Kilgore says her ASC has devoted time to planning its response to emer- gencies that occur while procedures are underway. “We have enough bat- tery backup that if someone is in sur- gery and a power outage occurred, we could finish that case. If that is not an option, we are prepared to get patients to a state where we can safely stop the procedure and transport them out of the ASC or to a safe zone.” An important consideration from

a business and operations perspec- tive, Boore says, is succession plan- ning and lines of authority. “You can base a plan on specific assignments for the members of your team, but what if the administrator is on vacation and no one has been trained to fill in? You need a really well-defined and orderly structure for the levels of responsibil- ity, who is going to be responsible for what tasks and who will fill in if a team member is unavailable.”

Focus on Communications No continuity of operations plan will be successful without effective com- munications, Boore says. “You need to determine how you will reach out to your medical staff and patients if you need to curtail services. Make sure you have all of the emergency contact information for your staff, other health care facilities and local agencies.” Kilgore says her ASC has an auto- mated system that can call patients in the event of a cancellation. “We also put together a phone tree for staff where we gathered everyone’s pre- ferred mode of communication if an emergency occurs. We have a member of administration whose job responsi- bility includes monitoring weather and news to learn about emergencies and initiate the communications plan. It is vital that a communication

plan involves everyone, Boore says. “It needs to go all the way up to the gov- erning body.”

American Association for Accredita- tion of Ambulatory Surgery Facilities, also have standards that speak to emer- gency preparedness. For the active shooter scenario,

Kilgore’s ASC invited state police to perform an assessment of the build- ing. From that experience, she says she identified another important reason for performing drills that accurately sim- ulate an emergency response. “The police told us that your body cannot go where your brain has not already been. In the event of an emergency, you do not know what to do if you have not practiced and talked about it.”

She also advises ASCs to take into account how they will share and exchange medical records with other providers, if necessary.

Test the Plan While simply creating the plan is important, that alone is not enough to prepare an ASC for a disaster, Kilgore says. The plan must be drilled, and the drill must be taken seriously. “As a AAAHC-accredited ASC,

performing drills is a requirement,” she says. “We perform a drill every quarter, focusing on the disaster most likely to affect our ASC, such as tor- nados and power outages. We have also drilled an active shooter scenario. After every drill, the team gets together to discuss what went well and what we need to improve on. It is amazing what you can learn after a drill.” Bergero notes that Joint Commis- sion-accredited ASCs are required to evaluate the effectiveness of their emergency management plan. “This includes participating in and evaluat- ing emergency response exercises to identify any deficiencies and opportu- nities for improvement.” Other accred- itors, e.g., Accreditation Associa- tion for Ambulatory Health Care and

Work with Local Organizations Your continuity of operations plan should take into consideration the needs of your community, consistent with your capabilities—staff, space, supplies

and equipment—and your

role in community response efforts, Bergero says. “ASCs are increasingly recognized in some communities as important partners in health care coali- tions, with the capacity to provide additional clinical support during mass casualty events if hospitals become overcrowded or inaccessible.” Once you perform your risk assessment, Boore advises reaching out to local, regional and state agen- cies as well as local hospitals and health systems to explore opportuni- ties to collaborate with them on disas- ter response planning. “An emphasis in the recent emer-

gency preparedness final rule— ‘Emergency Preparedness Require- ments for Medicare and Medicaid Participating Providers and Suppli- ers,’ published in November 2016—is on cooperation and collaboration with response teams,” she says. “It is no longer acceptable for an ASC to sit on the sideline. When you consider some of the recent major disasters, such as 9/11 and Hurricane Katrina, a commu- nity-wide response is a necessity.”


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