States. However, we agree with the commenter’s observation that the definition of an ‘‘emergency’’ or ‘‘disaster’’ should include internal emergency or disaster events. Therefore, we clarify our statement that an ‘‘emergency’’ or ‘‘disaster’’ is an event that can affect the facility internally as well as the overall target population or the community at large. We believe that hospitals should have a single emergency plan that addresses all-hazards, including internal emergencies and a man-made emergency (or both) or natural disaster. Hospitals have the discretion to determine when to activate their emergency plan and whether to apply their emergency plan to internal or smaller emergencies or disasters that may occur within their facilities. We encourage hospitals to prepare for allhazards that may affect their patient population and apply their emergency preparedness plans to any emergency or disaster that may arise. Furthermore, we encourage hospitals that may be dealing with an internal emergency or disaster to maintain communication with external emergency preparedness entities and other facilities where appropriate. Comment: A few commenters were concerned that the proposed rule did not require planning for recovery of operations. The commenters recommended that CMS include requirements for facilities to plan for the return of normal operations after an emergency. A commenter recommended that CMS include requirements for provider preparedness in case of an PO 00000 Frm 00007 Fmt 4701 Sfmt 4700 63865 information technology (IT) system failure. Response: We understand the commenter’s concerns and believe that facilities should consider planning for recovery of operations during the emergency or disaster response. Recovery of operations will require that facilities coordinate efforts with the relevant health department and emergency management agencies to restore facilities to their previous state prior to the emergency or disaster event. Our new emergency preparedness requirements focus on continuity of operations, not recovery of operations. Facilities can choose to include recovery of operations planning in their emergency preparedness plan, but we have not made recovery of operations planning a requirement. We refer commenters that are interested in recovery of operations planning to the following resources for more information: • National Disaster Recovery Framework (NDRF): https:// www.fema.gov/national-disasterrecovery-framework. • Continuity Guidance Circular 1 (CGC 1), and Continuity Guidance for Non-Federal Entities (States, Territories, Tribal, and Local Government Jurisdictions and Private Sector Organizations) http://www.fema.gov/ pdf/about/org/ncp/cont_guidance1.pdf. • National Preparedness System (https://www.fema.gov/nationalpreparedness-system) • Comprehensive Preparedness Guide 101 http://www.fema.gov/media-librarydata/20130726-1828-25045-0014/ cpg_101_comprehensive_preparedness_ guide_developing_and_maintaining _emergency_operations_ plans_2010.pdf) Comment: A commenter requested clarification on whether hospitals would have direct access to the Emergency System for Advance Registration of Volunteer Health Professionals (ESAR–VHP). A commenter recommended that CMS work with other federal agencies, including the Department of Homeland Security (DHS) and the Federal Emergency Management Agency (FEMA) to expand ESAR–VHP and Medical Reserve Corps (MRC) team deployments to a 3 month rotation basis. The commenter also recommended that CMS purchase and pre-position Federal Reserve Inventories (FRI) at healthcare distributorships. Response: Hospitals do not have direct access to the Emergency System for Advance Registration of Volunteer Health Professional (ESAR–VHP). The Assistant Secretary for Preparedness E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 63866 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations and Response (ASPR) manages the ESAR–VHP program. The program is administered on the state level. A hospital would request volunteer health professionals through State Emergency Management. For more information, reviewers may email ASPR at esarvhp@hhs.gov or visit the ESAR/VHP Web site: http://www.phe.gov/esarvhp/ pages/home.aspx. Volunteer deployments typically last for 2 weeks and are not extended without the agreement of the volunteer. In regards to the comment on the Federal Reserve Inventories, we believe that the commenter may be referring to the Strategic National Stockpile (SNS). The SNS program is a national repository of antibiotics, chemical antidotes, antitoxins, life-support medications, and medical supplies. It is not within CMS’ purview to purchase, administer, or maintain SNS stock. We refer commenters who have questions about the SNS program to the Centers for Disease Control and Prevention (CDC) Web site at http:// emergency.cdc.gov/stockpile/index.asp. Comment: A commenter noted that CMS did not include emergency preparedness requirements for transport units (fire and rescue units, and ambulances). Furthermore, the commenter questioned whether a Certificate of Need (CON) is necessary during an emergency. Another commenter questioned why large single specialty and multispecialty medical groups are not discussed as included or excluded in this rule. The commenter noted that these entities have Medicare and Medicaid provider status; therefore, should be included in this rule. Another commenter questioned whether the proposed regulations would apply to residential drug and alcohol treatment centers. The commenter noted that if this is the case, it would be difficult for these centers to meet the proposed requirements due to lack of funding. Response: The emergency preparedness requirements only pertain to the 17 provider and supplier types discussed previously in this rule, which have existing CoPs or CfCs. These provider and supplier types do not include fire and rescue units, and ambulances, or single-specialty/multispecialty medical groups. Entities that work with hospitals or any of the other provider and supplier types covered by this regulation may have a role in the provider’s or supplier’s emergency preparedness plan, and providers or suppliers may choose to consider the role of these entities in their emergency preparedness plan. In addition, we note that CMS does not exercise regulatory VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 authority over drug and alcohol treatment centers. In response to the question about a Certificate of Need, we note that facilities must formulate an emergency preparedness plan that complies with state and local laws. A Certificate of Need is a document that is needed in some states and local jurisdiction before the creation, acquisition, or expansion of a facility is allowed. Facilities should check with their state and local authorities in regards to Certificate of Need requirements. Comment: A commenter requested clarification on a facility’s responsibility to patients that have already evacuated the facility on their own. Response: Facilities are required to track the location of staff and patients in the facility’s care during an emergency. The facility is not required to track the location of patients who have voluntarily left on their own, since they are no longer in the facility’s care. However, if a patient voluntarily leaves a facility’s care during an emergency or a disaster, the facility may choose to inform the appropriate health department and emergency management or emergency medical services authorities if it believes the patient may be in danger. Comment: A commenter questioned whether the requirements take into account the role of the physician during emergency preparedness planning. The commenter questioned whether physicians will be required to provide feedback during the planning process, whether physicians would have a role in preserving patient medical documentation, whether physicians would be involved in determining arrangements for patients during a cessation of operations, and to what extent physicians would be required to participate in training and testing. Response: Individual physicians are not required, but are encouraged, to develop and maintain emergency preparedness plans. However, physicians that work in a facility that is required to develop and maintain an emergency preparedness plan can and are encouraged to provide feedback or suggestions for best practices. In addition, physicians that are employed by the facility and all new and existing staff must participate in emergency preparedness training and testing. We have not mandated a specific role for physicians during an emergency or disaster event, but we expect facilities to delineate responsibilities for all of their facility’s workers in their emergency preparedness plans and to determine the appropriate level of training for each professional role. PO 00000 Frm 00008 Fmt 4701 Sfmt 4700 Comment: A commenter objected to use of the term ‘‘volunteers’’ in the proposed rule. The commenter stated that this term was not defined and recommended that the proposal be limited to healthcare professionals used to address surge needs during an emergency. Another commenter recommended that the regulation text should be revised to include the language, ‘‘Use of health care volunteers’’, to further clarify this distinction. Response: We provided information on the use of volunteers in the proposed rule (78 FR 79097), specifically with reference to the Medical Reserve Corps and the ESAR–VHP programs. Private citizens or medical professionals not employed by a hospital or facility often offer their voluntary services to hospitals or other entities during an emergency or disaster