Recently I fielded a question regarding the requirements for organizations to have department-level emergency response plans and what those requirements might represent in terms of specific elements, etc. I have to admit that my initial reaction was that I really didn’t see much rationale in the creation of detailed department-level response plans; to be honest, it sounded very much like busy work, but that may just be me. But upon reflection of what is actually required (at least for the moment—still waiting on the Conditions of Participation “version” of emergency response—I’m sure that will result in some interesting conversation), while I can’t make a completely unassailable case for department-level plans (with some exceptions, but those may pivot on an organization versus department assessment), there may be some value in at least looking at the concept (in recognition that there is nothing in the requirements that specifies department-level plans; department level planning is certainly in the mix, but written plans, not so much).
By parsing the response elements to the tried and true Joint Commission model, we’d want to account for communications, management of resources and assets, management of staff roles and responsibilities, management of safety and security, management of utility systems and capacities, and the management of patient care and support activities (is that six elements? Yes!). My thought is that the critical infrastructure needs would “live” in the organization’s response plan and that most of the department-level plans would be along the lines of “consult with incident command” during a response activation—and isn’t that kind of the purpose of IC anyway?
Which leads me to the question of how much a department-level plan is going to deviate from/bring value to what is already included in the organizational response plan? I’m having a very difficult time convincing myself that what any organization “needs” when it comes to emergency response is yet another layer of plans. For all intents and purposes, the more layers you have underneath the command function, the more intricate the communications lines, etc. and to my way of thinking, intricacy is not necessarily a hallmark of effective emergency response. When I think of the command function/structure, while you certainly want to have some “distance” between the deciders and the doers, I would think that (at least at the organization level) you would want an org chart that is reasonably “flat” (precipitous command structures make me nervous; they just seem to be less flexible in the moment).
So, dear audience, have any of you folks gone down this road of developing department-level response plans (recognizing that there are certain departments, like materials management and food services, that have a role in supporting the entire organization’s response capabilities)? If you have, has it been worth the efforts to do so? Or did you look at it and decide, from a prioritization standpoint, that the value in doing so did not represent a worthwhile investment? Any feedback/discussion would be very much appreciated.
One topic upon which I’ve not weighed in is the proposed changes to The Joint Commission’s Emergency Management and Leadership standards to more clearly reflect the responsibility of organizational leadership to provide oversight of the Emergency Management function in both critical access hospitals and “regular” hospitals. (Details can be found here: http://tinyurl.com/buozat3)
The proposed changes have been open for comment since late October, but the field review process (which can – and hopefully has/will – include your thoughts and comments, boys and girls) is coming to a close (December 4, 2012 is the cutoff date) and I didn’t want you folks to miss out on the opportunity to shape the future (that’s probably a wee bit hyperbolic, but that’s me).
Now, to be completely honest with you, I hadn’t really looked too closely at the suggested changes, as much because I think there’s likely to be pushback from some folks to “soften” the language in the Leadership chapter regarding the anointing of an individual to be the “emergency manager” (that’s my euphemism). And after what happened in NYC post-Sandy, this could end up being a very interesting conversation.
I can’t honestly say that I disagree empirically with anything they’re proposing; they still seem convinced that hospital leaders will not take this stuff seriously (unless they are well and truly “on the hook”). I suspect that there’s going to be a lot of up-selling at individual hospitals that the changes mean that someone must be hired specifically to handle emergency management, which will, in turn, cause consternation among those in healthcare who count the beans, which will, in turn, result in TJC having to clarify what they mean.
But again, I don’t think that what they are suggesting is out in left field, or– to any great extent–unreasonable. I’ve been to any number of hospitals where the leadership oversight of the EM program is one “hat” among many, but not every healthcare organization is in the crosshairs of crazy levels of emergencies (part of me can’t escape the thought that Sandy, like Katrina, was an event above and beyond what they could normally expect to experience, based on past history), so there will always be some level of variability. In looking back at the last 18-24 months, we’ve had a lot of catastrophic events directly impacting hospitals. For whatever reason, hospitals had never really taken a direct hit from a tornado until last year; so, does what happened in Joplin last year change how you have to look at things, particularly in tornado country? Absolutely, but that’s how you have to manage risk – focus on what you know has happend/can happen, and then work on the rest of it as time permits.
At any rate, I would encourage any of you folks out there who have not taken advantage of the field review to weigh in and raise the conversation to an ever-more-thoughtful level. You folks, as I like to say, are living the dream– and your stories/challenges are invaluable to this process. Make yourselves heard, lads and lassies, make yourselves heard!
There’s nothing I like more than questions from the studio audience, so this week I thought I’d field a question on one of those risks that never seems to go away completely, as much because there are not very many specific requirements. So, let’s consider abduction drills.
