CoP Educational Series Part 6: Emergency Preparedness

Posted on Thursday, July 13, 2017 6:57 PM

Emergency Preparedness requirements set forth in the newly revised CoPs mirrors the Federal mandate that goes into effect in November of 2017 for most other Medicare certified providers. Included in the Standards for this CoP is an Emergency Plan, Emergency Preparedness Policy and Procedures, a Communication Plan, Training and Testing and provisions for those home health agencies that are part of an integrated health system.

Home Health agencies are required to have an Emergency Plan that must be in place and reviewed and updated at least annually. The plan must be based on a facility and community-based risk assessment using an all hazards approach. It must also include strategies for addressing emergency events as outlined in the risk assessment. Also addressed is the patient populations, including what services the home health agency has the ability to provide during an emergency and the continuity of care during this period of time. Included in the Plan is the process for cooperation and collaboration with all emergency preparedness officials.

Emergency Preparedness Policies and Procedures are also required. They too must be reviewed and updated at least annually. The policies and procedures must define how an agency handles patients during a disaster that must be addressed in the comprehensive assessment for each patient. Procedures must also include the notification of local and state officials regarding patients needing evacuation and on how services will be delivered when there is an interruption of services due to an emergency. The home health agency is also required to report to local and state officials any on-duty staff and patients they are unable to contact and have a process for using volunteers or other staff to accommodate a surge needs during an emergency. The patient’s confidentiality and PHI is of the upmost importance and the agency must address how it will be protected during an emergency.

The Communication Plan is required and must be reviewed and updated at least annually. Contact information for staff, contracted entities or individuals providing services to the home health agency, all patient’s physicians, volunteers and all emergency preparedness staff and any other sources of assistance. The agency must have both a primary and secondary means of communicating with staff and emergency preparedness personnel. The Communication Plan must also outline the manner in which the agency will implement a process for the sharing of patient information to ensure continuity of all care.

Home health agencies are required to implement a training and testing program covering all aspects of the Emergency Preparedness requirements. This program must be reviewed and updated at least annually. The training must be provided at least annually to all staff, volunteers and any individuals providing services to the agency and all training provided must be documented.  At least annually, the agency must conduct Emergency Preparedness testing and participate in a full-scale community based Emergency Preparedness exercise. If there is no community-based Emergency Preparedness exercise to participate in, the agency must test within their facility. A second community or facility based exercise must also be conducted. The second event can be a table top exercise including group discussion and led by a facilitator. 

Lastly, home health agencies that are a part of an integrated health system that includes other Medicare certified providers, has the option of participating with the system’s emergency preparedness plan. If the home health agency chooses to participate with the system, they must ensure the agency’s patient population and services are considered and incorporated into the overall plan.

Written by Peggy Patton, Vice President of Education Services

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