event. Therefore, we believe that facilities should have policies and procedures in place to address the use of volunteers in an emergency, among other emergency staffing strategies. We believe such policies should address, among other things, the process and role for integration of healthcare professionals that are locally-designated, such as the Medical Reserve Corps (https:// www.medicalreservecorps.gov/Home Page), or state-designated, such as Emergency System for Advance Registration of Volunteer Health Professional (ESAR–VHP), (http:// www.phe.gov/esarvhp/pages/ home.aspx) that have assisted in addressing surge needs during prior emergencies. As with previous emergencies, facilities may choose to utilize assistance from the MRC or through the state ESAR–VHP program. We believe the description of healthcare volunteers is already included in the current requirement and does not need to be further defined. Comment: A commenter questioned if the proposal will require facilities to plan for an electromagnetic event. The commenter noted that protecting against and treating patients after an electromagnetic event is costly. Another commenter recommended that the rule explicitly include and address the threats of fire, wildfires, tornados, and flooding. The commenter notes that these scenarios are not included in the National Planning Scenarios (NPS). Response: We expect facilities to develop an emergency preparedness plan that is based on a facility-based and community-based risk assessment using an ‘‘all-hazards’’ approach. If a provider or supplier determines that its facility or community is at risk for an E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations electromagnetic event or natural disasters, such as fires, wildfires, tornados, and flooding, the provider or supplier can choose to incorporate planning for such an event into its emergency preparedness plan. We note that compliance with these requirements, including a determination of whether the provider or supplier based its emergency preparedness plan on facility-based and community-based risk assessments using an all-hazards approach, will be assessed through onsite surveys by CMS, State Survey Agencies, or Accreditation Organizations with CMS-approved accreditation programs. Comment: A few commenters had recommendations for the structure and organization of the proposed rule. A commenter recommended that CMS specify the 17 providers and supplier types to which the rule would apply in the first part of the rule, so that facilities could verify whether or not the regulations would apply to them. A few commenters suggested that the requirements of the proposed rule should not be included in the CoPs, but instead comprise a separate regulatory chapter specific to emergency preparedness. Response: We included a list of the provider and supplier types affected by the emergency preparedness requirements in the proposed rule’s Table of Contents (78 FR 79083 through 79084) and in the preamble text 78 FR 79090. Thus, we believe that we clearly listed the affected providers and suppliers at the very beginning of the proposed rule. We also believe the emergency preparedness requirements should be included in the CoPs for providers, the CfCs for suppliers, and requirements for LTC facilities. These CoPs, CfCs, and requirements for LTC facilities are intended to protect public health and safety and ensure that high quality care is provided to all persons. Facilities must meet their respective CoPs, CfCs, or requirements in order to participate in the Medicare and Medicaid programs. We are able to enforce and monitor compliance with the CoPs, CfCs, and requirements for LTC facilities through the survey process. Therefore, we believe that the emergency preparedness requirements are included in the most appropriate regulatory chapters. Comment: A few commenters suggested additional citations for the proposed rule, recommended that we include specific reference material, and suggested edits to the preamble language. A commenter stated that we omitted some references in the preamble discussion of the proposed rule. The VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 commenter noted that while we included references to HSPD 5, 21, and 8 in the proposed rule, the commenter recommended that all of the HSPDs should have been included. Furthermore, the commenter noted that HSPD 7 in particular, which does not provide a specific role for HHS, should have been referenced since it includes discussion of critical infrastructure protection and the role it plays in allhazards mitigation. A commenter suggested that we add the following text to section II.B.1.a. of the proposed rule (78 FR 79085): ‘‘HSPD–21 tasked the establishment of the National Center for Disaster Medicine and Public Health (http:// ncdmph.usuhs.edu) as an academic center of excellence at the Uniformed Services University of the Health Sciences to lead federal efforts in developing and propagating core curricula, training, and research in disaster health.’’ A commenter recommended that we include the Joint Guidelines for Care of Children in the Emergency Department, developed by the American Academy of Pediatrics, the American College of Emergency Physicians, and the Emergency Nurses Association, as a resource for the final rule. A commenter suggested the addition of the phrase ‘‘private critical infrastructure’’ to the following statement on page 79086 of the proposed rule: ‘‘The Stafford Act authorizes the President to provide financial and other assistance to state and local governments, certain private nonprofit organizations, and individuals to support response, recovery, and mitigation efforts.’’ A commenter included several articles and referenced documentation on emergency preparedness and proper management and disposal of medical waste materials, while another recommended that CMS reference specific FEMA reference documents. Another commenter referred CMS to the Comprehensive Preparedness Guidelines 101 Template, although the commenter did not specify the source of this template. Response: We thank the commenters for their recommended edits throughout the document. The editorial suggestions are appreciated and noted. We also want to thank commenters for their recommendations for additional resources on emergency preparedness. We provided an extensive list of resources in the proposed and have included links to various resources in this final rule that facilities can use as resources during the development of their emergency preparedness plans. PO 00000 Frm 00009 Fmt 4701 Sfmt 4700 63867 However, we note that these lists are not comprehensive, since we intend to allow facilities flexibility as they implement the emergency preparedness requirements. We encourage facilities to use any resources that they find helpful as they implement the emergency preparedness requirements. Omissions from the list of resources set out in the proposed rule do not indicate any intention on our part to exclude other resources from use by facilities. Comment: A commenter stated that the local emergency management and public health authorities are the bestplaced entities to coordinate their communities’ disaster preparedness and response, collaborating with hospitals as instrumental partners in this effort. Response: We stated in the proposed rule that local emergency management and public health authorities play a very important role in coordinating their community’s disaster preparedness and response activities. We proposed that each hospital develop an emergency plan that includes a process for ensuring cooperation and collaboration with local, tribal, regional, state and federal emergency preparedness officials’ efforts to ensure an integrated response during a disaster or emergency situation. We also proposed that hospitals participate in community mock disaster drills. As noted in the proposed rule, we believe that community-wide coordination during a disaster is vital to a community’s ability to maintain continuity of healthcare for the patient population during and after a disaster or emergency. Comment: A few commenters were concerned about the exclusion of specific requirements to account for the health and safety of healthcare workers. A commenter, in reference to pediatric healthcare, recommended that we consider adding a behavioral healthcare provision to the emergency preparedness requirements, which would account for the professional selfcare needs of healthcare providers. Another commenter suggested that we change the language on page 79092 of the proposed rule to include 5 phases of emergency management, with the addition of the phrase ‘‘protection of the safety and security of occupants in the facility.’’ Another commenter recommended that we include occupational health and safety elements in the four proposed emergency preparedness standards. Furthermore, the commenter recommended that we consult with the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the Worker Education and Training Program E:\FR\FM\16SER2.SGM 16SER2 63868 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations mstockstill on DSK3G9T082PROD with RULES2 of the National Institute for Environmental Health Sciences (NIEHS) for more information on integrating worker health and safety protections into emergency planning. Response: While we believe that providers should prioritize the health and safety of their healthcare workers during an emergency, we do not believe that it is appropriate to include detailed requirements within this regulation. As we have previously stated, the regulation is not intended to be overly prescriptive. Therefore, providers have the discretion to establish policies and procedures in their emergency preparedness plans that meet the minimum requirements in this regulation and that are tailored to the specific needs and circumstances of the facility. We note that providers should continue to comply with pertinent federal, state, or local laws regarding the protection of healthcare workers in the workplace. While it is not within the scope of this rule to address OSHA, NIOSH, or NIEHS work place regulations, we encourage providers and suppliers to consider developing policies and procedures to protect healthcare workers during an emergency. We refer readers to the following list of resources to aid providers and suppliers in the formulation of such policies and procedures: • https://www.osha.gov/SLTC/ emergencypreparedness/ • http://www.cdc.gov/niosh/topics/ emergency.html • http://www.niehs.nih.gov/health/ topics/population/occupational/ index.cfm Comment: A few commenters noted that while section 1135 of the Act waives certain Conditions of Participation (CoPs) during a public health emergency, there is no authority to waive the Conditions for Payment (CfPs). The commenters recommended that the Secretary thoroughly review the requirements under the CoPs and the CfPs and seek authority from Congress to waive additional requirements under the CfPs that are burdensome and that affect timely access to care during emergencies. Response: While we appreciate the concerns of the commenters, these comments are outside the scope of this rule. 1. Integrated Health Systems In the proposed rule, we proposed that for each separately certified healthcare facility to have an emergency preparedness program that includes an emergency plan, based on a risk VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 assessment that utilizes an all hazards approach, policies and procedures, a communication plan, and a training program. Comment: We received a few comments that suggested we allow integrated health systems to have one coordinated emergency preparedness program for the entire system. Commenters explained that an integrated health system could be comprised of two nearby hospitals, a LTC facility, a HHA, and a hospice. The commenters stated that under our proposed regulation, each entity would need to develop an individual emergency preparedness program in order to be in compliance. Commenters proposed that we allow for the development of one universal emergency preparedness program that encompasses one community-based risk assessment, separate facility-based risk assessments, integrated policies and procedures that meet the requirements for each facility, and coordinated communication plans, training and testing. They noted that allowing for a coordinated emergency preparedness program would ultimately reduce the burden placed on the individual facilities and provide for a more coordinated response during an emergency. Response: We appreciate the comments received on this issue. We agree that allowing integrated health systems to have a coordinated emergency preparedness program is in the best interest of the facilities and patients that comprise a health system. Therefore, we are revising the proposed requirements by adding a separate standard to the provisions applicable to each provider and supplier type. This separate standard will allow any separately certified healthcare facility that operates within a healthcare system to elect to be a part of the healthcare system’s unified emergency preparedness program. If a healthcare system elects to have a unified emergency preparedness program, this integrated program must demonstrate that each separately certified facility within the system actively participated in the development of the program. In addition, each separately certified facility must be capable of demonstrating that they can effectively implement the emergency preparedness program and demonstrate compliance with its requirements at the facility level. As always, each facility will be surveyed individually and will need to demonstrate compliance. Therefore, the unified program will also need to be developed and maintained in a manner PO 00000 Frm 00010 Fmt 4701 Sfmt 4700 that takes into account the unique circumstances, patient populations, and services offered for each facility within the system. For example, for a unified plan covering both a hospital and a LTC facility, the emergency plan must account for the residents in the LTC facility as well as those patients within a hospital, while taking into consideration the difference in services that are provided at a LTC facility and a hospital. In addition, the healthcare system will need to take into account the resources each facility within the system has and any state laws that the facility must adhere to. The unified emergency preparedness program must also include a documented community– based risk assessment and an individual facility-based risk assessment for each separately certified facility within the health system, both utilizing an allhazards approach. The unified program must also include integrated policies and procedures that meet the emergency preparedness requirements specific to each provider type as set forth in their individual set of regulations. Lastly, the unified program must have a coordinated communication plan and training and testing program. We believe that this approach will allow a healthcare system to spread the cost associated with training and offer a financial advantage to each of the facilities within a system. In addition, we believe that, in some cases this approach will provide flexibility and could potentially result in a more coordinated response during an emergency that will enable a more successful outcome. 2. Requests for Technical Assistance and Funding The December 2013 proposed rule included an appendix of the numerous resources and documents used to develop the proposed rule. Specifically, the appendix to the proposed rule included helpful reports, toolkits, and samples from multiple government agencies such as ASPR, the CDC, FEMA, HRSA, AHRQ, and the Institute of Medicine (See Appendix A, 78 FR 79198). In response to our proposed rule, we received numerous comments requesting that we provide facilities with increased funding and technical assistance to implement our proposed regulations. Comment: A few commenters appreciated the resources that we provided in the proposed rule, but expressed concerns that, despite the resources referenced in the regulation, busy and resource-constrained facilities will not have a simple and organized way to access technical assistance and E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations other valuable information in order to comply with the proposed requirements. Commenters indicated that despite the success of healthcare coalitions, they have not been established in every region. Commenters suggested that formal technical assistance should be available to facilities to help them successfully implement their emergency preparedness requirements. A commenter recommended that ASPR should lead this effort given its expertise in emergency preparedness planning and its charge to lead the nation in preventing, preparing for, and responding to the adverse health effects of public health emergencies. Another commenter suggested that we consider hosting regional meetings for facilities to share information and resources and that we provide region specific resources on our Web site. Commenters encouraged CMS to promote collaborative planning among facilities and provide the support needed for facilities to leverage each other’s resources. These commenters believe that networks of facilities will be in a better position than governmental resources to identify cost and time saving efficiencies, but need support from CMS to coordinate their efforts. Response: We appreciate the feedback from commenters and understand how valuable guidance and resources will be to providers and suppliers in order to comply with this regulation. We do not anticipate providing formal technical assistance, such as CMS-led trainings, to providers and suppliers. Instead, as with all of our regulations, we will release interpretive guidance for this regulation that will aid facilities in implementing these regulations and provide information regarding best practices. We strongly encourage facilities to review the interpretative guidance from us, use the guidance to identify best practices, and then network with other facilities to develop strategic plans. Providers and suppliers impacted by this regulation should collaborate and leverage resources in developing emergency preparedness programs to identify cost and time saving efficiencies. We note that in this final rule we have revised the proposed requirements to allow integrated health systems to elect to have one unified emergency preparedness program (see Section II.A.1.Intergrated Health Systems for a detailed discussion of the requirement). We believe that collaborative planning will not only leverage the financial burden on facilities, but also result in a more coordinated response to an emergency event. VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 In addition, we note that in the proposed rule, we indicated numerous resources related to emergency preparedness, including helpful reports, toolkits, and samples from ASPR, the CDC, FEMA, HRSA, AHRQ, and the Institute of Medicine (See Appendix A, 78 FR 79198). Providers and suppliers should use these many resources as templates and the framework for getting their emergency preparedness programs started. We also refer readers to SAMHSA’s Disaster Technical Assistance Center (DTAC) for