Preparing for the Survey

Through the Eyes of the Surveyor

Open Mind

There are gaps!

Emergency Preparedness is now a focus!

What We Know

2004/05 Hurricanes 2006 OIG report

94% emergency plans met Federal regulations 80% met training requirements

Reality: Many lacked information recommended by experts Were not followed during actual incidents Lack of Emergency Management coordination

History of the Survey

2007 CMS publishes emergency preparedness checklists as “recommended tools “for Healthcare Facilities , State LTC Ombudsman, and State SA.

Where it Began

transportation contracts were not always honored

evacuation travel took longer than expected medication needs complicated travel

host facilities were unavailable or inadequately prepared

What the Report Found

facilities could not maintain adequate staff

food and water shortages occurred

prompt return of residents was difficult.

Findings (continued)

CMS should consider strengthening Federal certification standards for nursing home emergency plans by including requirements for specific elements of emergency planning.

Recommendation

210 facilities effected in 7 states with hurricanes, floods, and wildfires.

Review of 24 facilities whose residents were sheltered in place or evacuated . (2010)

2007- 2010 Round 2

Floods 2009 Red River Flooding 7 facilities evacuated

Hurricanes 2008 (Gustav and Ike ) 92 facilities in Louisiana and 84 in Texas.

Facts

Department of Health and Human Services OFFICE OF INSPECTOR GENERAL

◦ GAPS CONTINUE TO EXIST IN NURSING HOME EMERGENCY

PREPAREDNESS AND RESPONSE DURING DISASTERS: 2007–2010

Daniel R. Levinson Inspector General April 2012

Inadequate staff training Surveyors not trained to review nursing

home emergency plans Procedures for finding missing residents Most administrators did not use CMS

checklist (13/24 aware and 7/13 used it)

Findings: The Nitty Gritty

Staffing backup plan Resident care Resident identification, information, tracking Sheltering in Place Evacuation Communication and collaboration

Six Areas of Concern in Plans

Staffing Tasks (during a disaster) Did not ensure sufficient staffing levels for care 22/24 have backup for staff unable to report to work

Resident Care tasks illness or death with evacuation disaster counseling to residents info on specific needs (oxygen, vents, feeding tubes)

and characteristics (dementia)

Specific Gaps in Plans

Resident Identification, information, and tracking

How to identify (wristband , tags) What information must accompany resident Identify next of kin/ power of attorney

Sheltering in Place Amount of potable water Extra medical supplies

Continued

Evacuation How to transport and protect medical records Evacuation routes and alternates Transport adequate food and water

◦ Communication and Collaboration No plan to communicate with ombudsmen and

authorities Did not include collaboration with EM to develop plan or

determine whether to evacuate or shelter in place

Still More

◦ February 2012 Looked at 4 hurricane (Katrina, Rita, Gustav, and Ike)

and 36,389 residents to compare SIP vs evacuation◦

◦ Conclusion Evacuation significantly exacerbated subsequent

morbidity/mortality. Universal evacuation policies require reconsideration.

Address safeguarding human resources, ensuring business continuity, and protecting physical resources.

Federal Register (proposed 12/27/2013)

§483.75(m) Disaster and Emergency Preparedness

§483.75(m)(1) The facility must have detailed written plans and procedures to meet all potential emergencies and disasters, such as fire, severe weather, and missing residents.

F517

§483.75(m)(2) The facilities must train all employees in emergency procedures when they begin to work in the facility, periodically review the procedures with existing staff, and carry out unannounced staff drills using those procedures.

F518

 Subsistence (§ 483.73(b)(1))

Training and Testing (§ 483.73(d))

Generator Testing (§ 483.73(e))

Emergency Preparedness Long Term Care (LTC) Facilities

subsistence needs for staff and residents, whether they evacuate or shelter in place, including◦ food, water, and medical supplies alternate

sources of energy

Subsistence (§ 483.73(b)(1))

facilities must participate in or conduct a mock disaster drill and a tabletop exercise bi-annually.

 facilities review their procedures with staff, conduct unannounced drills

Training and Testing (§ 483.73(d))

 a minimum of 4 continuous hours at least once every 12 months

Generator Testing (§ 483.73(e))

Essentials needed to provide health care is available:

◦ safeguarding human resources◦ ensuring business continuity◦ and protecting physical resources.

Essentials for Survival

(1) risk assessment and planning ( All Hazards and HVA)

(2) policies and procedures (based on the emergency plan and risk assessment)

 

Core Elements for Success

(3) communication (develop and maintain an emergency preparedness plan) 

(4) training and testing. (staff know and exercise the plan) 

Core Elements (continued)

State Has to Address Changes

Michigan Deficiencies in Emergency Planning 2009 -2010 *

Number of Nursing Homes Surveyed…431* Total of Tags F517 and K48…86 (20%)…National

Average 7.6%* Total of Tags F518 and K50…164 (38.1%)…National

Average 27.9%*

Motivation for Change

Helpful Hints for the Provider

Be Prepared! Practice

Know your plan!

Know your staff!

Know the CMS Survey!

Game plan

Questions

Onward to the Survey

Emergency Management collaboration

Description of amounts and types of food supply

Extra pharmacy stock, medical supplies and equipment

Most Common Surveyor Checklist Gaps in Plan

Planning for emergency financial needs and security

Transporting adequate food and water to relocation

Transported items with each resident

Michigan Gaps (continued)

Assure assistive devices are transported

Resident becomes ill or dies in route

Training for all transport vendors and volunteers

How will residents be identified and info secured

Gaps

Communication with LTC Ombudsman

Conducting exercises and drills

Loss of resident’s personal effects

Re-entry

Gaps

Digging Even Deeper