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You probably already know about this, but…the threats just keep on coming

Just when you thought 2020 couldn’t get any more dramatic (we even had an earthquake this morning in Southern New England—I don’t know that I had ever knowingly experienced one before), but a warning from the Feds regarding nefarious “actors” (I placed that in quotation marks as an homage to my friend, and former editor, Scott Wallask) attempting to target healthcare facilities, et al. I’m sure your IT folks are all over this, but I’m thinking that if you were looking for a non-COVID-related emergency response exercise scenario, evaluating your organization’s response to this latest threat might be worth a look-see. It will be interesting to see how this develops over time as a subtext to everything else that’s going on. If you’re looking for greater detail, I think you’ll find these links useful:

It seems unlikely that this will be the last time we hear about such attacks.

In other preparedness news, under the category of “other things that happen while you’re busy responding to a pandemic,” there was a “hard landing” of a helicopter on the roof of USC Keck Medical Center out in Los Angeles. Fortunately, no one was badly injured, but it just goes to show you that (and it seems particularly so this year) you never know what’s coming next.

Hope you all are well and staying safe!

At what point does an emergency response activation become the ‘new normal’?

As we approach the “end” of 2020 (and holding on to the hope that 2020 won’t find a way to persist into next year), I was pondering the question of how one might meet the requirement for a second emergency response activation if one did not have the extraordinary foresight to plan and conduct an exercise before the wheels fell off the world back in March. My thought was that the complexities of the current situation (and the onset of the “flu season”) might give you enough variation to parse the current response (certainly we are not in the same “place” as we were back in the spring) into two evaluations (making sure that we are accounting for an evaluation of the critical response elements: communications, resources and assets, staff roles and responsibilities, safety and security, utility systems, patient care). I suppose one could also “leverage” the update of your hazard vulnerability analysis (HVA)—if you have had a spare moment to do so. As I recall, everyone had pandemic on their HVA, with varying degrees of presumed preparedness. It will be interesting/instructive to see how well your previous analysis matched up with how your organization has fared thus far. It is certainly within the realm of improvement to evaluate current response activities in terms of lessons learned over the past few months (and extrapolating into the next few months).

One glimmer of hope for organizations that are accredited by The Joint Commission is a note attached to the drill requirements that indicates that organizations are exempt from engaging in their next full scale exercise following the onset of the emergency event. My “read” is that (and I believe that this applies for as long as the presidential declaration is in place) folks are allowed to focus their attentions on managing the emergency at hand as opposed to having to come with something else (new, different, etc.) to exercise. I hope to get some confirmation of this over the next little while, but I’d be interested to hear from anyone that has undergone recent survey—my hope is for some flexibility on this count—in full recognition that flexibility has not necessarily been the hallmark of the survey process of late.

At any rate, as this whole megillah had a beginning (and is certainly having a middle), hopefully it will have an end that results in a return to the “old normal.”

Hope you are all well and staying safe. Please stay in touch as you can!

The impossible year continues: Emergency response in 2020

Interestingly enough, I don’t believe that I have a great deal of yammering to do this week; not sure if it’s just a case of mental fatigue with all that continues to transpire (or I daresay, escalate) in terms of community emergencies of virtually every and any imaginable kind. Just between COVID-19 and a typical hurricane season, it would have been an adventure of epic proportions, but perhaps a wee bit more manageable than the various forces assailing the planet. But no, what in the past had tended to be rather transient in nature has now turned towards an aggregation of conditions that rivals…certainly nothing in recent memory and perhaps not ever (the Dark Ages, maybe).

One of the positive byproducts of such a year as this is the ongoing development and promulgation of resources – I have maintained, and will continue to do so, that hospitals are generally pretty well prepared to deal with “stuff.” As I see it, the whole point of preparedness is to be able to manage circumstances (be they singular or plural) without “breaking” (by breaking, I mean a catastrophic failure of response such that folks are actually placed in unprotected risk because of the break, as opposed to facing a situation in which hospital operations would need to be altered, moved, etc.). There are no perfect organizations when it comes to this, which is as it should be—but that doesn’t mean that folks are content to rest on past experiences, but rather to build on those experiences and make improvements. The magnitude of events this year has tested the healthcare industry in ways that would only have been predicted as a hyperbolic planning exercise (this year has been a whole lot of “and then this happens”). As has been the case any number of times in the past, hospitals and other healthcare organizations have had to manage things on their own and/or with community partners as the upper levels of the response infrastructure have been less effective than might have been desired (not pointing any fingers—this is not the first time, nor is it likely to be the last time that the most effective response happens at the local level).