more information on delivering an effective mental health and substance abuse (behavioral health) response to disasters at http://www.samhsa.gov/dtac/. Finally we note that ASPR, as a leader in healthcare system preparedness, developed and launched the Technical Resources, Assistance Center, and Information Exchange (TRACIE). TRACIE is designed to provide resources and technical assistance to healthcare system preparedness stakeholders in building a resilient healthcare system. There are numerous products and resources located within the TRACIE Web site that target specific provider types affected by this rule. While TRACIE does not focus specifically on the requirements implemented in this regulation, this is a valuable resource to aid a wide spectrum of partners with their health system emergency preparedness activities. We strongly encourage providers and suppliers to utilize TRACIE and leverage the information provided by ASPR. Comment: Some commenters noted that their region is currently experiencing a reduction in the federal funding they receive through the HPP. These commenters stated that the HPP program has proven to be successful and encouraged healthcare entities impacted by this regulation to engage their state HPP for technical assistance and training while developing their emergency preparedness programs. Commenters shared that HPP staff have established trusting and fundamental relationships with facilities, associations, and emergency managers throughout their state. Commenters expressed that while the program has been instrumental in supporting their state’s healthcare emergency response, it does not make sense to impose these new emergency preparedness regulations while financial resources through the HPP are diminishing. Commenters stressed that the HPP program alone cannot support the rollout of these new regulations and emphasized that a strong and wellfunded HHP program is needed to PO 00000 Frm 00011 Fmt 4701 Sfmt 4700 63869 contribute to the successful implementation of these new requirements. Commenters also suggested that CMS offer training to the states’ HPP programs, so that these agencies can remain in a central leadership role within their states. Response: We appreciate the feedback and agree that the HPP program has been a fundamental resource for developing healthcare emergency preparedness programs. While we recognize that HPP funding is limited, we want to emphasize that the HPP program is not intended to solely fund a facility’s individual emergency preparedness program and activities. Despite the limited financial resources, healthcare facilities should continue to engage their healthcare coalitions and state HPP coordinators for training and guidance. We encourage healthcare facilities, particularly those in neighboring geographic areas, to collaborate and build relationships that will allow facilities to share and leverage resources. Comment: A few commenters noted that, while these new emergency preparedness regulations should be put in place to protect vulnerable communities, there should also be incentives to help facilities meet these new standards. Many commenters expressed concerns about the decrease in funding available to state and local governments. Most commenters recommended that grant funding and loan programs be provided to support hiring staff to develop or modify emergency plans. However, a few commenters suggested that federal funding should be allocated to the nation’s most vulnerable counties. These commenters believe that special federal funding consideration should not be provided to all, but rather should be given to those counties and cities with a uniquely dense population. A commenter believed that incentives should be put in place to reward those facilities that are found compliant with the new standards. In addition, several commenters requested that CMS provide additional Medicare payment to providers and suppliers for implementing these emergency preparedness requirements. Response: We currently expect facilities to have and develop policies and procedures for patient care and the overall operations. The emergency preparedness requirement may increase costs in the short term because resources will have to be devoted to the assessment and development of an emergency plan utilizing an all-hazards approach. While the requirements could result in some immediate costs to a E:\FR\FM\16SER2.SGM 16SER2 63870 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations provider or supplier, we believe that developing an emergency preparedness program will overall be beneficial to any provider or supplier. In addition, planning for the protection and care of patients, clients, residents, and staff during an emergency or a disaster is a good business practice. As we have previously noted, CMS has the authority to create and modify health and safety CoPs, which establish the requirements that a provider must meet in order to participate in the Medicare or Medicaid programs. mstockstill on DSK3G9T082PROD with RULES2 3. Requirement To Track Patients and Staff In the proposed rule, we requested comments on the feasibility of tracking staff and patients in outpatient facilities. Comment: Overall commenters agreed that there is not a crucial need for outpatient facilities to track their patients as compared to inpatient facilities. Commenters noted that outpatient providers and suppliers would most likely close their facilities prior to or immediately after an emergency, sending staff and patients home. We did not propose the tracking requirement for transplant centers, CORFs, Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services, and RHCs/FQHCs. For OPOs we proposed that they would only need to track staff. We stated that transplant centers’ patients and OPOs’ potential donors would be in hospitals, and thus, would be the hospital’s responsibility. Response: We agree with the majority of commenters and continue to believe that it is impractical for outpatient providers and suppliers to track patients and staff during and after an emergency. In the event of an emergency outpatient providers and suppliers will have the flexibility to cancel appointments and close their facilities. Therefore, we are finalizing the rule as proposed. Specifically, we do not require transplant centers, RHCs/FQHCs, CORFs, Clinics, Rehabilitation Agencies, and Public Health Agencies as providers of Outpatient Physical Therapy and Speech-Language Pathology Services to track their patients and staffs. We are also finalizing our proposal for OPOs to track staff only both during and after an emergency. A detailed discussion of comments specific to OPOs tracking staff can be found in section II.Q. of this final rule (Emergency Preparedness Regulations for Organ Procurement Organizations). VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 Comment: In addition to the feedback we received on whether we should require outpatient providers and suppliers to track their patients and staff, we also received varying comments in regards to the providers and suppliers that we did propose to meet the tracking requirement.Commenters supported the proposal for certain providers and suppliers to track staff and patients, and agreed that a system is needed. Some understood that the information about staff and patient location would be needed during an emergency, but stated that it would be burdensome and often unrealistic to expect providers and suppliers to locate individuals after an emergency event. Some commenters noted that patients at a receiving facility would be the responsibility of the receiving facility. Some commenters stated that tracking of patients going home is not their responsibility, or would be difficult to achieve. A commenter believed that tracking of staff would be a violation of staff’s privacy. A commenter stated that in their large facility, only the ‘‘staff on duty’’ at the time of the emergency would be in their staffing system. Some commenters stated that staff would be difficult to track because some facilities have hundreds or thousands of employees, and some staff may have left to be with their families. Some commenters suggested that CMS promote the use of voluntary registries to help track their outpatient populations and encouraged coordination of these registries among facility types. A few commenters stated that one of the tools discussed in the preamble for tracking patients; namely, The Joint Patient Assessment and Tracking System (JPATS) was only available for hospitals and did not include other providers such as LTC facilities, and several stated the system is incompatible with their IT systems. Response: For RNHCIs, PRTFs, PACE organizations, LTC facilities, ICFs/IID, hospitals, and CAHs, we proposed that these providers develop policies and procedures regarding a system to track the location of staff and patients in the hospital’s care both during and after an emergency. Despite providing services on an outpatient basis, we also proposed to require hospices, HHAs, and ESRD facilities to assume this responsibility because these providers and suppliers would be required to provide continuing patient care during an emergency. We also proposed the tracking requirement for ASCs because we believed an ASC would maintain PO 00000 Frm 00012 Fmt 4701 Sfmt 4700 responsibility for their staff and patients if patients were in the facility. After carefully analyzing the issues raised by commenters regarding the process to track staff and patients during and after an emergency, we agree with the commenters that our proposed requirements could be unnecessarily burdensome. We are revising the tracking