The Joint Commission Discussion

The Joint Commission Discussion

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.

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

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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.

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

  • 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 Discussio

CMC Rule In Healthcare Emergency Management Discussio

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 C

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FR 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–3178–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

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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.

Healthcare Emergency Manager Core Competencies Assignment

Healthcare Emergency Manager Core Competencies Assignment

Appendix C – Healthcare Emergency Management Competencies Appendix C Healthcare Emergency Management Competencies: Competency Framework Final Report 1 Joseph A. Barbera, MD, Anthony G. Macintyre, MD, Greg Shaw, DSc, Valerie Seefried, MPH, Lissa Westerman, RN, Sergio de Cosmo, MS Institute for Crisis, Disaster, and Risk Management The George Washington University October 11, 2007 Introduction In December 2004, the Veterans

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Health Administration (VHA) Emergency Management Strategic Healthcare Group awarded the Institute for Crisis Disaster & Risk Management (ICDRM) a contract to participate in establishing innovative training and personal development curricula for the VHA Emergency Management Academy (VHA-EMA). The objective of the project was to develop a nationally peer-reviewed, National Incident Management System (NIMS) compliant, competency-based instructional outline and curriculum content upon which to base education and training courses. The curriculum is intended to educate VHA personnel for response and recovery in healthcare emergencies and disasters, to provide a resource for future VHA training programs, and to be placed in the public domain for use by other healthcare personnel. The initial phase of the EMA project consisted of developing a competency framework (competency definition, structure and format, and critical elements) followed by development of peer-reviewed emergency response and recovery competencies for VHAselected healthcare system job groups. The competencies describe knowledge, skills, and abilities essential for adequate job performance during the emergency response and recovery phases of an incident. Peer review was accomplished through a web-based survey of the proposed competencies, which was distributed to a select, nationwide sampling of emergency management personnel who were identified as having extensive experience or advanced expertise in healthcare emergency response. The survey process was designed to obtain a balanced expert opinion as to whether the project team’s written competencies were valid, and to assess the appropriate level of proficiency for each primary competency (i.e., awareness, operations, or expert). The competencies developed during this initial phase were then used to guide the development of learning objectives for the instructional curriculum. 1 This report was supported by Department of Veterans Affairs, Veterans Health Administration contract “Emergency Management Academy Development,” CCN20350A. The report is the work of the authors and does not represent the views of the Department of Veterans Affairs or any of its employees. Institute for Crisis, Disaster and Risk Management The George Washington University 33 Appendix C – Healthcare Emergency Management Competencies An extensive research effort was conducted to understand the historical use of competencies, and to establish objective criteria for competency development. Historical development of competencies Competency modeling originated in business management research, and has evolved extensively over the past 25 years as other disciplines began adopting the practice. 2 The original intent of competency development was to enhance the then common “job analysis” by relating a position’s requisite knowledge, skills and abilities to the overall objectives of the organization in which the position existed. This approach aligns the objectives (i.e., desired outputs) of individual jobs with the overall objectives of the organization, such that organizational objectives are achieved through effective individual job performance. While this was the original intent of competencies, their definition varied widely as time progressed. Competency definitions range from emphasizing underlying characteristics of an employee (e.g., a motive, trait, skill, aspects of one’s self-image, social role, or a body of knowledge) that produce effective and/or superior performance 3 to performance characteristics (i.e., how an employee conducted their job in relation to the organization’s objectives). 4 The application of competencies across the many organizations that use them has also varied widely. The private sector has commonly employed competencies to define “superior performers” 5 and therefore, as a selection tool for hiring, promotion, and/or salary enhancement. In other organizations, competencies have been used for job-specific performance feedback and improvement. Still others have used competencies to guide future program training and development. Because of this variation in definition and application, it becomes critically important to address these vagaries at the outset of any competency development project. This concept was well-described by one competency research team: “The first step in the implementation of any competency-based management framework must be the organizational consensus on how to define ‘competency.’ This agreed upon definition will drive the methodology used to identify and assess the competencies within the organization.” 6 The GWU-ICDRM project team strongly agreed with this concept, and started the project by defining how the competencies within this initiative would be applied: 2 Newsome, Shaun, Victor M Catano, and Arla L. Day. Leader Competencies: Proposing a Research Framework. 2003. available at http://www.cleleadership.ca/paper/leader_competenciesproposing_a_research_framework.pdf 3 Boyatzis, Richard. The Competent Manager: A Model for Effective Performance New York: Wiley, 1982. 4 US Office of Personnel Management. Executive Core Qualifications (ECQ’s), accessed at http://www.opm.gov/ses/ecq.asp 5 Klein AL. Validity and Reliability for Competency-based Systems: Reducing Litigation Risks. Compensation Benefits and Review, 28, 31-37, 1996. cited in “Newsome, Shaun, Victor M Catano, and Arla L. Day. Leader Competencies: Proposing a Research Framework. 2003. 6 Newsome, Shaun, Victor M Catano, and Arla L. Day. Leader Competencies: Proposing a Research Framework. 2003. available at http://www.cleleadership.ca/paper/leader_competenciesproposing_a_research_framework.pdf Institute for Crisis, Disaster and Risk Management The George Washington University 34 Appendix C – Healthcare Emergency Management Competencies The project competencies are intended to serve as formative tools to guide healthcare system personnel in developing knowledge, skills and abilities for effective performance during emergency response and recovery. These competencies are also intended to serve as a guide for developing preparedness education and training, and therefore, to serve as a basis for the healthcare emergency management curriculum. Finally, the competencies may be employed as a tool for assessing the performance of individual healthcare personnel performance during emergency response and recovery operations. Defining a competency framework Despite an extensive search of published articles related to competencies, the GWUICDRM project team determined that no single authoritative source presented a consistent competency definition and competency framework to adequately support the VHA-EMA project needs. A framework was therefore developed, analyzed through pilot competency development, refined and completed before establishing the individual emergency response and recovery competencies for this project. The competency framework was therefore used to impose a strict methodological consistency when developing and defining all competencies developed in this program. Central to this framework is the critical importance of competencies being objective and measurable, internally and externally consistent, and tightly described within the context of the organization’s specific objectives. Within this framework, the project team defined a “competency” as a specific knowledge element, skill, and/or ability that is objective and measurable (i.e., demonstrable) on the job. It is required for effective performance within the context of a job’s responsibilities, and leads to achieving the objectives of the organization. Competencies are ideally qualified by an accompanying proficiency level. 7 The GWU-ICDRM project team recognized the need to adapt the methods for competency development, since the usual business approach to establishing competencies is problematic for emergency management. Business management models establish competencies by observing performance and relating it to individual and organizational outputs. Because emergencies are rare events, and therefore emergency response and recovery outputs occur very infrequently, the related competency framework and definitions for this project are based less upon observed outputs. Instead, the basis is a healthcare system’s emergency response and recovery objectives, together with the NIMS-consistent incident command system 8 structure and processes mandated for use by all emergency response organizations in the U.S. 9,10 7 GWU Institute for Crisis, Disaster and Risk Management. Emergency Management Glossary of Terms (October 2007) available at www.gwu.edu/~icdrm/ 8 Fedral Emergency Management Agency. National Incident Management System (NIMS) (March 1, 2004), available at: http://www.fema.gov/emergency/nims/index.shtm. 9 Bush GW. Homeland Security Presidential Directive (HSPD) -5: Management of Domestic Incidents (February 28, 2003) accessed at http://www.whitehouse.gov/news/releases/2003/02/20030228-9.html Institute for Crisis, Disaster and Risk Management The George Washington University 35 Appendix C – Healthcare Emergency Management Competencies Response competencies in systems using the Incident Command System (ICS), therefore, should be based upon the general incident objectives an organization has during incident response, and upon the organizational structures, processes, and relationships with other organizations that are used during response rather than those used during everyday experience. Emergency competencies are commonly developed without this relationship to a defined response system, 11 making it difficult to define how scientific or medical knowledge is to be implemented in an emergency response. In contrast, the GWUICDRM project team specifically incorporated the NIMS mandate to use ICS by including reference to the NIMS/Incident Command System structure and processes throughout the project’s emergency response and recovery project competencies. Because of the anticipated large number of competencies, the project team also established a “primary versus supporting competency” hierarchy to categorize the individual competencies as they were developed. Designating “primary” and “supporting” competencies helps to maintain a priority in the framework when listing a large number of individual competencies. Supporting competencies are also a means to more fully define and clarify the primary competencies. Preparedness versus response and recovery competencies Published articles describing emergency management competencies commonly do not differentiate between preparedness and response competencies, and list them in an intermixed fashion. 12,13 The GWU-ICDRM project team sought to maintain a separation between these categories. Preparedness competencies are commonly based upon everyday organizational objectives, structure, processes, and relationships to other organizations. Preparedness is unquestionably important, but for it to be accurate, comprehensive and successful in establishing an effective emergency response capability, a thorough understanding of the response system must be established first, and preparedness guided by this. It was therefore reasoned by the project team that specific competencies for emergency response should be established and validated first, and then used as the “end state” to guide the development of valid preparedness competencies. 