CMS Emergency Preparedness Requirements for
Home Health Care
Requirement: Emergency Plans
Develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach. Include strategies for addressing emergency events identified by the risk assessment. Address patient population, including, but not limited to, the type of services the HHA has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
SafePlans’ ERIP system streamlines the emergency plan development process. With ERIP, plans are easier to complete and maintain, especially since plans are accessible via secure Internet, in pdf files for downloading and printing, and the ERIP mobile app.
Requirement: Policies and Procedures
Develop and implement emergency preparedness policies and procedures, based on the emergency plan, risk assessment and communication plan. Policies and procedures must be reviewed and updated at least annually. The policies and procedures must address the plans for patients during a natural or man-made disaster. Individual plans for each patient must be included as part of the comprehensive patient assessment. Procedures to inform State and local emergency officials about patients in need of evacuation at any time due to an emergency situation based on patient’s medical and psychiatric condition and home environment.
Procedures to follow up with on-duty staff and patients to determine services needed, in the event of interruption in services during or do to emergency. Inform State and local officials of any on-duty staff or patients unable to be contacted. A system of medical documentation that preserves patient information, protects confidentiality of patient information, and secures and maintains the availability of records. The use of volunteers in an emergency or other staffing strategies, including process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.
ERIP brings policies out of the typewriter age and into the modern era. Create, share and collaborate online, via the ERIP app and of course via PDF documents suitable for printing. As a procedure is updated, all stakeholders can be alerted via email, push notification in the ERIP app AND via text message.
Requirement: Communications Plan
Develop and maintain an emergency preparedness communication plan that complies with Federal, State, and local laws and must be reviewed and updated at least annually. The communication plan must include names and contact information for Staff, Entities providing services under arrangement, Patients’ physicians, and Volunteers.
Contact information for the following is also required: Federal, State, tribal, regional, and local emergency preparedness staff, Other sources of assistance, Primary and alternate means of communicating with staff, Federal, State, tribal, regional, and local emergency management agencies, a method for sharing information and medical documentation for patients under care, as necessary, with other health care providers to maintain continuity of care, a means of providing information about the general condition and location of patients under the facility’s care as permitted under 45 CFR 164.510(b)(4), a means of providing information about the HHAs needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.
A Communications Plan developed in ERIP insures all stakeholders have access to an interactive communications plan that may be linked to communications resources such as mass notification systems.
Requirement: Training and Testing
Develop and maintain an emergency preparedness training and testing program based on the emergency plan, risk assessment, policies and procedures at paragraph and the communication plan. The training and testing program must be reviewed and updated at least annually. The HHA must do all of the following: Initial training in emergency preparedness policies and procedures of all new and existing staff, individuals providing on-site services under arrangement, and volunteers, consistent with their expected roles and provide emergency preparedness training at least annually. Maintain documentation of the training. Demonstrate staff knowledge of emergency procedures.
Conduct exercises to test the emergency plan at least annually. Participate in a community-based full-scale exercise or when a community-based exercise is not accessible, prticipate in an individual, facility-based exercise. If an actual natural or man-made emergency occurs that requires activation of the emergency plan, the HHA is exempt from engaging in a community-based or individual, facility-based full-scale exercise for 1 year following the onset of the actual event. Conduct an additional exercise that may include, but is not limited to a second full-scale exercise that is community-based or individual, facility-based. A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan. Analyze the HHA’s response to and maintain documentation of all drills, tabletop exercises, and emergency events and revise the HHA’s emergency plan, as needed.
ERIP includes eLearning courses for staff and web-based tabletop scenarios. All staff training may be scheduled and tracked in ERIP.
If part of a healthcare system consisting of multiple separately certified healthcare facilities that elects to have a unified and integrated emergency preparedness program, the HHA may choose to participate in the healthcare system’s coordinated emergency preparedness program. If elected, the unified and integrated emergency preparedness program must demonstrate that each separately certified facility within the system actively participated in the development of the unified and integrated emergency preparedness program, be developed and maintained in a manner that takes into account each separately certified facility’s unique circumstances, patient populations, and services offered,
demonstrate that each separately certified facility is capable of actively using the unified and integrated emergency preparedness program and is in compliance with the program, include a unified and integrated emergency plan that meets all of the previously stated requirements of this section. The unified and integrated emergency plan must also be based on and include a documented community-based risk assessment, utilizing an all-hazards approach, a documented individual facility-based risk assessment for each separately certified facility within the health system, utilizing an all-hazards approach, include integrated policies and procedures that meet the requirements set forth in the coordinated communication plan and training and testing programs.
ERIP’s assessment module allows the tracking of all requirements. Assessments can be conducted within the ERIP app.