new emergency preparedness requirements for healthcare

Business Preparedness &

Continuity Consulting

Copyright © 2015 Accinctus LLC. All Rights Reserved.

New

Emergency

Preparedness

Requirements

for the

Health Care

Sector

Brian Siravo, CBCP

President, Accinctus

Copyright © 2015 Accinctus LLC. All Rights Reserved. www.accinctus.com

Business Preparedness & Continuity Consulting Services

2

Health Care Providers are

Not Prepared for Disasters

and Emergencies!

(Neither are most organizations but that’s a separate issue.)

http://www.accinctus.com/


Copyright © 2015 Accinctus LLC. 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; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and 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



Business Preparedness &

Continuity Consulting

Helping your business build a strong and resilient road to your future success.Copyright © 2015 Accinctus LLC. 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 [email protected].

Find out more at www.accinctus.com

Accinctus is a Veteran Owned Small

Business

mailto:[email protected]


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