10 Barbera JA, Macintyre AG, et al. Emergency Management Principles and Practices for Healthcare Systems, Unit 3, Lesson 3.1.1, accessed at http://www1.va.gov/emshg/page.cfm?pg=122 11 ATPM (Association of Teachers of Preventive Medicine) in collaboration with Center for Health policy, Columbia University School of Nursing. Emergency Response Clinician Competencies in Initial Assessment and Management, 2003, accessed at http://www.atpm.org/education/Clinical_Compt.html 12 INCMCE (International Nursing Coalition for Mass Casualty Education). Educational Competencies for Registered Nurses Responding to Mass Casualty Incidents, 2003. Available at: http://www.nursing.hs.columbia.edu/institutes-centers/chphsr/hospcomps.pdf 13 ACEP (American College of Emergency Physicians) and the U.S Department of Health & Human Services, Office of Emergency Preparedness. Developing Objectives, Content, and Competencies for the Training of Emergency Medical Technicians, Emergency Physicians, and Emergency Nurses to Care for Casualties Resulting From Nuclear, Biological, or Chemical (NBC) Incidents, Final Report April 23, 2001. American College of Emergency Physicians, Irving, Texas. Institute for Crisis, Disaster and Risk Management The George Washington University 36 Appendix C – Healthcare Emergency Management Competencies Because of these considerations, the initial project focus was response and recovery competencies. Emergency management program competencies related to mitigation and preparedness were developed later for the two job groups that are the initial focus of the certification project. Establishing appropriate levels of proficiency Concurring with other authors that “competency” is not an all-or-none phenomenon, the GWU-ICDRM project team established “proficiency levels” to address this issue in a graduated fashion. Proficiency levels delineate the “The degree of understanding of the subject matter and its practical application through training and performance…” 14 In emergency management, proficiency indicates the level of mastery of knowledge, skills and abilities (i.e., competencies) that are demonstrable on the job and lead to the organization achieving its objectives. Levels of proficiency may therefore also be used to describe the level of mastery that is the objective of and specific training or education program. The final proficiency levels defined for this project are presented in Table 1. Table 1. Definition of the Levels of Proficiency Represents an understanding of the knowledge/skills/abilities Awareness encompassed by the competency, but not to a level of capability to adequately perform the competency actions within the organization’s system. Operations Expert Represents the knowledge/skills/abilities to safely and effectively perform the assigned tasks and activities, including equipment use as necessary Represents operations-level proficiency plus the additional knowledge/skills/abilities to apply expert judgment to solve problems and make complex decisions. As core and job group competencies were developed, the project team qualified each primary competency with an indicated level of proficiency (awareness, operations, expert). 14 EMA. Urban Search & Rescue Incident Support Team Training: Student Manual. Module 1, Unit 4, Page 6: Planning Process Overview. n/a:40. 4/16/2004, accessed at: http://www.fema.gov/emergency/usr/usrist2.shtm Institute for Crisis, Disaster and Risk Management The George Washington University 37 Appendix C – Healthcare Emergency Management Competencies Developing emergency response and recovery competencies Using the competency framework established in this project, response and recovery “core” competencies were developed for all personnel within a healthcare system that may have a role in the emergency response, regardless of their specific emergency response and recovery function. Additional competencies were then established for three functionally based job groups within a healthcare. The original designation for these job groups were (1) healthcare facility leaders, (2) patient care providers, and (3) emergency management program managers. The titles and definitions evolved with outside input as the project tasks were accomplished (see Table 2 for final titles and descriptions). Initial competency identification and development was accomplished through an analysis of ICS as presented in NIMS, an extensive literature review, and an evaluation of the VHA system and processes for emergency response. 15 Additionally, the GWU-ICDRM project team relied upon their extensive emergency management and disaster response experience, and upon related previous research efforts. 16,17,18 The emergency response and recovery competencies for the initially designated three job groups were then fully developed, studied through a web-based survey, revised based upon input and completed. 19 Identification of additional job groups and their associated competencies Early in the competency development process, it became apparent that there were additional important healthcare emergency management job groups beyond the three that were initially described. These groups have distinct response and recovery responsibilities (and therefore associated competencies) for the healthcare organization’s resiliency and medical surge. After extensive research during the latest phase of the project, the additional groups were identified as: Facilities and Engineering Services (FES), Police and Security Services (PSS), and Clinical Support Services (CSS). Their descriptions are presented in Table 2. Using the previously defined methodology (including web-based peer review), the follow-on project allowed for the development of emergency response and recovery competencies for these remaining job groups. 15 Veterans Health Administration. VHA Emergency Management Program Guidebook, 2005, accessed at: http://www1.va.gov/emshg/page.cfm?pg=114 16 Barbera, Joseph A and Anthony G. Macintyre. Medical and Health Incident Management System: A Comprehensive Functional Description for Mass Casualty Medical and Health Incident Management. Institute for Crisis, Disaster & Risk Management. The George Washington University, Washington DC, October 2002, accessed at www.gwu.edu/~icdrm/ 17 Barbera, Joseph A and Anthony G. Macintyre. Mass Casualty Handbook: Hospital Emergency Preparedness and Response, First Edition. Jane’s Information Group, 2003. 18 CNA Corporation. Medical Surge Capacity & Capability: The Management System for Integrating Medical and Health Resources During large-Scale Emergencies. August 2004, accessed at: http://www.hhs.gov/ophep/mscc_handbook.html 19 Barbera JA, Macintyre AG, et al. VHA-EMA Emergency Response and Recovery Competencies: Competency Survey, Analysis, and Report (June 16, 2005), available at www.gwu.edu/~icdrm/ Institute for Crisis, Disaster and Risk Management The George Washington University 38 Appendix C – Healthcare Emergency Management Competencies Development of preparedness and mitigation (program) competencies for Emergency Management Program Managers and Healthcare System Leaders The methodology utilized in this project focused first on the development and validation of response and recovery competencies as an “end state” for healthcare system personnel in their emergency management activities. The second phase of the project allowed for the development of program competencies for Emergency Program Managers and Healthcare System Leaders, which focused upon preparedness and mitigation activities necessary to reach this “end state.” These two job groups maintain primary responsibility for the emergency management program within a healthcare system, and thus have extensive primary competencies that relate to program development and maintenance required for successful response to emergencies and disasters. The program competencies were developed using the earlier methods, with identical criteria that the competencies be objective and measurable, maintain internal and external consistency, and be described within the context of an organization’s specific emergency management program objectives. Program competencies may more closely align with business management models during day-to-to day operations. Hence, organizational and individual outputs for these groups can be expected to be more frequent. This concept was included in the development of the program competencies. While no formal survey was conducted following the development of these program competencies, peer review was accomplished by providing draft competencies to experts for comment. Only minor changes resulted. The final job group titles and their descriptions are listed below. The competencies follow. Table 2. Healthcare System Job Group Definitions All Personnel (AP) All personnel are defined as any healthcare system administrator, employee, professional staff, licensed independent practitioners or others with a specified role in the healthcare systems emergency operations plan (EOP). Patient Care Providers (PCP) Physicians, physician assistants, registered nurses, licensed practical nurses, nurses working within expanded roles (CRNA, RNP, and others), emergency medical technicians, paramedics, and respiratory therapists and others who provide direct clinical patient care. Not included are clinical support staff that provide patient care services under the direct supervision of patient care providers: e.g., nurse’s aides, procedure technicians, orderlies, and others. Institute for Crisis, Disaster and Risk Management The George Washington University 39 Appendix C – Healthcare Emergency Management Competencies Hospital and/or healthcare system-wide senior executives (CEO, COO, CFO), hospital-wide managers, department heads, nursing executives, chief of the medical staff, and/or senior managers in Healthcare System Leaders large departments or key operating units. It is assumed that members of this job group, due to their everyday organizational (HSL) positions, would be assigned to serve in the command and general staff positions of an ICS structure during a healthcare system’s emergency response. Emergency Management Program Managers (EPM) Personnel primarily responsible for developing, implementing and maintaining healthcare facility and system-wide emergency management (EM) programs that include the Emergency Operations Plan (EOP). System level emergency program managers, above the level of individual facilities, (such as VHA Area Emergency Managers or program managers at the level of the VA Emergency Management Strategic Healthcare Group) are also included in this job group. It is assumed that the individuals in this job group will be assigned to a command & general staff ICS position (usually planning section chief) during response, and so are expected to possess the response and recovery competencies listed under Healthcare System Leaders as well. In some healthcare systems, an EM Program Manager may oversee a more limited position (e.g. program coordinator) with a narrower range of competencies. Clinical Support Services (CSS) Personnel that perform tasks related to the medical care of patients without direct patient interface (e.g. pharmacists, lab technicians, etc.) or provide patient services that aren’t primarily medical care (social services, physical and occupational therapy, pastoral care, patient educators, and others) or provide patient care services under the direct supervision of patient care providers (such as nurse’s aides, procedure technicians, orderlies, transporters). Police & Security Services (PSS) Personnel whose day to day job in the healthcare system involves security and the full range of law enforcement activities. Day-today duties may or may not put these individuals into direct contact with patients. Institute for Crisis, Disaster and Risk Management The George Washington University 40 Appendix C – Healthcare Emergency Management Competencies Facilities and Engineering Services (FES) Personnel whose day to day job involves maintaining the physical plant and its various systems. Included in this group are facilities and physical plant personnel, engineers, grounds personnel, biomedical engineers, food services, communications and IT personnel. It also usually includes administrative safety positions below the level of the healthcare system leaders. Day to day duties rarely put these personnel in direct patient contact. Institute for Crisis, Disaster and Risk Management The George Washington University 41 Appendix C – Healthcare Emergency Management Competencies Emergency Response and Recovery Competencies All Personnel (AP) All personnel are defined as any healthcare system administrator, employee, professional staff, licensed independent practitioners or others with a specified role in the healthcare systems emergency operations plan (EOP). x AP-R1: Utilize general Incident Command System (ICS) principles during incident response and recovery. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R1.1: Describe ICS as an emergency response and recovery operating system and its application to healthcare system incident response and recovery, management structure, concept of operations, and planning cycle. o AP-R1.2: Describe your potential role(s) and responsibilities within the healthcare system response and recovery in terms of ICS principles. o AP-R1.3: Describe the ICS-delineated expectations of individual responders in relation to the healthcare system response and recovery to include: attendance at briefings, reporting requirements, and use of rolerelated documents such as Operational Checklists (Job Action Sheets). Skills o AP-R1.4: Demonstrate an operations level of proficiency in ICS principles by utilizing appropriate forms, attending indicated meetings, and adhering to appropriate reporting requirements. x AP-R2: Recognize situations that suggest indications for full or partial activation of the healthcare system’s Emergency Operations Plan (EOP), and report them appropriately and promptly. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R2.1: Describe the general characteristics of emergency situations that may indicate the need for full or partial EOP activation. o AP-R2.2: Describe the reporting requirements and methodology for situations that may require full or partial EOP activation. Skills o AP-R2.3: Identify situations within your areas of regular duty that should be reported for consideration for full or partial activation of the healthcare system’s EOP. Institute for Crisis, Disaster and Risk Management The George Washington University 42 Appendix C – Healthcare Emergency Management Competencies o AP-R2.4: Report situations within your areas of regular duty by following EOP notification procedures and contacting the appropriate person as indicated by your specific role and by the situation at hand (e.g., page operator, supervisor, etc.). x AP-R3: Participate in healthcare system mobilization to rapidly transition from day-to-day operations to incident response organization and processes Recommended proficiency for Primary Competency: operations level Knowledge o AP-R3.1: Describe the procedures necessary to receive notification of EOP activation and to prepare your work area, as indicated, for EOP response and recovery. o AP-R3.2: Describe the initial reporting requirements for your expected role or position. o AP-R3.3: Describe the location and format of the system EOP. Skills o AP-R3.4: Follow your functional areas mobilization plan as outlined in the EOP to prepare your work area for EOP response and recovery. o AP-R3.5: Confirm notification receipt and report to the appropriate EOP position your initial situation, resource status, and any special problems encountered for your specific role or functional area. o AP-R3.6: Locate the facility EOP and access portions applicable to your role and responsibilities. x AP-R4: Apply the healthcare system’s core mission statement to your actions during emergency response and recovery. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R4.1: Describe how your emergency operations role and responsibilities support the healthcare system mission during emergency response and recovery. Skills o AP-R4.2: Demonstrate your understanding of the healthcare system’s mission during emergency response and recovery by ensuring your actions continually contribute to 1) continuity of patient care operations, 2) the safety of patients, families, and staff, 3) the conservation of property, and 4) the healthcare system support to the community to ensure the nation’s safety. x AP-R5: Apply the healthcare system code of ethics to your actions during emergency operations. Institute for Crisis, Disaster and Risk Management The George Washington University 43 Appendix C – Healthcare Emergency Management Competencies Recommended proficiency for Primary Competency: operations level Knowledge o AP-R5.1: Describe how the healthcare system’s and other codes of ethics (such as Federal codes of ethics for Federal facilities), as applicable, apply to your role and responsibilities during emergency response and recovery. Skills o AP-R5.2: Demonstrate your understanding of the healthcare system’s and Federal codes (as applicable) of ethics by applying them to your individual response actions during emergency response and recovery. x AP-R6: Execute your personal/family preparedness plans to maximize your availability to participate in the healthcare system’s emergency response and recovery. Recommended proficiency for Primary Competency: expert level Knowledge o AP-R6.1: Describe the importance of both a personal and a family preparedness plan to allow you to perform your healthcare system emergency response and recovery role. o AP-R6.2: Describe your responsibility as an employee to maintain a personal and family preparedness plan. o AP-R6.3: Describe your responsibility as a supervisor (if applicable) to promote employee maintenance of a personal and family preparedness plan. o AP-R6-4: Identify the personal/family specific requirements and details that must be addressed in your personal/family preparedness plan that allow you to perform your healthcare system response role in a potentially changed work schedule and environment. Skills o AP-R6.5: Demonstrate your availability to work in your assigned role during healthcare system response and recovery by executing your personal/family preparedness plan. o AP-R6.6: Demonstrate an expert level of proficiency in personal and family preparedness planning by executing your personal/family preparedness plan and meeting your personal and family needs across any circumstances. x AP-R7: Respond with your previously prepared and maintained personal “go-kit” to maximize your ability to perform your assigned role during healthcare system response and recovery. Recommended proficiency for Primary Competency: expert level Knowledge Institute for Crisis, Disaster and Risk Management The George Washington University 44 Appendix C – Healthcare Emergency Management Competencies o AP-R7.1: Describe the importance of your personal “go kit” for selfprotection and to allow you to perform your healthcare system response and recovery role and responsibilities (A “go kit” contains personal supplies that an employee would need to work their emergency response and recovery role beyond a usual work shift, potentially not returning home for 72 hours). o AP-R7.2: Describe your responsibility as an employee to maintain a personal “go-kit.” o AP-R7.3: Describe your responsibility (if applicable) as a supervisor to promote employee maintenance of a personal “go kit.” o AP-R7.4: Describe how the EOP components and related policies and procedures, (evacuation, shelter in place, lock down, etc.) of the healthcare system Emergency Operations Plans impact your decisions on what should be included in your personal “go kit.” o AP-R7.5: Identify your personal situation (physical ability/constraints, medical needs, personal/family preparedness plan, etc.) and how it impacts on your decisions on what should be included in your personal “go kit.” Skills o APC-7.6: Demonstrate your availability to work in your assigned role and operational periods during response and recovery through the use of your personal “go kit.” x AP-R8: Follow the general response procedures for all personnel in the Occupant Emergency Procedures (OEP) and assist others (healthcare system personnel, patients, and visitors) as necessary to accomplish the OEP directives. [Footnote: More specific response procedures are addressed under respective job groups.] Recommended proficiency for Primary Competency: operations level Knowledge o AP-R8.1: Describe the component parts of the OEP and your responsibilities and actions under each. o AP-R8.2: Describe circumstances that could lead to OEP activation and your responsibilities during OEP activation. o AP-R8.3: Describe the reporting procedures for your job position that would activate the OEP. Skills o AP-R8.4: Execute your roles and responsibilities for the facility OEP by conducting the OEP directives for your job position in evacuation, shelter in place, or other actions during emergency operations. x AP-R9: Perform your specific roles and responsibilities as assigned in the healthcare system’s Emergency Operations Plan (EOP) and the appropriate Incident Action Plan (IAP) in order to support the system’s objectives. Institute for Crisis, Disaster and Risk Management The George Washington University 45 Appendix C – Healthcare Emergency Management Competencies Recommended proficiency for Primary Competency: operations level Knowledge o AP-R9.1: Describe the ICS framework as applied specifically to the healthcare system emergency response and recovery. o AP-R9.2: Describe your role and responsibility as assigned in the healthcare system’s EOP. o AP-R9.3: Describe how potential changes in event parameters may necessitate changes in the facility IAP objectives and strategies, and hence changes in your job area’s tactics and assignments (Management by objectives). o AE-R9.4: Describe the urgent issues that could potentially require a change in your job or job area’s response strategies and tactics. o AP-R9.5: Describe your personal accountability requirements during emergency response and recovery. o AP-R9.6: Describe the equipment and technologies for your specific role and responsibilities within the healthcare facility EOP. o AP-R9.7: Describe the facility policy applicable to your role for engaging the media. Skills o AP-R9.8: Demonstrate appropriate EOP-designated reactive actions in response to potential/actual events that have activated the EOP. o AP-R9.9: Demonstrate your specific role and responsibilities as assigned in the healthcare facility’s EOP by following your operational checklist (job action sheet), completing assignments, filling out appropriate forms, and fulfilling reporting requirements. o AP-R9.10: Ensure organizational objectives are met by formulating and/or implementing specific tactics consistent with the objectives and strategies delineated in the controlling IAP for the current operational period. o AP-R9.11: Report data to supervisors, as indicated, to contribute to measuring effectiveness of your EOP functional area and its contributions to achieving the organization’s designated incident objectives. o AP-R9.12: Operate all equipment and technologies for your specific role and responsibilities within the healthcare system’s EOP. x AP-R10: Follow the Communication Plan and reporting requirements as outlined in the healthcare system’s EOP and the specific Incident Action Plan for an emergency event. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R10.1: Describe the policy and methods for communication and reporting during emergency response and recovery. Institute for Crisis, Disaster and Risk Management The George Washington University 46 Appendix C – Healthcare Emergency Management Competencies o AP-R10.2: Describe the process for rapidly communicating urgent issues that could require a change in response strategies or tactics for your job area, and the appropriate party to receive your communication. o AP-R10.3: Describe the process for reporting significant hazard or response impacts that you or your job area encounter to the appropriate party as indicated by the EOP. o AP-R10.4: Describe the general content of the communication plan component of the Incident Action Plan as it relates to your emergency response and recovery role. o AP-R10.5: Describe the procedures applicable to your role for interaction with the media. Skills o AP-R10.6: Demonstrate the reporting requirements within your functional area as delineated in the healthcare system EOP. o AP-R10.7: Maintain communications with appropriate parties for your role/functional area despite changing requirements and event parameters. o AP-R10.8: Demonstrate an understanding of media interactions by referring requests to appropriate personnel (as applicable), and when interacting with the media, follow designated interview procedures and protocols. x AP-R11: Follow and enforce healthcare system’s safety rules, regulations, and policies during emergency response and recovery. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R11.1: Describe the healthcare system’s safety rules, regulations, and policies during emergency response and recovery that maintain personal safety and a safe work environment. o AP-R11.2: Describe how to apply the Safety Plan component of the facility Incident Action Plan. o AP-R11.3: Describe the safety specific actions and procedures to be followed when unsafe situations/events are encountered. o AP-R11.4: Describe incident parameters that may serve as stressors for response personnel, how stress may be manifested, and appropriate interventions for your specific role. Skills o AP-R11.5: Demonstrate your adherence to and enforcement of healthcare system safety rules, regulations, and policies during emergency response and recovery by wearing appropriate PPE, following pre-defined safety procedures, identifying and addressing unsafe practices, and following the IAP Safety Plan as briefed by your immediate supervisor. o AP-R11.6: Recognize and address incident stress for yourself and others in your functional area by identifying manifestations of stress and, in a fashion appropriate to your specific role, decreasing the stressors, limiting Institute for Crisis, Disaster and Risk Management The George Washington University 47 Appendix C – Healthcare Emergency Management Competencies the negative impact of the stressors, or ensuring appropriate assistance in recovering from negative stressors. x AP-R12: Follow and enforce police and security measures consistent with the nature of the incident that has prompted the EOP activation. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R12.1: Describe healthcare system security rules, regulations, and policies that apply to your assigned role and responsibilities in the EOP. o AP-R12.2: Describe the security specific actions and procedures to be followed when a suspicious event or security breach is detected. Skills o AP-R12.3: Demonstrate your adherence to and enforcement of security measures during emergency response and recovery by following security briefings, instruction from individual security personnel, and badge procedures. x AP-R13: Utilize or request (as appropriate) and integrate equipment, supplies, and personnel for your specific role or functional area during emergency response and recovery. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R13.1: Describe procedures for requesting equipment, supplies, and personnel for your functional area and the integration of these resources during emergency response and recovery. Skills o AP-R13.2: Demonstrate your ability to request and integrate additional resources by following EOP procedures outlined for these activities. o AP-R13.3: Demonstrate the ability to assess the adequacy of equipment, supplies and personnel to carry out your job assignments during each operational period. x AP-R14: Follow demobilization procedures that facilitate rapid and efficient incident disengagement and out-processing of individual resources and/or the overall healthcare organization. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R14.1: Describe demobilization policies and procedures for your work area, including procedures to “catch up” on regular staffing and other activities that were suspended or revised during emergency operations. Institute for Crisis, Disaster and Risk Management The George Washington University 48 Appendix C – Healthcare Emergency Management Competencies o AP-R14.2: Describe the policy and procedures for out-processing of personnel during demobilization. o AP-R14.3: Describe the policy and procedures for conducting an initial Incident Review (commonly known as a “hot wash”) for your work area. o AP-R14.4: Describe the policy and procedures for documenting and reporting incident-related issues for inclusion in After Action Report process, analysis, and corrective measures. Skills o AP-R14.5: Demonstrate demobilization procedures for the incident by following the demobilization plan specific to your functional area. o AP-R14.6: Prioritize, initiate or participate in delayed activities (relevant to your position) that were suspended or revised during emergency response. o AP-R14.7: Participate in out-processing, to include a performance evaluation and any indicated physical exam. o AP-R14.8: Provide input into the Incident Review as appropriate for your position during emergency response. x AP-R15: Follow recovery procedures that ensure facility return to baseline activity. Recommended proficiency for Primary Competency: operations level Knowledge o AP-R15.1: Describe policies and procedures for rehabilitation of personnel. o AP-R15.2: Describe policies and procedures for rehabilitation of equipment (including recertification for use), reordering of supplies specific to your functional area, and rehabilitating your workspace. o AP-R15.3: Describe policies and procedures specific to your role and responsibilities for rehabilitation of the facility. o AP-R15.4: Describe the policies and procedures for a formal After-Action Report. Skills o AP-R15.5: Demonstrate an understanding of the importance of personnel rehabilitation activities by participating in personnel rehabilitation as instructed. o AP-R15.6: Demonstrate an understanding of facility and equipment rehabilitation by participating in these procedures to ensure your functional area readiness for day-to-day activities and future EOP activations. o AP-R15.7: Demonstrate an understanding of After Action-Reports by submitting items in the required format. Institute for Crisis, Disaster and Risk Management The George Washington University 49 Appendix C – Healthcare Emergency Management Competencies Emergency Management Program Manager (EPM) Personnel primarily responsible for developing, implementing and maintaining healthcare facility and system-wide emergency management (EM) programs that include the Emergency Operations Plan (EOP). System level emergency program managers, above the level of individual facilities, (such as VHA Area Emergency Managers or program managers at the level of the VA Emergency Management Strategic Healthcare Group) are also included in this job group. It is assumed that the individuals in this job group will be assigned to a command & general staff ICS position (usually planning section chief) during response, and so are expected to possess the response and recovery competencies listed under Healthcare System Leaders as well. 20 x EPM-R1: Recognize circumstances and/or actions, across the program manager’s jurisdiction if appropriate, that indicate a potential incident and report the situation to facility leadership and appropriate authorities. Recommended proficiency for Primary Competency: expert level Knowledge o EPM-R1.1: Describe the conditions across representative hazard types that indicate a potential incident requiring healthcare system response and recovery capabilities. o EPM-R1.2: List the healthcare system leadership positions that should be notified in the event of a potential incident and describe the formal notification process. o EPM-R1.3: List the outside authorities and resources that can be queried to rapidly obtain information about an evolving event, and describe the communication methods for this purpose. Skills o EPM-R1.4: Identify and obtain information from all non-healthcare system sources that could indicate the occurrence of an incident and need for healthcare system response. o EPM-R1.5: Report the circumstances of the potential incident to the relevant facility leader(s) and notify outside authorities as appropriate. x EPM-R2: Provide assistance and guidance to healthcare system Incident Managers, and other authorities as requested, on the decision to fully or partially activate Emergency Operations Plans (EOP). Recommended proficiency for Primary Competency: expert level Knowledge 20 In some healthcare systems, an EM Program Manager may oversee a more limited position (e.g. program coordinator) with a narrower range of competencies. Institute for Crisis, Disaster and Risk Management The George Washington University 50 Appendix C – Healthcare Emergency Management Competencies o EPM-R2.1: Describe the criteria that indicate the need for a partial or full healthcare system EOP activation. o EPM-R2.2: Describe the impact of EOP activation (full or partial) upon day-to-day facility operations. o EPM-R2.3: Describe the process for healthcare system EOP activation. Skills o EPM-R2.4: Assist facility leaders with the decision to activate emergency medical response plans and procedures by communicating relevant information about the nature and consequences of an incident and by explaining the benefits of activating the EOP. o EPM-R2.5: Provide Incident Managers with a list of all facility personnel positions with the authority to activate the EOP, as requested, and outline the methods for activation. x EPM-R3: Assist in the rapid mobilization of activated healthcare systems to transition from day-to-day activities to response and recovery operations. Recommended proficiency for Primary Competency: operations level Knowledge o EPM-R3.1: Describe processes and procedures used to mobilize the healthcare system and/or its individual facilities for emergency response and recovery. o EPM-R3.2: List all the external agencies relevant to your position that should be notified of the healthcare system’s EOP activation and determine their level of response. o EPM-R3.3: List all the internal healthcare system resources and facilities (ICP/EOC and others) that must be mobilized as the EOP is activated. Skills o EPM-R3.4: As requested by facility or healthcare system leadership, assist in facility mobilization by ensuring appropriate external liaisons are established and ensuring the facility management structure for response is clearly communicated externally. o EPM-R3.5: Provide the Healthcare System Incident Manager with briefings on the mobilization status of healthcare system facilities and/or internal resources (such as the EOC or the Decontamination Area) as indicated by the type and scope of the incident activation. x EPM-R4: Ensure full and proper execution of the appropriate emergency operations plan (EOP) for your healthcare system or designated healthcare system facilities during emergency response and recovery. Recommended proficiency for Primary Competency: expert level Knowledge Institute for Crisis, Disaster and Risk Management The George Washington University 51 Appendix C – Healthcare Emergency Management Competencies o EPM-R4.1: Describe the facility-specific as well as the larger, overarching healthcare system incident management organizational structure and response roles of all functional areas and key positions and how the incident management team (IMT) functions in parallel with continued enterprise management and operations.. o EPM-R4.2: Describe the healthcare enterprise’s organizational requirements as well as the relevant laws, regulations, policies and precedents that affect emergency operations and principles of emergency management. Skills o EPM-R4.3: Provide the healthcare system Incident Command Post with an initial projection of the supplies and resources needed for response and recovery as requested and as appropriate. o EPM-R4.4: At the outset of the incident, provide a briefing to the healthcare system incident manager on the response actions undertaken by external incident response agencies, or assure this is accomplished by the healthcare system senior liaison. o EPM-R4.5: Verify that the healthcare system’s personnel have adopted incident management roles and responsibilities according to the response structure and functional roles delineated in the relevant EOPs. o EPM-R4.6: Verify compliance of EOP response actions with applicable rules and regulations, and advise the facility Incident Commander as indicated. o EPM-R4.7: Provide assistance by monitoring the emergency response system assessing the adequacy and effectiveness of the incident management system in place at activated facilities within the healthcare system, as appropriate for the Program Manager’s jurisdiction. o EPM-R4.8: Address any apparent deficiencies noted in the incident management system during response and recovery by notifying the Incident Commander of the facility within the healthcare system and recommending solutions. x EPM-R5: Demonstrate the ability to function as a healthcare system’s Plans Chief within the ICS structure as indicated by the Emergency Operations Plan (EOP). Recommended proficiency for Primary Competency: expert level Knowledge o EPM-R5.1: Describe the healthcare system response roles and responsibilities ascribed to the chief of the Planning Section in the EOP. o EPM-R5.2: Describe the facility Incident Planning Cycle and the key components for which the Plans Chief is responsible. o EPM-R5.3: Describe the methods for functional area reporting and for the collation, processing, and dissemination of this information. Institute for Crisis, Disaster and Risk Management The George Washington University 52 Appendix C – Healthcare Emergency Management Competencies o EPM-R5.4: Describe methods for monitoring response and recovery actions in order to assist the Incident Commander in determining progress towards achieving the incident objectives. Skills o EPM-R5.5: Establish an effective Incident Planning Cycle by defining operational periods (approved by the system Incident Commander), coordinating the Planning Cycle timing with non-healthcare system response agencies, and disseminating the schedule for essential planning activities (management and planning meetings, operational briefings, and others). o EPM-R5.6: Ensure adequate functional area reporting by establishing the time schedule for reporting and verifying reports are received, to include situation, resource status, specific tactics utilized, progress accomplished, and unusual problems encountered; include patient tracking as necessary. o EPM-R5.7: Include information originating internal and external to the system in the planning process by monitoring internal and external sources for information, including the level of response by external organizations, and considering the information in the planning process. o EPM-R5.8: Ensure awareness of event parameters within the healthcare system by providing continual updates to the leader of functional areas and external agencies as appropriate. o EPM-R5.9: Provide rapid contingency response by monitoring for sudden changes in event parameters that necessitate revision of response strategies and tactics, and disseminate appropriate notification to relevant internal and external parties. o EPM-R5.10: Manage orderly and concise planning activities (management and planning meetings, operational briefings) by limiting distractions, providing agendas, and ensuring documentation of all relevant information discussed in the meetings. x EPM-R6: Perform or assist with the senior healthcare system liaison function and ensure that relevant response and recovery information is exchanged with senior healthcare system management levels beyond the immediate agency executive, if indicated. Recommended proficiency for Primary Competency: operations level Knowledge o EPM-R6.1: Describe the purpose and structure of the enterprise’s overarching healthcare system administrative hierarchy (such as the Veterans Integrated Service Network and Headquarters for the VHA) and its potential role during facility emergency response and recovery. o EPM-R6.2: Describe essential components of facility planning that should be disseminated to senior healthcare system management levels. o EPM-R6.3: Describe any assigned healthcare enterprise responsibilities to the community, State, or Federal governments or other entities established Institute for Crisis, Disaster and Risk Management The George Washington University 53 Appendix C – Healthcare Emergency Management Competencies through contracts, statutes or other authorities (for example, the VHADoD Contingency Plan) where the healthcare organization should establish a formal liaison function. Skills o EPM-R6.4: If part of a larger healthcare system (such as a VA Medical Center within a Veterans Integrated Service Network (VISN)), fulfill the region-wide emergency operations (response) plan and liaison function if it is activated. o EPM-R6.5: Ensure that senior healthcare system officials are receiving accurate information from the facility (usually through the facility’s agency executive) by providing the current facility IAP and/or situation reports in formats that are understandable to them. o EPM-R6.6: Ensure that the facility Agency Executive and Incident Manager receive appropriate communications from senior healthcare system officials above the level of the incident management structure. o EPM-R6.7: Assure that established responsibilities to the community, State, or Federal governments or other entities addressed and required actions communicated to appropriate Agency Executives and Incident Management Teams. x EPM-R7: If Program Manager of a larger healthcare system (such as a VA Medical Center within a Veterans Integrated Service Network (VISN)) with activated IMTs within individual healthcare facilities within your network, establish senior liaison with appropriate external healthcare organizations within the healthcare system in your area, conduct information exchange, and coordinate incident response strategies and tactics. Recommended proficiency for Primary Competency: operations level Knowledge o EPM-R7.1: List relevant external healthcare organizations that exist within the emergency response network in your area and methods for contacting them. o EPM-R7.2: Describe how the emergency response and recovery actions of healthcare facilities within your network and in your area impact one another. o EPM-R7.3: Describe how healthcare facilities within your network and external agencies in the same impact area may support one another during emergency response and recovery. Skills o EPM-R7.4: Ensure the IMT contact information for activated IMTs in your network is disseminated to appropriate external emergency response agencies. o EPM-R7.5: Facilitate the process for healthcare facilities within your network to gain access to appropriate external emergency response Institute for Crisis, Disaster and Risk Management The George Washington University 54 Appendix C – Healthcare Emergency Management Competencies agencies by establishing liaison or providing contact methods (as indicated). o EPM-R7.6: Facilitate coordination of response strategies and tactics by ensuring regular exchange of Incident Action Plans (or summaries contained in Situation Reports) between IMTs in your network and the appropriate external emergency