requirements based on the type of facility. For CAHs, Hospitals, and RNHCIs we are removing the proposed requirement for tracking after an emergency. Instead, in this final rule we require that these facilities must document the specific name and location of the receiving facility or other location for patients who leave the facility during the emergency. We would expect facilities to track their onduty staff and sheltered patients during an emergency and indicate where a patient is relocated to during an emergency (that is, to another facility, home, or alternate means of shelter, etc.). Also, since providers and suppliers are required to conduct a risk assessment and develop strategies for addressing emergency events identified by the risk assessment, we would expect the facility to include in its emergency plan a method for contacting off-duty staff during an emergency and procedures to address other contingencies in the event staff are not able to report to duty which may include but are not limited to staff from other facilities and state or federallydesignated health professionals. For PRTFs, LTC facilities, ICF/IIDs, PACE organizations, CMHCs, and ESRD facilities we are finalizing as proposed the requirement to track staff and patients both during and after an emergency. We have clarified that the requirement applies to tracking on-duty staff and sheltered patients. Furthermore, we clarify that if on-duty staff and sheltered patients are relocated during the emergency, the provider or supplier must document the specific name and location of the receiving facility or other location. Unlike inpatient facilities, PRTFs, ICF/IIDs, and LTC facilities are residential facilities and serve as the patient’s home, which is why in these settings we refer to the patients as ‘‘residents.’’ Similar to these residential facilities ESRD facilities, CMHCs, and PACE organizations, provide a continuum of care for their patients. Residents and patients of these facilities would anticipate returning to these facilities after an emergency. For this reason, we believe that it is imperative for these facilities to know where their residents/patients and staff are located during and after the E:\FR\FM\16SER2.SGM 16SER2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations mstockstill on DSK3G9T082PROD with RULES2 emergency to allow for repatriation and the continuation of regularly scheduled appointments. While we pointed out JPATS as a tool for providers and suppliers, we note that we indicated that we were not proposing a specific type of tracking system that providers and suppliers must use. We also indicated that in the proposed rule that a number of states have tracking systems in place or under development and the systems are available for use by healthcare providers and suppliers. We encourage providers and suppliers to leverage the support and resources available to them through local and national healthcare systems, healthcare coalitions, and healthcare organizations for resources and tools for tracking patients. We have also reviewed our proposal to require ASCs, hospices, and HHAs to track their staff and patients before and after an emergency. We discuss in detail the comments we received specific to these providers and suppliers and revisions to their proposed tracking requirement in their specific section later in this final rule. B. Implementation Date We proposed several variations on an implementation date for the emergency preparedness requirements (78 FR 79179). Regarding the implementation date, we requested information on the following issues: • A targeted approach to emergency preparedness that would apply the rule to one provider or supplier type or a subset of provider types, to learn from implementation prior to requiring compliance for all 17 types of providers and suppliers. • A phased-in approach that would implement the requirements over a longer time horizon, or differential time horizons for the different provider and supplier types. Comment: Most commenters recommended that CMS set a later implementation date for the emergency preparedness requirements. Some commenters recommended that we use a targeted approach, whereby the rule would be implemented first by one provider/supplier type or a subset of provider/supplier types, with later implementation by other provider/ supplier types, so they can learn from prior implementation at other facilities. Others recommended that CMS phase in the requirements over a longer time horizon. Many commenters recommended that CMS require implementation at hospitals or LTC facilities first, so that other facilities could benefit from the experience and lessons learned by these VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 providers. Some of these commenters stated that these providers have the most capacity to implement these requirements. A commenter recommended that hospitals implement the requirements of the rule first, followed by CAHs and other inpatient provider types and LTC facilities. Other provider and supplier types would follow thereafter. The commenter recommended that CMS establish a period of non-enforcement for each implementation phase, while a Phase 1 evaluation is conducted and feedback is given to other facilities. Several commenters, including major hospital associations, disagreed with CMS’ proposal to implement all of the requirements 1 year after the final rule is published. The commenters noted that implementation of all the requirements after 1 year would be burdensome and costly to many facilities. In addition, a few commenters noted that certain facilities, mainly rural and small facilities, may be at a disadvantage because they have not participated in national emergency preparedness planning efforts or because they lack the necessary resources to implement emergency preparedness plans. A few commenters drew a distinction between accredited and non-accredited facilities and recommended that hospitals implement the requirements within a year or 2 after publication of the final rule. Some of the commenters noted that non-accredited facilities, CAHs, HHAs, and hospices, would need more time. Several of these commenters also stated that hospitals that need more time for implementation should be able to propose to CMS a reasonable period of time to comply. A few commenters stated that the emergency preparedness proposal is unlike the standards utilized by the TJC and that enforcement of these requirements should be at a later date for both accredited and non-accredited facilities. Some commenters recommended that CMS give ASCs and FQHCs additional time to come into compliance. A commenter recommended that CMS set a later implementation date for the requirements and provide a flexible implementation timeframe based on provider type and resources. A few commenters stated that the implementation timeline is too short for rehabilitation facilities, long-term acute care facilities, LTC facilities, behavioral health inpatient facilities, and ICF/IIDs. A few commenters recommended that CMS phase-in implementation on a standard-by-standard basis. A commenter recommended that LTC facilities implement the requirements 12 PO 00000 Frm 00013 Fmt 4701 Sfmt 4700 63871 to 18 months after hospitals. Furthermore, the commenter recommended an 18 to 24 month phasein of emergency systems and a 24 to 38 month phase-in for the training and testing requirements. Another commenter recommended that facilities be allowed to comply with the initial planning requirements within 2 years, and then be allowed to comply with the subsistence and infrastructure requirements in years 3 and 4. The commenters varied in their recommendations on the timeframe CMS should use for the implementation date. These recommendations ranged from 6 months to 5 years, with a few commenters recommending even longer periods. Some commenters noted that applying a targeted approach, covering one or a subset of provider classes to learn from implementation prior to extending the rule to all groups, would also allow a longer period of time for other provider/supplier types to prepare for implementation. Furthermore, a commenter noted that a phased in approach would help to alleviate the cost burden on facilities that would need to create an emergency plan and train and test staff. Response: We appreciate the commenters’ feedback. We considered a phased-in approach in a number of ways. We looked at phasing in the implementation of various providers and suppliers; and phasing in the various standards of the regulation. We concluded that this approach would be too difficult to implement, enforce, and evaluate. Also, this would not allow communities to have a comprehensive approach to emergency preparedness. However, we agree that there should be a later implementation date for the emergency preparedness requirements. However, we do not believe that a targeted or phased-in approach to implementation is appropriate. One thing we proposed and are now finalizing to address this concern is extending the implementation timeframe for the requirements to 1 year after the effective date of this final rule (see section section II, Provisions of the Proposed Rule and Responses to Public Comments, part B, Implementation Date). We believe it is imperative that each provider thinks in terms broader than their own facility, and plan for how they would serve similar and other healthcare facilities as well as the whole community during and surrounding an emergency event. To encourage providers to develop a comprehensive and coordinated approach to emergency preparedness, all providers need to adopt the requirements in this final rule at the same