CRAFTING A STRATEGIC PLAN BEFORE DISASTER STRIKES
RULES OF THE ROAD
In 2016, the Centers for Medicare & Medicaid Services (CMS) published new rules for disaster planning. The rules, which became effective November 2017, apply only to those providers who accept Medicare or Medicaid payments.
Not all senior living communities have to comply, but most assisted living and skilled nursing communities will fall under the CMS rules. Even for those who are not obliged to follow these rules, the CMS requirements offer a helpful roadmap.
“You can look to this as a model, because it is laid out pretty clearly,” said Molly S. Evans, a partner & emergency preparedness practice group lead with law firm Feldesman Tucker Leifer Fidell. CMS has described four key requirements for emergency planning. Providers need to:
1
Develop a plan based on a risk assessment.
“The risks in Washington, D.C. might look different from the risks in Montana. In general, you consider all the hazards you might likely have and think about which ones are most likely to happen,” Evans said.
2
Establish policies and procedures.
How will you evacuate? How to shelter in place? Where will food and water come from? How will you obtain energy in an emergency? The plan should lay out a detailed approach to all of these.
3
Create a communications plan.
“How will you communicate to federal, state, and local emergency officials? How will you communicate internally? If the landlines are down, do you have a satellite phone? You need an alternate means to communicate,” Evans said. Many senior living communities already have some policies in place which can form the basis of this more extensive communications plan.
4
Training and testing.
“The rule asks for annual training of all staff as well as a full-scale exercise in the community, something that involves other hospitals and health care providers, and other community players in the emergency response role, as well as a tabletop exercise with your internal team,” Evans said.
There’s some latitude in terms of what must be trained and how often. Evans suggests training on high-likelihood risks more frequently, while rotating in less likely events as part of an annual exercise.
She also points to technology as a possible enabler for senior living communities looking to fulfill the CMS mandate while keeping the expense of planning in check. Providers who already use a learning management system can leverage that investment to promote content around emergency planning. Tabletop exercises and other training sessions can be archived online for future use.
“It can be extremely helpful if it means you are not reinventing the wheel,” she said.
“We make it part of the orientation
process. We start talking about emergency planning from the first day that people come into the building. And then there is not a lot of lag time between when they first come in and when they start to take part in train- ing. We provide a foundation as part of ori- entation and then we build on that more formally each time we offer training in the community,” he said.
Emergency response professionals agree
that a disaster plan is only as good as the training that goes into it over time. How- ever detailed a plan may be, however well thought out, it will stand or fall depending on how often and how well front-line staff have been drilled in its execution. Part of that continuing practice likely will
include ongoing conversations between the executive director and a growing range of
12 SENIOR LIVING EXECUTIVE JANUARY/FEBRUARY 2018
outside partners. In addition to the charter bus company and the local hotel, executive directors increasingly are forging ties to public health offices, first responders, and other community partners who may be part of a broader emergency response.
New partnerships In 2016, the Centers for Medicare & Medic- aid Services (CMS) issued a new set of guide-
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60