response agencies. EPM-R7.7: Facilitate the use of mutual aid agreements between facilities within your network, and with external organizations when indicated. x EPM-R8: Participate in demobilization processes within the activated healthcare organization (such as a VHA Medical Center and/or within its overarching Veterans Integrated Service Network) to disengage resources from incident response and allow return to normal operations or back to stand-by status. Recommended proficiency for Primary Competency: operations level Knowledge o EPM-R8.1: Describe both the general objectives of the demobilization process and the specific management issues associated with demobilization, rehabilitation of response elements, and preparation to return to routine professional roles. Skills o EPM-R8.2: Assist in the demobilization of the healthcare organization and its resources by verifying that operational objectives have been met (or are reassigned to continuing units) and that appropriate internal and external notification is made regarding demobilization. o EPM-R8.3: Participate in any initial incident review (commonly known as a “hot wash”) and assist organizational leadership with ensuring appropriate procedures are followed for maintaining/preserving information for the After Action Report process. o EPM-R8.4: Assist with the debriefing and performance assessments of response personnel under your supervision, and others as requested by the organization’s incident manager. x EPM-R9: Assist, as indicated by assigned position in recovery management, with healthcare organization recovery to full pre-incident function, including return to routine facility management and medical care activities. Recommended proficiency for Primary Competency: operations level Knowledge o EPM-R9.1: Describe the incident planning and management processes for transitioning from response to recovery. Institute for Crisis, Disaster and Risk Management The George Washington University 55 Appendix C – Healthcare Emergency Management Competencies o EPM-R9.2: Describe the procedures and priorities for returning response resources and the overall organization to pre-incident operations and management. o EPM-R9.3: Describe the process required to re-evaluate the healthcare organization’s patient population and post-incident patient care activities, which includes addressing the backlog of regular work. Skills o EPM-R9.4: Assist, as requested, with personnel rehabilitation by providing advice on procedures for addressing physical or psychological concerns. o EPM-R9.5: Assist, as requested, with facility and equipment rehabilitation by establishing priority of recovery activities and identifying additional resources that may be required. o EPM-R9.6: Assist, as requested, with addressing backlogs of regular work by providing advice to facility leaders on surge capacity methods and the prioritization of backlogged services. x EPM-R10: Fulfill emergency management program requirements for a formal incident After-Action Report (AAR) process that captures and processes recommended changes to achieve organizational learning. Recommended proficiency for Primary Competency: expert level Knowledge o EPM-R10.1: Describe the policies and procedures as well as other considerations for completing the formal After Action Report on healthcare system response. o EPM-R10.2: Describe procedures for capturing information, analysis and acceptance or recommendations, and implementation of changes to a healthcare system EOP and overarching emergency management program. Skills o EPM-R10.3: Conduct efficient After Action Reports by utilizing incident response procedures for conducting a meeting and by ensuring After Action Report items are documented in the required format (i.e., issue, background, recommended action, responsible party and recommended timeframe). o EPM-R10.4: Ensure organizational learning by conducting appropriate analysis of recommendations, obtaining formal administration approval of accepted recommendations, and incorporating the recommended changes into the healthcare system EOP and other components of the emergency management program. Institute for Crisis, Disaster and Risk Management The George Washington University 56 Appendix C – Healthcare Emergency Management Competencies Healthcare System Leaders (HSL) Hospital and/or healthcare system-wide senior executives (CEO, COO, CFO), hospitalwide managers, department heads, nursing executives, chief of the medical staff, and/or senior managers in large departments or key operating units. It is assumed that members of this job group, due to their everyday organizational positions, would be assigned to serve in the command and general staff positions of an ICS structure during a healthcare system’s emergency response. x HSL-R1: Identify specific criteria of potential events that require the full or partial activation of the system’s Emergency Operations Plan (EOP). Recommended proficiency for Primary Competency: expert level Knowledge o HSL-R1.1: Describe the specific characteristics of potential events that would require EOP full or partial activation. o HSL-R1.2: Describe the impact of EOP activation (full or partial) upon day-to-day facility operations. o HSL-R1.3: Describe potential sources of information that may assist with incident recognition. Skills o HSL-R1.4: Demonstrate understanding of criteria for EOP full or partial activation by initiating appropriate levels of EOP activation rapidly during specific events. o HSL-R1.5: Ensure appropriate decisions are made about EOP activation by considering the impact of EOP activation (full or partial) upon day-today facility operations including the provision of essential services to existing patient populations. o HSL-R1.6: Ensure appropriate information is included in the decision to activate the EOP (as necessary) by coordinating with facility personnel who have relevant information or who have expertise relevant to the incident type. o HSL-R1.7: Ensure appropriate information from external sources is considered in the decision to activate the EOP by coordinating with external agencies that may provide incident-related information. x HSL-R2: Activate or support activation of the Emergency Operations Plan (EOP) to manage emergency response. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R2.1: Describe the EOP activation and notification process. Institute for Crisis, Disaster and Risk Management The George Washington University 57 Appendix C – Healthcare Emergency Management Competencies o HSL-R2.2: List the types of notification for the facility and specific functional areas. o HSL-R2.3: List relevant external agencies that should be notified of the system’s EOP activation (full or partial); e.g. VHA/VISN administrators, local public health, local public safety, etc. o HSL-R2.4: Describe the initial reporting process from the notified functional areas in order to determine receipt of the notification message and initial resource availability. Skills o HSL-R2.5: Ensure appropriate EOP activation by identifying personnel with authority to activate the EOP and using the established methods for activation. o HSL-R2.6: Ensure awareness of EOP activation by determining and conducting the appropriate level of notification (update, alert, advisory, activation) for the system, specific functional areas, and external agencies as applicable. o HSL-R2.7: Confirm the activation of functional areas (management, operations, logistics, plans/information, finance/administration) by receiving and processing confirmation of notifications. x HSL-R3: Ensure rapid system mobilization that transitions response personnel and resources from day-to-day activities to their designated incident response status. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R3.1: Describe the management positions responsible for assuring mobilization of all key resources and personnel in the healthcare system’s EOP, and the reporting process for determining mobilization status. o HSL-R3.2: Describe the layout, location of supplies, and set-up of the facility Incident Command Post (ICP) or alternatively (according to the organization’s EOP), the healthcare facility’s Emergency Operations Center (EOC) with a smaller ICP at the site of primary response activity. Skills o HSL-R3.3: Confirm the mobilization of functional areas (management, operations, logistics, plans/information, finance/administration) by receiving and processing confirmation of mobilization and full readiness for response. o HSL-R3.4: Ensure adequate resources and facilities are available for the healthcare system including assisting with or supervising (as indicated by leader position) establishment of the Emergency Operations Center (EOC) and Incident Command Post (ICP) for the organization. o HSL-R3.5: Review the mobilized command and general staff area of the ICP or EOC to confirm that those positions can fully operate in their positions. Institute for Crisis, Disaster and Risk Management The George Washington University 58 Appendix C – Healthcare Emergency Management Competencies x HSL-R4: Ensure appropriate execution of the healthcare system Occupant Emergency Procedures (OEP) by assuring appropriate protective actions for patients, staff and visitors, and for the integrity of the healthcare system. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R4.1: Describe the decision process for activating the OEP and how the OEP functions within the Emergency Operations Plan (EOP) for the organization. o HSL-R4.2: Describe the accountability processes for staff, patients, visitors, vital records, and critical equipment and how the overall and final accountability is confirmed. o HSL-R4.3: List critical external resources required to support OEP activation. Skills o HSL-R4.4: Make decisions during OEP implementation that reflect the prioritized system objectives of life safety, incident stabilization, and protection of mission critical property and operating systems. o HSL-R4.5: Demonstrate oversight of accountability for staff, patients, visitors and mission critical systems. x HSL-R5: Ensure that the system’s incident management is effective, utilizes Emergency Operations Plan (EOP) procedures and processes, and uses a pro-active ‘management by objective’ approach. Recommended proficiency for Primary Competency: expert level Knowledge o HSL-R5.1: Describe the functional organization of the healthcare system’s incident management during emergency response and recovery and how the activated incident management team (IMT) interacts through the agency executive with the enterprise’s ongoing management and operating systems. o HSL-R5.2: Describe the initial reactive phase of the healthcare system’s incident response and the important transition to pro-active ‘management by objectives.’ o HSL-R5.3: Describe the healthcare system’s code of ethics and how it is considered/applied during incident planning and management decisionmaking procedures during emergency response and recovery. Skills o HSL-R5.4: Ensure the healthcare system’s incident management structure is well delineated by formally assigning facility incident management positions and providing the organizational structure with assignments Institute for Crisis, Disaster and Risk Management The George Washington University 59 Appendix C – Healthcare Emergency Management Competencies o o o o x (System ICS diagram) to relevant parties both internal and external to the system. HSL-R5.5: Provide pro-active incident management by developing, analyzing, and revising, as necessary, facility response objectives during management meetings in the Planning Cycle (management by objectives). HSL-R5.6: Ensure that healthcare system response objectives are efficiently and adequately met by performing continual monitoring of the system’s incident response system and outcomes. HSL-R5.7: Ensure the healthcare system’s code of ethics is applied, as appropriate, by considering it during response planning and decisionmaking. HSL-R5.8: Address limitations of the healthcare system’s EOP capacity and capability by identifying limitations and developing responseappropriate options to address unmet needs. HSL-R6: Manage continuous incident action planning through iterative planning cycle procedures that provide strategic and general tactical guidance to healthcare system personnel in order to achieve surge capacity, surge capability, and organizational resiliency. Recommended proficiency for Primary Competency: expert level Knowledge o HSL-R6.1: Describe the purpose of management meetings, planning meetings, and operations briefings for emergency response and recovery. o HSL-R6.2: Describe the key components of the healthcare system’s response Incident Action Plan and methods of dissemination, both internally and externally. o HSL-R6.3: Describe the purpose and the components of long term, alternative, contingency, and demobilization planning. Skills o HSL-R6.4: Ensure the clear delineation of the healthcare system’s operations cycle by establishing and disseminating the timing of planning meetings and operational periods. o HSL-R6.5: Ensure facility objectives are met by supervising the development, analysis, and revision of facility response strategies and general tactics. o HSL-R6.6: Ensure healthcare system personnel safety by identifying, minimizing, or preventing threats/hazards, and by responding to all real or potential safety issues for healthcare system response (Safety Plan) throughout the emergency response and recovery. o HSL-R6.7: Ensure efficient incident planning, as indicated by your incident management position, by participating in or conducting structured planning and management meetings, and operations briefings. o HSL-R6.8: Ensure appropriate dissemination of incident planning decisions by documenting and disseminating the healthcare system’s Institute for Crisis, Disaster and Risk Management The George Washington University 60 Appendix C – Healthcare Emergency Management Competencies Incident Action Plans to relevant persons internal and external to the facility. o HSL-R6.9: Demonstrate comprehensive incident planning by performing or assigning