time. E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 63872 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations Commenters have stated that hospitals that are TJC-accredited are part of the Hospital Preparedness Program (HPP) program, and those hospitals that follow National Fire Protection Association (NFPA®) standards, have already established most of the emergency preparedness requirements set out in this rule. Based on CDC’s National Health Statistics Reports; Number 37, March 24, 2011, page 2 (NCHS–2008PanFluand EP_NHAMCSSurveyReport_2011.pdf), about 67.9 percent of hospitals had plans for all six hazards (epidemicpandemic, biological, chemical, nuclearradiological, explosive-incendiary, and natural incidents). Nearly all hospitals (99.0 percent) had emergency response plans that specifically addressed chemical accidents or attacks, which were not significantly different from the prevalence of plans for natural disasters (97.8 percent), epidemics or pandemics (94.1 percent), and biological accidents or attacks. However, we also believe that other facilities will be ready to begin implementation of these rules at the same time as hospitals. We believe that most facilities already have some basic emergency preparedness requirements that can be built upon to meet the requirements set out in this final rule. We note that we have modified or eliminated some of our proposed requirements for certain providers and suppliers, as discussed later in this final rule, which should ease concerns about implementation. Therefore, we believe that all affected providers and suppliers will be able to comply with these requirements 1 year after the final rule is published. We do not believe a period of nonenforcement is appropriate as it will further prolong the implementation of necessary and life-saving emergency preparedness planning requirements by facilities. A later implementation date will leave the most vulnerable patient populations and unprepared facilities without a valuable, life-saving emergency preparedness plan should an emergency arise. We have not received comments that persuaded us that a later implementation date for these requirements of more than 1 year is beneficial or appropriate for providers and suppliers or their patients. In response to commenters that opposed our proposal to implement the requirements 1 year after the final rule was published and recommended that we afford facilities more time to implement the requirements, we do not believe that the requirements will be overly burdensome or overly costly to providers and suppliers. We note, as we have heard from many commenters, that VerDate Sep2014 19:01 Sep 15, 2016 Jkt 238001 many facilities already have established emergency preparedness plans, as required by accrediting organizations. However, we acknowledge that there may be a significant amount of work that small facilities and those with limited resources will need to undertake to establish an emergency preparedness plan that conforms to the requirements set out in this regulation. However, we believe that prolonging the requirements in this final rule by 1 year will provide sufficient time for implementation among the various facilities to meet the emergency preparedness requirements. We encourage facilities to engage and collaborate with their local partners and healthcare coalitions in their area for assistance. Facilities may also access ASPR’s TRACIE web portal, which is a healthcare emergency preparedness information gateway that helps stakeholders at the federal, state, local, tribal, non-profit, and for-profit levels have access to information and resources to improve preparedness, response, recovery, and mitigation efforts. ASPR TRACIE, located at: https://asprtracie.hhs.gov/, is an excellent resource for the various CMS providers and suppliers as they seek to implement the enhanced emergency preparedness requirements. We encourage facilities to engage and collaborate with their local partners and healthcare coalitions in their area for technical assistance as they include local experts and can provide regional information that can inform the requirements as set forth. Comment: Some commenters recommended that CMS implement all of the emergency preparedness requirements 1 year after the final rule is published. Other commenters recommended that CMS implement the requirements as soon as the final rule is published or set an implementation date that is less than 1 year from the effective date of this final rule. A few of these commenters, including a major beneficiary advocacy group, stated that implementation should begin as soon as practicable, or immediately after the final rule is published and cautioned against a later implementation date that may leave facilities without important emergency preparedness plans during an emergency. Some of these commenters stated that hospitals in particular already have emergency preparedness plans in place and are well equipped and prepared to implement the requirements set out in these regulations over the course of a year. Some commenters noted that most hospitals are fully aware of the 4 emergency preparedness requirements set out in the proposed rule through PO 00000 Frm 00014 Fmt 4701 Sfmt 4700 current accreditation standards. Furthermore, the commenters noted that these four requirements would not impose any additional burdens on hospitals. A few commenters acknowledged that some hospitals are not under the purview of an accrediting agency and therefore may need up to 1 year to implement the requirements. Response: We appreciate the commenters’ feedback. We agree with the commenters’ view that implementation of the requirements should occur 1 year after the final rule is published for all 17 types of providers and suppliers. We believe that an implementation date for these requirements that is 1 year after the effective date of this final rule will allow all facilities to develop an emergency preparedness plan that meets all of the requirements set out within these regulations. While we understand why some commenters would want these requirements to be implemented shortly after publication of the final rule, we also understand some commenters’ concerns about that timeframe. We believe that facilities will need a period of time after the final rule is published to plan, develop, and implement the emergency preparedness requirements in the final rule. Accordingly, we believe that 1 year is a sufficient amount of time for facilities to meet these requirements. Comment: A few commenters recommended that CMS include a provision that would allow facilities to apply for additional time extensions or waivers for implementation. A commenter recommended that CMS allow facilities to rely on their existing policies if the facility can demonstrate that the existing policies align with the emergency preparedness plan requirements and achieve a similar outcome. Response: We do not agree with including a provision that will allow for facilities to apply for extensions or waivers to the emergency preparedness requirements. We believe that an implementation date that is beyond 1 year after the effective date of this final rule for these requirements is inappropriate and leaves the most vulnerable facilities and patient populations without life-saving emergency preparedness plans. However, we do understand that some facilities, especially smaller and more rural facilities, may experience difficulties developing their emergency preparedness plans. Therefore, we believe that setting an implementation date of 1 year after the effective date of this final rule for these requirements will give these and other facilities E:\FR\FM\16SER2.SGM 16SER2 mstockstill on DSK3G9T082PROD with RULES2 Federal Register / Vol. 81, No. 180 / Friday, September 16, 2016 / Rules and Regulations sufficient time for compliance. As stated earlier, we encourage facilities to form coalitions in their area for assistance in meeting these requirements. We also encourage facilities to utilize the many resources we have included in the proposed and final rule. We appreciate that some facilities have existing emergency preparedness plans. However, all facilities will be required to develop and maintain an emergency preparedness plan based on an all-hazards approach and address the four major elements of emergency preparedness in their plan that we have identified in this final rule. Each facility will be required to evaluate its current emergency preparedness plan and activities to ensure that it complies with the new requirements. Comment: A few commenters recommended that CMS implement enforcement of the final rule when the interpretive guidance (IG) is finalized by CMS. A few commenters noted that this implementation data should include a period of engagement with hospitals and other providers and suppliers, a period to allow for the development and testing of surveyor tools, and a readiness review of state survey agencies that is complete and publicly available. A commenter recommended that facilities implement the requirements 5 years after the IGs have been published. Another commenter recommended that CMS phase-in implementation in terms of enforcement and roll out, allowing time for full implementation and assistance to facilities and state surveyors. A few commenters recommended that providers be allowed a period of time where they are held harmless during a transitional planning period, where providers may be allotted more time to plan and implement the emergency preparedness requirements. Response: We disagree with the…
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Discuss the process of health policymaking

