New emergency preparedness requirements for healthcare

Business Preparedness &
Continuity Consulting
Copyright © 2015 AccinctusLLC. All Rights Reserved.
New
Emergency
Preparedness
Requirements
for the
Health Care
Sector
Brian Siravo, CBCP
President,Accinctus

Copyright © 2015 AccinctusLLC. All Rights Reserved. www.accinctus.com
Continuity Consulting Services
2
Health Care Providers are
Not Prepared for Disasters
and Emergencies!
(Neither are most organizations but that’s a separate issue.)

Copyright © 2015 AccinctusLLC. All Rights Reserved. www.accinctus.com 3
• Disasters and emergencies significantly
challenge health care providers to continue
services in a disrupted environment
• A study by the Department of Health and
Human Services of disasters in the U.S. from
2001-2012 concluded that health care
providers are not adequately prepared for
disasters and emergencies
Lessons Learned

From HHS:
As we have learned from past events and disasters, the
current regulatory patchwork of federal, state, and local
laws… falls far short of what is needed to require that
health care providers and suppliers be adequately
prepared for a disaster.
…currently, in the event of a disaster, health care
providers and suppliers across the nation would not
have the necessary emergency planning and
preparation in place to adequately protect the health and
safety of their patients.
Lessons Learned
Department of Health and Human Services, Centers for Medicare & Medicaid Services, 42 CFR Parts 403, 416, 418, 441, 460, 482, 483, 484,485, 486, 491, 494;
Medicare and Medicaid Programs; EmergencyPreparednessRequirements for Medicare and Medicaid Participating Providersand Suppliers; Proposed Rule

• While large hospitals may have parts of a
preparedness program in place or experienced
staff, few have comprehensive preparedness
programs to meet real world disasters
• More challenging is that most smaller facilities such
as long-term care facilities, clinics and specialized
treatment offices, etc. have less resources or
preparedness planning in place
Lessons Learned

HHS has proposed streamlined emergency
preparedness requirements in 42 CFR, Centers for
Medicare and Medicaid Services with the intent to:
• Improve emergency preparedness capabilities of
all medical providers and suppliers
• Consolidate and standardize emergency
preparedness regulations
Lessons Learned

7
What are the New
Emergency Preparedness
Requirements?

New Requirements
Requires 17 categories of Medicare & Medicaid
suppliers and providers (next slide) to comply with
the new emergency preparedness requirements
within 1 year after the final rule is published
Requires completion of 4 core elements:
• Risk Assessment and Planning
• Policies and Procedures
• Communication Plan
• Training and Testing

• Religious Nonmedical
Health Care Institutions
(RNHCIs)
• Ambulatory Surgical
Centers (ASCs)
• Hospices
• Inpatient Psychiatric
Services for Individuals
Under Age 21 in
Psychiatric Facilities or
Programs (PRTFs)
• Programs for All-
Inclusive Care for the
Elderly (PACE)
• Hospitals
• Transplant Centers
• Long Term Care (LTC)
Facilities – Skilled
Nursing Facilities
(SNFs)
• Intermediate Care
Facilities for Individuals
with Intellectual
Disabilities (ICF/IID)
• Home Health Agencies
(HHAs)
• Comprehensive
Outpatient
Rehabilitation Facilities
(CORFs)
• Critical Access Hospitals
(CAHs)
• Clinics, Rehabilitation
Agencies, and Public
Health Agencies as
Providers of Outpatient
Physical Therapy and
Speech-Language
Pathology Services
• Community Mental
Health Centers
(CMHCs)
• Organ Procurement
Organizations (OPOs)
• Rural Health Clinics
(RHCs)
• End-Stage Renal
Disease (ESRD)
Facilities
Providers / Suppliers

Your Organization Must:
1. Conduct a comprehensive, all-hazards risk
assessment
2. Develop and implement appropriate policies and
emergency procedures (i.e. plans) based on the
risk assessment
3. Develop an emergency communication plan
4. Establish an emergency preparedness training
and testing program that includes initial training &
annual exercises
New Requirements

11
HOW to Develop an
Emergency Preparedness
Program

• Development of your preparedness program will
take time and resources
• Use accepted business continuity process and
standards (NFPA 1600 or ISO 22301) to guide
implementation of your preparedness program
• Get professional assistance if you don’t have
in-house capabilities or need additional expertise
• Don’t forget to document-document-document!
Preparedness Process

Step 1: Define program requirements & goals
Step 2: Conduct Risk Assessment (RA) &
Business Impact Analysis (BIA)
Step 3: Develop required plans
Step 4: Develop & implement a training program
Step 5: Conduct exercises and tests to improve
your program
Preparedness Process

• Studies over the last decade have clearly shown
the US medical community is not adequately
prepared for disasters and emergencies
• HHS is consolidating emergency preparedness
requirements for all Medicare/Medicaid
providers & suppliers to increase emergency
preparedness & protect patient welfare
• The new requirements include mandatory
completion of 4 core elements and
establishment of a preparedness program
Bottom Line

15
How Accinctus Can Help
Your Organization

• Accinctus provides disaster preparedness and
business continuity services to businesses and
other organizations of any size
– 20+ years of experience in preparedness and
continuity planning
– Specific focus on small and medium business
(SMBs) and similar sized non-profit or faith-based
organizations
The Accinctus Solution

• The Accinctus ADAPTABLE© business continuity
model applies professional practices while
maintaining a flexible approach to best achieve
your preparedness goals
• Integrates NFPA 1600 and ISO 22301 standards
to achieve compliance with Medicare/Medicaid,
HIPAA, and other requirements

• Flexible service solutions include:
– Training classes & workshops designed to jump
start your in-house preparedness efforts
– Long-term, traditional outsourcing
– Short-term project or task focused solutions
– BC Pro-Flex
A set hour/month package with a certified
business continuity professional to work on any
related task of your preparedness program that
allows flexible scheduling over time

Continuity Consulting
Helping your business build a strong and resilient road to your future success.
Copyright © 2015 AccinctusLLC. All Rights Reserved.
If you have questions regarding the new
emergency preparedness requirements or
would like to know how Accinctus can help
you develop your program, please contact
Accinctus at questions@accinctus.com.
Find out more at www.accinctus.com
Accinctus is a Veteran Owned Small
Business

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