analysis of long term, alternative, contingency, and demobilization plans during response and recovery. o HSL-R6.10: Manage efficient exchange of information by participating in shift change briefings. x HSL-R7: Manage efficient information processing regarding response activities Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R7.1: Describe the components and timing of functional area reporting and how the results can be processed and analyzed to identify progress or problems in meeting the facility’s incident objectives. o HSL-R7.2: Describe critical sources of incident information external to the healthcare system. o HSL-R7.3: Describe procedures for reporting back to functional areas, including dissemination of the healthcare system’s Incident Action Plan. o HSL-R7.4: Describe types of event parameters that would require sudden changes in response strategies or tactics. Skills o HSL-R7.5: Ensure adequate functional area reporting by establishing the timing of the reporting and verifying that reports include a situation description, resource status, specific tactics utilized, progress accomplished, and unusual problems encountered (include patient tracking as necessary). o HSL-R7.6: Include information originating external to the healthcare system in the planning process by monitoring external sources for information (including the level of response by external organizations) and considering them in the planning process. o HSL-R7.7: Ensure awareness of event parameters within the healthcare system by providing continual updates to the leaders of functional areas and to external agencies as appropriate. o HSL-R7.8: Provide early response to contingencies by monitoring sudden changes in event parameters that necessitate immediate revision of response strategies and tactics and by disseminating appropriate notification to relevant parties (internal and external). x HSL-R8: Provide information on the facility’s emergency response and recovery activities to patients, patients’ families, facility personnel’s families, the media, and the general public, as appropriate. Recommended proficiency for Primary Competency: operations level Institute for Crisis, Disaster and Risk Management The George Washington University 61 Appendix C – Healthcare Emergency Management Competencies Knowledge o HSL-R8.1: Describe the methods of delivering information to the media and the important components of the message. o HSL-R8.2: Describe procedures used to ensure patients, patients’ families, and facility personnel’s families are kept apprised of response operations. o HSL-R8.3: Describe coordination techniques that ensure the facility’s media message is consistent with other organizations’ messages to the public. o HSL-R8.4: Describe HIPAA and its application to emergency response and recovery as well as other patient confidentiality measures. Skills o HSL-R8.5: Ensure the continuous update of relevant parties by providing, or assigning the task of providing, incident updates and the timing of subsequent update reports. o HSL-R8.6: Ensure media messages are appropriate and consistent with that of other organizations by coordinating with the external community incident managers and public information personnel. o HSL-R8.7: Identify public perceptions of the facility’s response and false information relating to the facility’s response by performing monitoring of media reports (address falsehoods as indicated). o HSL-R8.8: Ensure confidentiality of patient information by monitoring response and recovery actions for adherence to these standards where applicable. x HSL-R9: Monitor the response and recovery needs of the facility’s functional areas, and, if needed, provide support with additional facilities, equipment, communications, personnel or other assistance. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R9.1: Describe resource-tracking processes for the facility. o HSL-R9.2: Describe the resource request processes for functional areas in the facility to request both internal and external resources. o HSL-R9.3: List the critical elements of a Communications Plan. o HSL-R9.4: List potential sources of technical assistance. o HSL-R9.5: Describe procedures for ensuring the health and well-being of facility personnel. o HSL-R9.6: Describe integration methods of outside donated resources (personnel, equipment, supplies). Skills o HSL-R9.7: Demonstrate the ability to anticipate functional area requests by conducting an adequate incident planning process. Institute for Crisis, Disaster and Risk Management The George Washington University 62 Appendix C – Healthcare Emergency Management Competencies o HSL-R9.8: Provide logistical support to functional areas, first by identifying functional area needs and then appropriate resources to meet those needs. o HSL-R9.9: Provide communication support to functional areas by assisting with the development and approval of the facility Communications Plan, which should document and disseminate contact methods for relevant parties internal and external to the facility. o HSL-R9.10: Provide technical assistance to functional areas, as indicated, by identifying outside subject matter experts or other appropriate information resources. o HSL-R9.11: Ensure the health and well-being of facility personnel by participating in/approving the Medical Plan for the IAP (as indicated by your management position). o HSL-R9.12: Assist with the integration of external assistance and supplies, solicited and unsolicited, by managing them until they are assigned to specific functional areas. x HSL-R10: Establish appropriate measures to document, track, or reimburse financial costs associated with facility response and recovery. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R10.1: Describe processes for tracking personnel and resources utilized during response. o HSL-R10.2: Describe processes for compensating personnel utilized during response and for claims made by these personnel. o HSL-R10.3: Describe processes for reimbursement of external assistance provided during response. o HSL-R10.4: Describe processes for tracking other costs of response (e.g. delayed elective procedures, equipment and supplies consumed, etc). Skills o HSL-R10.5: Provide for personnel compensation by maintaining lists of personnel utilized during response and time worked. o HSL-R10.6: Provide for incident expense claims by ensuring appropriate documentation is completed and submitted within the required time periods. o HSL-R10.7: Provide for equipment and supply reimbursement by tracking lists of supplies and equipment utilized during response and recovery. o HSL-R10.8: Provide for compensation of external assistance (contract or cooperative assistance) by tracking utilization of these resources and ensuring prompt payment as indicated. o HSL-R10.9: Provide a summary of response and recovery impact on facility finances by documenting and analyzing the direct and indirect costs of EOP activation, including lost revenue. Institute for Crisis, Disaster and Risk Management The George Washington University 63 Appendix C – Healthcare Emergency Management Competencies x HSL-R11: Manage facility response so that it adheres to appropriate regulations and standards or seek relief as required. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R11.1: Describe permissible emergency response and recovery deviations from the normal standard of medical care provided under normal facility conditions, and the processes for seeking temporary suspension or relaxation of regulations during emergencies. o HSL-R11.2: Describe, in general, the applicable public health laws and their impact on the facility’s emergency response and recovery. o HSL-R11.3: Describe the process for verifying the credentials of healthcare and other professionals, from resources external to the facility, who offer assistance to the healthcare facility. o HSL-R11.4: Describe potential liability exposures that could occur for the facility and its patient care staff during emergency response and recovery. Skills o HSL-R11.5: Address appropriate healthcare regulatory issues during response and recovery by monitoring response activities for regulatory compliance and correcting deviations or appropriately justifying and explaining them. o HSL-R11.6: Request and obtain appropriate regulatory relief by contacting appropriate authorities and providing explanations of, and justifications for, the requests. o HSL-R11.7: Ensure appropriate credentialing and privileging of response personnel (from internal or external sources) to perform healthcare tasks, within the facility’s operations, by monitoring personnel activities for conformance to their specific expertise. o HSL-R11.8: Provide facility and personnel liability protection by documenting incident details surrounding occurrences with potential legal liability. x HSL-R12: Ensure that the Business Continuity Program considerations are incorporated into the facility’s Incident Action Planning (IAP) process. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R12.1: Describe the purpose and importance of a Business Continuity Program that is fully integrated into the facility EOP. o HSL-R12.2: Describe the elements and supporting functions of a Business Continuity Program as outlined in the NFPA 1600 Standard on Disaster/Emergency Management and Business Continuity Programs, 2004 Edition. Institute for Crisis, Disaster and Risk Management The George Washington University 64 Appendix C – Healthcare Emergency Management Competencies o HSL-R12.3: Describe how the Business Continuity Program aligns with overall Incident Command System (ICS) organization and procedures. Skills o HSL-R12.4: Include business continuity specific objectives in the Incident Action Planning process in order to address the recovery, resumption, and restoration of facility-specific services. o HSL-R12.5: Use (as appropriate) the Business Continuity support annex forms and guidance during emergency response and recovery. x HSL-R13: Assure that incident-specific safety guidance, in the form of an Incident Safety Plan and/or IAP safety message, is developed by the Safety Officer position through action planning and appropriately disseminated to responders. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R13.1: Describe the importance of empowering the safety office position to stop or alter incident operations that present immediate safety risks to responders, staff, patients, visitors or the integrity of the healthcare system. Skills o HSL-R13.2: Provide technical advice and other input into the safety plan and safety message development as indicated by technical background and the assigned position in Command and General Staff of the Incident Management Team (IMT). x HSL-R14: Ensure rapid and effective demobilization of the healthcare organization’s response resources, and eventually the emergency response itself, as the organization transitions to recovery operations. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R14.1: Describe the management of demobilization and the important processes that must occur during the demobilization process. o HSL-R14.2: Describe methods used to formally announce full or partial demobilization. o HSL-R14.3: Describe procedures for out-processing of personnel. o HSL-R14.4: Describe the procedures for conducting an initial incident review. Skills o HSL-R14.5: Guide the orderly demobilization of functional areas by ensuring that demobilization occurs as soon as the facility and/or resources are no longer needed for response (i.e. their specific response objectives have been met or otherwise resolved). Institute for Crisis, Disaster and Risk Management The George Washington University 65 Appendix C – Healthcare Emergency Management Competencies o HSL-R14.6: Provide clear explanation and notification of demobilization to relevant parties (internal and external), usually by demonstrating that response objectives have been met. o HSL-R14.7: Provide adequate out-processing of response personnel by ensuring adequate debriefings and assessments of performance as appropriate. o HSL-R14.8: Provide for an orderly initial incident review process (commonly known as a “hot wash”) by utilizing response procedures to conduct the meeting. x HSL-R15: Ensure recovery is accomplished to restore the healthcare organization to baseline operations and to capture important lessons for organizational improvement. Recommended proficiency for Primary Competency: operations level Knowledge o HSL-R15.1: Describe the overall process for managing the return of the organization to baseline operations and all activities to regular management oversight, including addressing the backlog of regular workload that accumulated during emergency operations. o HSL-R15.2: List critical equipment, priorities for rehabilitation, and the methods for re-certifying the equipment for future use. o HSL-R15.3: Describe the process for facility re-certification (if applicable). o HSL-R15.4: Describe the personnel rehabilitation process. o HSL-R15.5: Describe the After-Action Report process and methods utilized to keep the process orderly and constructive. Skills o HSL-R15.6: Manage the initial recovery operations by employing the same incident management structure and processes as used for the emergency response phase, with new objectives, personnel, and departmental assignments as needed; transition the management of residual recovery operations to everyday administrative functions as recovery management is terminated. o HSL-R15.7: Manage rehabilitation and re-certification for use of equipment and incident facilities by prioritizing areas for initial attention. o HSL-R15.8: Provide for personnel rehabilitation by disseminating the methods for response personnel to address psychological and/or physical concerns. o HSL-R15.9: Oversee the After-Action Report process by using facility procedures and processes that capture response deficiencies and best practices, and that incorporate accepted changes as EOP and emergency management program revisions (i.e., organizational learning). Institute for Crisis, Disaster and Risk Management The George Washington University 66 Appendix C – Healthcare Emergency Management Competencies Patient Care Provider (PCP) Physicians, physician assistants, registered nurses, licensed practical nurses, nurses working within expanded roles (CRNA, RNP, and others), emergency medical technicians, paramedics, and respiratory therapists and others who provide direct clinical patient care. Not included are clinical support staff that provide patient care services under the direct supervision of patient care providers: e.g., nurse’s aides, procedure technicians, orderlies, and others. x PCP-R1: Recognize situations related to patient care that indicate the need for full or partial activation of the healthcare system’s Emergency Operations Plan (EOP), and report them appropriately and promptly. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R1.1: Describe patient presentation criteria (unusual signs and symptoms indicative of deliberate illness/injury, indications of potentially epidemic illness/injury, unexpected rapid patient deterioration, difficult patient interventions such as decontamination, etc.) that indicate the possible need for EOP activation. o PCP-R1.2: Describe patient population profiles and other situation-based criteria (unusual numbers, very unusual contagiousness and other indications of increased risk to response personnel or current patients, etc.) that indicate the possible need for EOP activation. o PCP-R1.3 Describe resources available to Patient Care Providers in obtaining additional patient or situational information related to determining the need for activating the EOP. o PCP-R1.4: Describe the reporting requirements and the contact methods when events are recognized that may indicate the need for possible EOP activation (full or partial). Skills o PCP-R1.5: Identify situations within the regular clinical care area that should be reported for consideration of full or partial activation of the healthcare facility’s EOP. o PCP-R1.6: Report situations within the regular clinical care area by following EOP notification procedures and contacting the appropriate person (e.g., page operator, supervisor, etc.) as indicated by your specific role and by the situation at hand. o PCP-R1.7: Assist decision-makers with incident recognition by responding rapidly and adequately to their inquiries and requests for additional pertinent clinical and patient population information. Institute for Crisis, Disaster and Risk Management The George Washington University 67 Appendix C – Healthcare Emergency Management Competencies x PCP-R2: Participate in the mobilization of the your clinical area to transition from day-to day operations to the incident response organization and process. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R2.1: Describe the procedures necessary to prepare your clinical area, as indicated, for EOP response and recovery. Skills o PCP-R2.2: Ensure maximum patient surge capacity and capability and organizational resiliency by assisting in the mobilization of your clinical care area as described in the EOP. o PCP-R2.3: Establish and implement triage criteria based on actual and anticipated patient needs, disease parameters, and anticipated resources. o PCP-R2.4: Establish a decontamination area and other functions that are inactive during baseline operations, as indicated and per your individual assignment. o PCP-R2.5: Provide surge bed capacity for incident victims by accomplishing rapid disposition of existing patients in the emergency department, outpatient procedures area, and inpatient units as indicated by the EOP. o PCP-R2.6: Conduct actions as described in the EOP that are indicated for the specific incident parameters, including resource management and situation reporting. o PCP-R2.7: Ensure that external notifications (as relevant to your position) are coordinated through command and general staff x PCP-R3: Follow the healthcare Occupant Emergency Procedures (OEP) for your specific clinical care areas by assuring protective actions for patients and staff and by assisting others as necessary to accomplish the OEP directives. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R3.1: Describe the component parts of the OEP and your responsibilities to protect patients and, as indicated by your position, maintain accountability for patients, patient care information (charts, etc.) and clinical staff. o PCP-R3.2: Describe the methods to be used to maintain patient care during OEP activity, including during shelter-in-place, evacuation, or emergency events in the clinical unit. Skills o PCP-R3.3: Execute your roles and responsibilities in the facility OEP for protecting patients, patient information and others (as indicated) by Institute for Crisis, Disaster and Risk Management The George Washington University 68 Appendix C – Healthcare Emergency Management Competencies assisting with evacuating patients, establishing shelter-in-place, or other actions during OEP operations. o PCP-R3.4: Ensure continuous patient care by prioritizing and performing essential clinical interventions during OEP operations. x PCP-R4: Provide Surge Capacity by managing/treating increased numbers of patients (compared with day-to-day activities), regardless of etiology. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R4.1: Describe strategies and tactics appropriate to your clinical area that provide surge capacity for a significantly increased number of patients. o PCP-R4.2: Describe the triage processes necessary to match need with available resources in your clinical area. Skills o PCP-R4.3: Provide patient surge capacity by instituting and adhering to the EOP measures designated for your clinical area. o PCP-R4.4: Maximize the ability of patients to help themselves (when appropriate) by providing clear instructions and by enhancing their ability to help themselves (e.g., by controlling pain or other interventions). o PCP-R4.6: Manage or participate in degradation of overall services by prioritizing critical tasks and activities over less critical ones. o PCP-R4.7: Perform ongoing triage (matching resources to needs) to manage patient load by assigning priorities for services including diagnostic testing, pharmaceutical administration, operative intervention, blood infusion, and others. o PCP-R4.8: Provide continuous input into management decision-making by projecting resource needs for your clinical area as appropriate. x PCP-R5: Provide Surge Capability by managing/treating all incoming patients with specialty needs that vary significantly from day-to-day healthcare system activities. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R5.1: Describe special etiologies that may tax the facility response, even with limited numbers of patients. o PCP-R5.2: Describe the pathophysiology of injuries and illnesses associated with mass casualties and the indicated interventions for your clinical discipline. o PCP-R5.3: Describe threats or hazards posed by these types of patients. o PCP-R5.4: Describe methods for hazard/threat containment for these types of patients (as applicable). Institute for Crisis, Disaster and Risk Management The George Washington University 69 Appendix C – Healthcare Emergency Management Competencies o PCP-R5.5: List resources where technical information may be found that may assist with caring for patients with these needs. Skills o PCP-R5.6: Demonstrate understanding of injury and illness associated with these specialty-needs patients by providing the appropriate interventions to minimize further injury/illness and to maximize patient recovery. o PCP-R5.7: Provide evidence-based care for these patients by accessing technical expertise as appropriate. o PCP-R5.8: Perform special situation procedures per the EOP annexes and as indicated by event circumstances (e.g., decontamination, isolation, etc.) o PCP-R5.9: Contain hazards/threats posed by patients (as applicable) by removing the hazards from the patients, the use of PPE, appropriately locating patients or other measures. o PCP-R5.10: Adhere to appropriate chain custody procedures as applicable to the particular situation at hand. x PCP-R6: Provide for efficient information processing for your clinical area through both reporting and receiving information according to established time schedules. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R6.1: Describe the types of relevant information that are required for reporting from your clinical area. o PCP-R6.2: Describe the format and timing of reporting information from your clinical area. o PCP-R6.3: Describe the methods in which your clinical area should receive incident information during emergency response and recovery. Skills o PCP-R6.4: Provide input into the healthcare system’s incident planning through updates (as requested) on situation (patient care, continued or recovered function of patient care systems, etc.), resources (pharmaceuticals, equipment and medical supplies, etc.), special problems encountered, and tasks completed in your clinical area. o PCP-R6.5: Ensure tracking of incident patients by providing updates (as requested) on numbers, types, and locations of patients as well as interventions required. o PCP-R6.6: Ensure appropriate designations are used for patient tracking (‘meets case definition for incident’, ‘suspicious for case definition,’ etc.) as applicable. o PCP-R6.7: Provide prompt notification when patient care activities reveal information that dictates major or sudden changes in response strategies. o PCP-R6.8: Deliver or participate in briefings conducted for your clinical area. Institute for Crisis, Disaster and Risk Management The George Washington University 70 Appendix C – Healthcare Emergency Management Competencies x PCP-R7: Manage the psychological impact on victims, victims’ families, and staff through both preventative and therapeutic measures. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R7.1: Describe the potential psychological effects on incident victims and their families and the indicated interventions for your clinical discipline. o PCP-R7.2: List the potential psychological effects on responding personnel and the indicated interventions for your work area. o PCP-R7.3: Describe preventative methods that may lessen the psychological impact on victims, victims’ families, and staff. Skills o PCP-R7.4: Provide psychological and emotional support to patients and their families as indicated by your clinical discipline. o PCP-R7.5: Provide information on the event, its etiology, and facility interventions to patients and family members in your clinical area (written if possible). o PCP-R7.6: Provide frequent updates on expected interventions for individual victims to the family members in your clinical area. o PCP-R7.7: Assist with the identification of specific stressors for staff in your work area and report them to your supervisor. o PCP-R7.8: Assist with assigned measures designed to reduce staff stress during response and recovery (e.g. facilitating information dissemination amongst staff). x PCP-R8: Incorporate relevant safety practices and procedures in all incident operations for your clinical area. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R8.1: Describe categories of hazards that may pose a risk to clinical staff during emergency response and recovery. o PCP-R8.2: Describe interventions for clinical staff and others to reduce the potential risk created by incident parameters. Skills o PCP-R8.3: Participate in or conduct safety briefings (based upon the incident Safety Plan) during each work cycle. o PCP-R8.4: Adhere to universal precautions and infection control procedures (whether day-to-day or specific to the incident) as indicated. o PCP-R8.5: Adhere to appropriate work cycles for your clinical area. o PCP-R8.6: Select and use appropriate PPE when applicable. Institute for Crisis, Disaster and Risk Management The George Washington University 71 Appendix C – Healthcare Emergency Management Competencies o PCP-R8.7: Provide for safe use of PPE by monitoring those individuals utilizing PPE. o PCP-R8.8: Minimize security-safety risk to clinical personnel by coordinating with facility security personnel. x PCP-R9: Integrate outside resources into your clinical area as required to meet response objectives. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R9.1: Describe procedures for requesting, receiving, briefing, assigning and supervising clinical personnel from other clinical units or from other facilities. o PCP-R9.2: Describe procedures for requesting, receiving, rapid inservicing and using equipment and supplies (especially items that aren’t normally used in your clinical area). Skills o PCP-R9.3: Initiate requests for outside resources by delineating specific needs in the required format. o PCP-R9.4: Assist in the integration of personnel from outside your work area by ensuring they participate in briefings on operations in your area and monitoring their response actions o PCP-R9.5: Integrate equipment and supplies from outside your clinical area by ensuring familiarity with their use and by tracking their use. o PCP-R9.6: Provide appropriate utilization of technical expertise by assessing the source and incorporating applicable recommendations. x PCP-R10: Follow recovery procedures for your clinical area that promote rapid return of the facility to baseline activity. Recommended proficiency for Primary Competency: operations level Knowledge o PCP-R10.1: Describe policies and procedures for rehabilitation of patient care and clinical support personnel. o PCP-R10.2: Describe procedures for reassessing your clinical area’s patient population and planning for resolving surge needs. o PCP-R10.3: Describe the responsibilities, specific to your role, for rehabilitation of your clinical area. o PCP-R10.4: Describe the policies and procedures for formal After Action Report of patient care in your clinical area. Skills o PCP-R10.5: Demonstrate an understanding of the importance of personnel rehabilitation activities by participating in personnel rehabilitation as instructed. Institute f…
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Ethical Dilemmas In The Same Situations With Different People

