November 18, 2009
Emergency Management Planning is now a requirement for ambulatory surgery centers. An effective policy should be in place to respond to emergencies and the emergency management plan is an essential part of meeting this requirement. CMS has issued a checklist to assist you in writing your plan.
Here are a few key elements from the checklist to include:
- All Hazards Continuity of Operations (COOP) Plan: Develop a continuity of operations business plan using an all-hazards approach (e.g., hurricanes, floods, tornados, fire, bioterrorism, pandemic, etc) that could potentially affect the facility directly and indirectly within the particular area of location. Indirect hazards could affect the community but not the facility and as a result interrupt necessary utilities, supplies or staffing. Determine all essential functions and critical personnel.
- Collaborate with Local Emergency Management Agency: Collaborate with local emergency management agencies to ensure the development of an effective emergency plan.
- Develop Evacuation Plan: Develop an effective plan for evacuation, by ensuring provisions for the following are specified: Identification of person responsible for implementing the facility evacuation plan (even if no outside evacuation order is given), Multiple pre-determined evacuation locations (contract or agreement) with a “like” facility have been established, Evacuation routes and alternative routes have been identified, and the proper authorities have been notified, Adequate food supply and logistical support for transporting food is described, Procedure for protecting and transporting resident/patient medical records, Determine a method to account for all individuals during and after the evacuation.
- Facility Reentry Plan: Describe who will authorize reentry to the facility after an evacuation, the procedures for inspecting the facility, and how it will be determined when it is safe to return to the facility after an evacuation. The plan should also describe the appropriate consideration for return travel back to the facility.
- Review Emergency Plan: Complete an internal review of the emergency plan on an annual basis to ensure the plan reflects the most accurate and up-to-date information. Updates may be warranted for: Regulatory change, New hazards are identified or existing hazards change, After tests, drills, or exercises when problems have been identified, After actual disasters/emergency responses, Infrastructure changes, Funding or budget-level changes,etc.
The Emergency Management Plan should be incorporated into your Policy and Procedure manual. Make sure you staff is briefed on the plan and that its incorporation into the manual is reviewed and approved by the Board of Directors.
If you need further assistance preparing an emergency management plan to meet the new CMS Conditions for Coverage, contact Ortmann Healthcare Consultants at 803-252-7979. We’d be happy to help!
Submitted by Jessica Miller, Director of Regulatory Affairs
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