The current situation at this particular organization involves what I think is a pretty good cross-section of activities: campus-wide drills, suspicious person(s) on the unit drills, mother/baby-specific drills, as well as random quizzing of staff throughout the organization on their role(s) in the infant abduction policy (they have to answer 10 questions about the policy), and a monthly operational test of the infant security alarm system. Again, I think that’s a very good start to things. But it does sort of beg the question as to what requirements exist? Well, dear reader, I beg you, please read on.
Strictly speaking, The Joint Commission (TJC) does not have a great deal that could be characterized as requirements in this regard. EC.02.01.01 EP #9 requires hospitals to have written procedures that can be acted upon in the event the hospital experiences any security incident, including abductions of infants of pediatric patients. That’s pretty much all there is in the standards. I’m presuming that you have a written procedure for responding to an infant and/or pediatric abduction incident, so we’re off to a good start. [more]
Lately, I’ve encountered some consternation relative to emergency management, specifically EM.02.02.07, for communicating in writing to each licensed independent practitioners their role in an emergency and to whom they would report in an emergency.
From my experiences, there are any number of ways to demonstrate compliance with this performance element, and to be honest, I’ve not heard of any Joint Commission surveyors “pushing” on this issue, but it could certainly be a vulnerability. One way folks comply with this standard is through credentialing and/or re-credentialing, making use of a process that is already in place. I’m presuming that you have e-mail access for your medical staff members, in which case a simple summary of their duties/roles in an emergency response activation would suffice. Another thought would be handouts at your regularly scheduled medical staff meetings, though, depending on attendance, this might be a tough one to sell if you have a particularly picky surveyor. Anything along these lines would be quite adequate as a demonstration of compliance with this standard.
By the way, the standard does not specify a frequency, so–at least for the moment—you need only document one communication of this nature. It would certainly be appropriate to inform medical staff of substantive changes in their roles, etc., but that would not be considered a standards-based requirement.
Could I have a volunteer from the audience?
Whilst working in the upper part of the Midwest, I found an interesting take on how one might gather volunteers to help out as “victims” when conducting an emergency response exercise that calls for said victims (“paper” patients are OK in a pinch, but isn’t it way more fun/realistic to have some flesh-and-blood types to run through the process?) In this particular area, high school students, in order to fulfill their obligations for graduation, are charged with participating in X number of community service hours during their (hopefully) four-year stint. If I may opine for a moment, I think the community service idea is way cool and with any luck, might bring back the whole “taking care of each other” mindset that seems to have fled screaming into the night. I see way too much trash dumped by roadsides, etc., to think that we are accelerating as a culture toward a positive destination . . . but I digress.
At any rate, a process was set up with the schools that allowed for participation in emergency exercises to count toward the community service requirement. How cool is that? I don’t know if you have such a program in your neck of the woods, but I think it’s definitely worth checking out. And if you’re already doing this, how come you didn’t share it with the group? Shame, shame, shame…
This is a public service announcement—with guitars! (Okay, maybe not guitars) or perhaps this will work:
Money well spent…imagine that.
Every once in a while I like to share stuff that folks are developing in other areas of concerns/disciplines, and I think this one is a peach. In fact, I think it’s so useful, I’m just going to thank my good friend and colleague Marge McFarlane for sharing this with me, which helps me to share with you, and then shut the heck up:
The American College of Emergency Physicians is proud to announce the release of its newest training, Hospital Evacuation: Principles and Practices. The training can be found here.
We hope that you take the time to view the course and pass the information along. A description of the course can be found below:
“Healthcare facilities must be ready to tackle anything that comes their way. In times of disaster, natural or technological, they must remain open, operational, and continue carrying out their functions. When the situation escalates to a level that endangers the health and/or safety of the facilities patents, staff, and visitors, evacuation of the endangered areas is necessary. Safety and continuity of care among evacuees during a disaster depend on planning, preparedness, and mitigation activities performed before the event occurs. At the completion of the course, hospitals and other healthcare providers with inpatient or resident beds will have basic training and tools to develop an evacuation plan. This one-hour course will take the participant through the stages of preparing for a facility evacuation. It begins by performing an assessment of possible vulnerabilities and the resources available to a facility. Next, the course walks the learner through the development of a functional plan for a healthcare facility, and identification of key personnel positions implemented when a facility evacuates and the roles and responsibilities of each. The course concludes by addressing recovery issues, both plan development and operational.”
Good stuff, and I encourage each one of you with anything more than a passing interest in such things to check it out.
Every emergency is different from every other emergency, and every moment in every emergency is different from every other moment in an emergency, and each person’s situation is going to be different.
What it comes down to is organizations must strive to provide sufficient comfort for staff members to be able to show up at work and be productive.
It shouldn’t be difficult to figure out [more]
The surveyor cadre is not particularly knowledgeable about the practical application (and implications, for that matter) of federal level emergency management activities.
There is a broad-based Joint Commission requirement for organizations to comply with applicable local, state, and federal laws and regulations, but even the National Incident Management System and Hospital Incident Command System only truly become “requirements” when [more]