Ethical Dilemmas In The Same Situations With Different People

100 to 200 words. Time toman 12 APA, reference one- Be deatiled.

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  • Is it possible for one person to have an ethical dilemma with a situation and for another person not to have a dilemma in the same situation? Why or why not?

The Case of Jesica Santillon

The Case of Jesica Santillon

The word count distribution must include at least 350 words in response to each question. 1400 words total and 3 scholarly sources total. I wanted to address the “Real Time” requirement in the Case Summary section so that you don’t lose points unnecessarily. Here is a rule of thumb to work with: If the issue did not occur after January 2018, it should not feature in your case summary. This means your Case Summary essay should be an update of what has occurred over the past 12 months.

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In addition, don’t quote scholarly journal articles in the Case Summary. Typically, scholarly journal articles will not be “real time.” Moreover, quoting scholarly journals in the Case Summary tends to make students stray into analysis and application, rather than remaining focused on summary. The scholarly journal references should be reserved for your analysis and application essays. References for the Case Summary section should be current online sources. RESEARCH: You need to cite at least three Scholarly Journal articles in addition to citing the course textbook.

Library research is required in the COMPLETE assignment of each unit. At least (2) of your citations must be from scholarly journal articles with references and must use citations from the downloaded book, Burns, L. R., Bradley, E. H., & Weiner, B. J. (2011). Shortell and Kaluzny’s Health Care Management: Organizational Design and Behavior (6th ed.).

Wikipedia, Wiki Answers, About.com, Ask.com, Yahoo Answers, eHow, Personal blogs, and other sources of that ilk are not credible for academic work. Quoting such sources as credible is strictly forbidden.

Finding Articles in EBSCO (Library Help)

Power Point Presentation Essay

Power Point Presentation Essay

PowerPoint Presentations of 15-20 slides

Slides should have no more than 4-6 lines of text per slide, and 1-3 ideas per slide max. Text should be in bullet format, not paragraph/prose format. Information should be conveyed in a concise but comprehensible manner. With speaker notes.

Overview of a regulatory agency healthcare emergency management standards and/or regulations (choose one). Don’t just provide background. Be sure to take a deep dive and describe the importance of the regulatory agency and how their regulations have impacted healthcare.

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  • Centers for Medicare & Medicaid Services (CMS)
  • National Firefighter Professionals Association (NFPA)
  • The Joint Commission (TJC)

Journal articles preferred as references

 

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