At any rate, there are a few resources that I’ve noted over the past couple of weeks that I wanted to share. I somehow doubt that you’ll have a lot of spare time with which to review written materials, but I’m thinking that at least the links to these materials will be in a place you can “find” again. Lots of stuff here, a lot of it coming out of the response to wildfires in California, but as a primer for relocation, establishing alternative care sites, etc., there is much that is applicable to any untenable emergency condition:

As always, I hope this finds you safe and in reasonable sanity. I would like to think that we’ve got more of this behind us than in front of us, but the numbers are frowning at me, so I will just hold that hope…until next time!

Now that Superstorm Sandy has taken on the rosy hue of nostalgia…you mean it hasn’t?!?

By now I’m sure you’ve seen information regarding the CMS report that weighs in on hospital response during Superstorm Sandy and the challenges faced by hospitals during that October 2012 event.

Now, some of the media reports covering this particular issuance from CMS have painted kind of a bleak picture, but I don’t know if that is strictly the case. Certainly, there were, and likely will continue to be, challenges relating to response to any emergencies, but in looking at the data contained in the report, I ultimately can’t help but think the response efforts on the part of the hospitals in the New York metropolitan area and adjacent areas were pretty darn good.

Again, some of the coverage seems to highlight the 89% of hospitals that “reported experiencing critical challenges during Sandy, such as breakdowns in infrastructure and community collaboration” and equate “experiencing critical challenges” with “not being prepared.” Now I will freely admit that I have not exercised operational responsibilities in a hospital for about 13 or so years, but my recollection about such things is that one of the things that makes emergencies, like, emergencies, is that you experience critical challenges that could include breakdowns in infrastructure, etc. For me, the most important nuggets that are presented in the report are that:

  • Only 7% of the hospitals involved had to fully or partially evacuate (and yes, I do indeed recognize that evacuation is an entirely acceptable and appropriate response if the conditions dictate)
  • Only one hospital indicated that its emergency plan was not useful
  • No patient perished as the result of a hospital’s inability to appropriately respond to the disaster

Of course, there were a number of instances of flooding out of infrastructure components and some challenges relating to the whole idea of clinical folks not being able to use powered equipment to deliver IV fluids, etc., (I think it’s probably a good idea to look at those pesky clinical interventions in the case of utility systems or medical equipment failures; something tells me that this might become a wee bit more of a focus during your next TJC visit), but I will direct you back to #3. To me, this means that there was definitely some rough sledding as Sandy came and went, but the folks on the ground were able to keep things together, which is a pretty good measure of preparedness. If nothing happens, how do you know for sure you really were prepared?

Again, if you haven’t had a chance to read through the report, it’s a pretty interesting read (even for the Feds) and I think that some of the stories regarding somewhat rocky interactions with the community might sound at least a little familiar to folks. As with any emergency, there are lessons to be learned and there is much in this report to think on for just about everyone involved with hospital emergency management.

But perhaps the most instructive thing of all is the “tenor” of the conclusion and recommendations section, which doesn’t really point any fingers at the hospitals involved in responding to Sandy. Sure, there are some rather generic references to findings during previous Joint Commission surveys that could have had an impact on response capabilities, but to me it appears nothing more than a classic case of post hoc ergo propter hoc (for those of you not “down” with Latin, that translates roughly as “after this, therefore because of this”). They really don’t seem to be able to tie any survey findings to what happened, but I guess they have to tie the survey process in somehow—such is life.

Get ready, ’cause here I come!