Discuss the process of health policymaking

select any (proposed or enacted) public health policy. In two or three paragraphs discuss a few of the dimensions of the policymaking process as they relate to your chosen policy. In addition, I would like you to address specifically the roles of both ethics and evidence in the process. (Be sure to select a “public” health policy and not one enacted by a private organization. For example, one legislated by the US Congress, the FDA, CDC, HHS, CMS, etc.)

I chose New York’s recently changed abortion law. Here is my essay below.

The New York state Department stated that “maternal mortality rate has increased in the last decade from 13.3 per 100,000 live births in 2006, to 25 per 100,000 live births in 2015.” The vast majority of these deaths were caused by abortions that were done illegally in unsafe conditions. [a1] The alarming increase has prompted the Governor of New York to look closer into this epidemic and the concerning rise in the statistical numbers. One way to combat the rise in maternal mortality rate, the Governor enacted a new abortion law, that allowed mothers to have legal and safe abortions past the 24-week mark; if the mother and or infant’s health is at risk. [a2] This is a way for those parents who find out later in their pregnancy, that the child may not be viable and or has a birth defect that hinders the parent and or child emotionally, they will have the proper and safe channels to terminate the pregnancy.

This new law was adopted, but with hesitation and a large amount of push back. NYCLU Executive Director Donna Lieberman stated “Today, New York State took a historic vote to protect women’s rights and autonomy. The Reproductive Health Act recognizes reproductive health care as a fundamental right. It takes abortion out of the criminal code and puts it where women’s health belongs — in the public health law. It recognizes the range of medical professionals that women can turn to, expanding access to early care.” This was a phenomenal win for those who have advocated for women’s rights. The uphill battle has given women more control over their reproductive choice. In contrast, if a woman is attacked by an assailant and lose the baby as a result, the perpetrator wouldn’t be criminalized for the death of the child, because the death of an unborn child has been removed from the criminal penal code. Another issue that arises from this new policy is the Hippocratic oath, this oath states “do no harm”, it is one oath that many doctors, physicians and nurses take as they begin their career as caretakers. If a woman wants a late term abortion even though the mother and child are healthy and viable, but the mother feels as if she has a health issue that may hinder her from providing for the child, would the doctor be held liable for harming a child who is able to live outside the womb?

