RSSAll Entries Tagged With: "all-hazards emergency preparedness"

Walking in the shadow of the big man: CMS isn’t done with emergency preparedness

Imagine that!

The turn of February brought with it the latest epistle from our friends at CMS as they continue to noodle on the preparedness of the nation’s hospitals. I don’t know that this represents a ton of hardship for folks and I do know, for at least some folks, the latest directive is fairly straightforward as a function of their emergency preparedness programs, activities, etc. As we’ve discussed once or twice over the years (decades?!?), emergency preparedness is a journey, it is not a destination. And while we do have the opportunity to plot our own course on this, it seems that the regulatory oversight piece will never be very far away.

So, the first piece of this (you can find the whole missive here) is the pronouncement that planning for using an all-hazards approach to emergency management (and who isn’t?!?) should also include consideration of emerging infectious disease (EID: Influenza, Ebola, Zika, etc.) threats. The guidance goes on to indicate that planning for EIDs “may require modifications to facility protocols to protect the health and safety of patients, such as isolation and personal protective measures.” I think my immediate inclination would be to include EID threats as a separate line item for your HVA (my fear being if you integrate things too well into your existing, then you’ll be that much harder-pressed to “pull out” the EID portion of your organizational analysis). And/or if you combine all the IC stuff into one, then you might make changes to your plan to address the higher-risk stuff and create some operational challenges for your “normal” stuff. It’s early in the game on this one, so we’ll see how the process matures.

Next up we have some discussion relative to the use of portable/mobile generators as part of our emergency preparedness activities. It would seem that a lot of folks reached out to CMS to see if they were going to have to replace portable/mobile generators with the typical generator equipment found in hospitals, and (hooray!) the answer to that question is no, you don’t have to: unless your risk assessment indicates that you should. Apparently, there were other questions relating to the care and feeding of portable/mobile generators and the ruling on the field is that you would have to maintain them in accordance with NFPA 70 (and, presumably, the manufacturers’ IFUs), which includes:

  • Have all wiring to each unit installed in accordance with the requirements of any of the wiring methods in Chapter 3.
  • Be designed and located to minimize the hazards that might cause complete failure due to flooding, fires, icing, and vandalism.
  • Be located so that adequate ventilation is provided.
  • Be located or protected so that sparks cannot reach adjacent combustible material.
  • Be operated, tested and maintained in accordance with manufacturer, local and/or state requirements.

It also mentions that extension cords and other temporary wiring devices may not be used with the portable generators, so make sure that you have those ducks in a row.

There are a few more things to cover, but I think those can wait until next week. See you then!

The exodus is here: Are you prepared?

Some say not so much.

First off, many thanks to the standards sleuths out there that assisted on solving last week’s missing EP caper; it’s nice to know that I am not merely orating into the void (oration being a somewhat hyperbolic description of this blog—lend me your eyes!).

Now, on to our continuing coverage of emergency management stuff.

The ECRI report outlining the Top 10 Patient Safety Risks for 2018 (if you missed it last week, you can download it here), does make mention of all-hazards emergency preparedness as #7 on the Top 10 list, though I have to say that their description of the challenges, etc., facing hospitals was whatever word is the opposite of hyperbolic (I did a quick search for antonyms of hyperbolic, but nothing really jumped out at me as being apropos for this discussion), pretty much boiling down to the statement that “facilities that were prepared for…disasters fared better than those that were not.” And while there is a certain inescapable logic to that characterization, I somehow expected something a bit weightier.

That said, the ECRI report does at least indicate that there may have been hospitals that were prepared, which is a little more generous than hospital preparedness was described in the report from our friends at the Johns Hopkins Bloomberg School of Public Health Center for Health Security (you can find the report here). The opening of the Hopkins report goes a little something like this: “Although the healthcare system is undoubtedly better prepared for disasters than it was before the events of 9/11, it is not well prepared for a large-scale or catastrophic disaster.” Now that is a rather damning pronouncement, and it may be justified, but I’m having a bit of a struggle (based on reading the report) with what data was used in making that particular pronouncement. I’m not even arguing with their recommendations—it all makes abundant sense to me from a practical improvement standpoint—and I think it will to you as well. But (I’m using a lot of “buts” today), I’m having a hard time with the whole “is not well prepared” piece (in full recognition that it is healthcare as a single monolithic entity that is not well prepared). Could hospitals be better prepared? Of course! Will hospitals be better prepared? You betcha! Could hospitals have more and better access to a variety of resources (including, and perhaps most importantly, cooperation with local and regional authorities)? Have the draconian machinations of the federal budgeting process limited the extent to which hospitals can become prepared? Pretty sure that’s a yes…

Could the nation (or parts therein) experience catastrophic events that significantly challenge hospitals’ ability to continue to provide care to patients? Yup. Will the nation (or parts therein) experience catastrophic events that significantly challenge hospitals’ ability to continue to provide care to patients? Probably, and perhaps (given only the weather patterns of the last 12 months or so) sooner rather than later. There have always been (and there always will be) opportunities for hospitals to improve their level(s) of preparedness (preparedness is a journey, it is not a destination), including building in resiliency to infrastructure, resources, command leadership, etc. And while I appreciate the thought and preparation that went into the report, I can’t help but think that somehow this is going to be used to bludgeon hospitals on the regulatory front. In preparation for that possibility, you might find it useful to turn your emergency management folks loose on a gap analysis relative to the recommendations in the report (again, I can’t/won’t argue with the recommendations—I like ’em), just in case your next accreditation surveyor tries to push a little in this realm.