I’m still trying to get my head around the driving forces behind the pending CMS rules regarding all things emergency management. I don’t think I will ever understand why the requirements are quite as complex as they appear to be. My take has always been that the requirements could be distilled down to having a NIMS-compliant incident command structure, establishing a process for credentialing practitioners during an emergency, and a standard set of requirements for conducting exercises—everything that you need to be able to do, I think, fits very nicely into those couple of items. Would your actual plan be a complicated undertaking? Absolutely. The all-hazards approach has to be both flexible and comprehensive, so the mere physics of such an undertaking would tend away from small dense structures to larger, more fluid structure. But I’d not convinced that the overarching requirements need to be quite so (insert adjective here).

I also have a hard time thinking that hospitals and other healthcare organizations don’t take emergency management concerns seriously. As I pen this on the eve of the first anniversary of the Boston Marathon bombing, I continue to reflect on how well the hospitals in the Boston area responded to that horrific event. Were the lessons learned? Opportunities identified? You betcha! But when it comes down to getting the job done in real life/time, last April was a sterling example of how well hospitals plan and cooperate and respond to emergencies. No CEO wants their hospital to be on the front page of the local paper/web page because their organization dropped the ball during an emergency. That kind of publicity, no one needs.

So now we’re faced with another set of requirements—not particularly dissimilar from what we already have—and another set of interpretations by yet another set of authorities having jurisdiction. And the question I have yet to find a really good answer for is this: how is this going to make hospitals better prepared to respond to an emergency? If anyone has figured that one out, please share!

Alien invasion: Take me to your (Emergency Management) leader!

It’s been a fairly busy year when it comes to updates of standards and such (short of the anticipated adoption of the 2012 Life Safety Code®…as Tom Petty once noted, the waiting is the hardest part, but I digress) and this week we’ll take a look at the new requirements relative to leadership and oversight of the Emergency Management (EM) function. I’m still not entirely certain what we’re gaining by this, unless as a means of ensuring that organizational leadership is inclined to provide sufficient resources to the task of being appropriately prepared for emergencies, but I’m sure it will all be made clear in the fullness of time.

So, we start with LD.04.01.05 which (in EP 5) mandates hospital leaders to identify an individual (and it does say “individual,” not the usual “individual(s)”—sounds like only one person’s going to be on the hook for this) to be accountable for matters of EM that are not within the responsibilities of the incident commander role. This includes such processes as staff implementation of the four phases of EM (mitigation, preparedness, response, and recovery); staff implementation of EM across the six critical areas (communications, resources and assets, safety and security, staff roles and responsibilities, utilities, and patient clinical and support activities); collaboration across clinical and operational areas relative to EM; and collaboration with the community relative to EM stuff. I think that’s pretty straightforward and, to be honest, I can’t say that I’ve run into any organizations that have not taken things to this level.

Next up we have LD.04.04.01. EP 25, which ties hospital senior leadership in as the drivers of EM improvements across the organization, including prioritization of improvement opportunities, as well as a specific review of EM planning reviews (a review of the review, if you will) and a review of the emergency response plan (exercises and real events) evaluations. So this speaks to a very specific communications process from the “boots on the ground” EM resources up to senior leadership. This one is very doable and even “done-able” if you’ve been including consideration of EM program evaluations as a function of your annual evaluation of the Environment of Care Management program. Lots of folks are doing this, so this one’s not so much of a stretch.

Finally, we have EM.03.01.03, EPs 13 and 15, which basically establish the requirement to have a specific process for the evaluation of EM exercises and actual response activities. You’re doing this, I am quite certain, but what you might not be succinctly documenting is the multidisciplinary aspect of the evaluation process (don’t forget to include those licensed independent practitioners—we want them at the table). It goes on to the process for reporting the results of the exercise/event evaluations to the EOC committee. Again, I’m pretty confident that this is in place for many (probably most, maybe even all) folks.

That’s the scoop on this. The changes are effective January 1, 2014 and I don’t think this is going to present much of a problem for folks, though please feel free to disagree (if you are so inclined). Certainly what’s being required fits into the framework of processes and activities that are already in place, so less fraught with peril than other changes that could have been made. (I’m still waiting for the influx exercise requirement to be changed to an evacuation exercise requirement. I think we do influx pretty well; evacuation, that’s a whole other kettle of fish.)

Well, while I don’t think that you’d have to include alien invasion on your HVA, if such a thing were to occur, at least we’ll know who to take them to when they ask…