Although on the surface, this new policy shows great potential and progression, there are a lot of underlying factors that may arise and cause it to fail. This new policy is so new that we have yet to see the ramifications of its implementation, therefor we are unable to assess whether or not it was a good decision. Ruth Ginsbrg said “ the emphasis must be no on the right to abortion but on the right to privacy and reproductive control.”, and that exactly what this law is trying to do.


Grading Rubric

A specific health policy or program was selected and details provided (10pts possible): 10 points received

Were at least 2 dimensions of the policymaking process identified (20pts possible): 0 points received

Was it made clear how these aspects of the policymaking process were related to the chosen policy (10pts possible): 0 points received

Was the role of ethics discussed in relation to the policymaking process for this health policy/program with some specificity (5pts possible): 0 points received

Was the role of evidence discussed in relation to the po

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licymaking process for this health policy/program with some specificity (5pts possible): 0 points received

Comments: Here are his recommendations to fix it.

Very nicely written and you picked a policy with potential. However, the point of this exercise was to objectively “discuss a few of the dimensions of the policymaking processes they relate to your chosen policy.” These were covered in the video lecture. In the future, please carefully read the instructions because all exercises and exams will be graded similarly.

You lost a lot of points since what you wrote wasn’t focused on the policymaking process. However, for this first assignment I am letting students go back and make changes/additions to their submissions if they did poorly. Please email me your updated document by the end of February if you would like me to re-grade this exercise without any penalty.

Discuss the process of health policymaking

Discuss the process of health policymaking

select any (proposed or enacted) public health policy. In two or three paragraphs discuss a few of the dimensions of the policymaking process as they relate to your chosen policy. In addition, I would like you to address specifically the roles of both ethics and evidence in the process. (Be sure to select a “public” health policy and not one enacted by a private organization. For example, one legislated by the US Congress, the FDA, CDC, HHS, CMS, etc.)

I chose New York’s recently changed abortion law. Here is my essay below.

The New York state Department stated that “maternal mortality rate has increased in the last decade from 13.3 per 100,000 live births in 2006, to 25 per 100,000 live births in 2015.” The vast majority of these deaths were caused by abortions that were done illegally in unsafe conditions. [a1] The alarming increase has prompted the Governor of New York to look closer into this epidemic and the concerning rise in the statistical numbers. One way to combat the rise in maternal mortality rate, the Governor enacted a new abortion law, that allowed mothers to have legal and safe abortions past the 24-week mark; if the mother and or infant’s health is at risk. [a2] This is a way for those parents who find out later in their pregnancy, that the child may not be viable and or has a birth defect that hinders the parent and or child emotionally, they will have the proper and safe channels to terminate the pregnancy.

This new law was adopted, but with hesitation and a large amount of push back. NYCLU Executive Director Donna Lieberman stated “Today, New York State took a historic vote to protect women’s rights and autonomy. The Reproductive Health Act recognizes reproductive health care as a fundamental right. It takes abortion out of the criminal code and puts it where women’s health belongs — in the public health law. It recognizes the range of medical professionals that women can turn to, expanding access to early care.” This was a phenomenal win for those who have advocated for women’s rights. The uphill battle has given women more control over their reproductive choice. In contrast, if a woman is attacked by an assailant and lose the baby as a result, the perpetrator wouldn’t be criminalized for the death of the child, because the death of an unborn child has been removed from the criminal penal code. Another issue that arises from this new policy is the Hippocratic oath, this oath states “do no harm”, it is one oath that many doctors, physicians and nurses take as they begin their career as caretakers. If a woman wants a late term abortion even though the mother and child are healthy and viable, but the mother feels as if she has a health issue that may hinder her from providing for the child, would the doctor be held liable for harming a child who is able to live outside the womb?

Although on the surface, this new policy shows great potential and progression, there are a lot of underlying factors that may arise and cause it to fail. This new policy is so new that we have yet to see the ramifications of its implementation, therefor we are unable to assess whether or not it was a good decision. Ruth Ginsbrg said “ the emphasis must be no on the right to abortion but on the right to privacy and reproductive control.”, and that exactly what this law is trying to do.


Grading Rubric

A specific health policy or program was selected and details provided (10pts possible): 10 points received

Were at least 2 dimensions of the policymaking process identified (20pts possible): 0 points received

Was it made clear how these aspects of the policymaking process were related to the chosen policy (10pts possible): 0 points received

Was the role of ethics discussed in relation to the policymaking process for this health policy/program with some specificity (5pts possible): 0 points received

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Was the role of evidence discussed in relation to the policymaking process for this health policy/program with some specificity (5pts possible): 0 points received

Comments: Here are his recommendations to fix it.

Very nicely written and you picked a policy with potential. However, the point of this exercise was to objectively “discuss a few of the dimensions of the policymaking processes they relate to your chosen policy.” These were covered in the video lecture. In the future, please carefully read the instructions because all exercises and exams will be graded similarly.

You lost a lot of points since what you wrote wasn’t focused on the policymaking process. However, for this first assignment I am letting students go back and make changes/additions to their submissions if they did poorly. Please email me your updated document by the end of February if you would like me to re-grade this exercise without any penalty.

HCM 481 CSU Global Challenges for Hospitals in Strategic Planning

HCM 481 CSU Global Challenges for Hospitals in Strategic Planning

Scenario: You are the Director of Planning of a mid-size hospital in a suburban market. As the organization continues to move forward and prepare for its annual strategic planning retreat, the CEO has asked you to create a “white paper” (similar to a short research paper) that explains “best practices” in strategic planning. He has asked you to identify the top three challenges that healthcare organizations encounter in the planning process and to identify one method or technique for each challenge that other organizations have used to successfully address these challenges.

The “White Paper” should be well-written and meet the following requirements:

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  • 2 pages (single-spaced) in length
  • Include at least three current references from the peer-reviewed articles
  • Reference list is expected and formatted according to the APA guidelines
  • Here is a resource to help you write a White paper:
  • https://contently.com/strategist/2012/02/10/how-to-write-a-white-paper/ (Links to an external site.)Links to an external site.

 

Tags: health healthcare strategic planning hospitals healthcare management