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How to Comply with the CMS Conditions for Coverage on Emergency Preparedness Bob Loeper, VP Operations Support Business Continuity/Disaster Response Fresenius Kidney Care November 9, 2018 Facilities Impacted by the Emergency Preparedness Rule


  1. How to Comply with the CMS Conditions for Coverage on Emergency Preparedness Bob Loeper, VP Operations Support Business Continuity/Disaster Response Fresenius Kidney Care November 9, 2018

  2. Facilities Impacted by the Emergency Preparedness Rule Hospitals Comprehensive Outpatient • • Rehabilitation Facilities (CORFs) Religious Nonmedical Health Care • Institutions (RNHCIs) Critical Access Hospitals (CAHs) • Ambulatory Surgical Centers (ASCs) Clinics, Rehabilitation Agencies, and • • Public Health Agencies as Providers of Hospices • Outpatient Psychiatric Residential Treatment • Physical Therapy and Speech • Facilities (PRTFs) Language Pathology Services • All Inclusive Care for the Elderly • (PACE) Community Mental Health Centers • (CMHCs) Transplant Centers • Organ Procurement Organizations • Long Term Care (LTC) Facilities • (OPOs) Intermediate Care Facilities for • Rural Health Clinics (RHCs) and • Individuals with Intellectual Federally Qualified Health Centers Disabilities (ICF/IID) (FQHCs) Home Health Agencies (HHAs) • End Stage Renal Disease (ESRD) • Facilities

  3. Developing a Facility Emergency Plan

  4. Hazard Vulnerability Assessment (HVA) • Define Hazards expected in your community • Rank hazards by probability, risks and preparedness • Define Mitigation Strategies for top 5 to 10 hazards • Show proof of mitigation strategies • IDT must participate in completing the HVA, including the Medical Director

  5. Hazardous Vulnerability Analysis Type of Disasters • Hurricane • Power Outage • Tornado • Equipment Failure (RO) • Wild Fires • Pandemic • Earthquake • Civil Unrest / Riots • Winter Weather • Volcano • Flood • Nuclear Incident • Drought • Ransomware • Chemical Spill • Water Main Break

  6. Hazardous Vulnerability Analysis

  7. Hazardous Vulnerability Analysis (HVA) Type of Disaster Probability of Impact on Persons, Preparedness level or Total Occurring? Property or Internal & External Business Resources 3 - High 3 - High 0 - Very Good 2 - Medium 2 - Medium 1 - Good 1 - Low 1 - Low 2 - Fair 0 - None 0 - None 3 - Poor

  8. HAZARD VULNERABILITY ASSESSMENT TOOL SEVERITY PROBABILITY RISK PREPARED-NESS Total EVENT Possibility of death or Those events with a higher score Likelihood this will injury / Physical should be prioritized; as these events Preplanning occur Damage / Dialysis will require additional planning and Interruption preparation. 0 = N/A 1 = 0 = N/A 1 = 3 = Low / None Low 2 = Low 2 = 2 = Moderate SCORE 0 - 9 Moderate 3 = Moderate 3 = 1 = High 0 High High = N/A 0 Volcano 0 0 0 0 Hurricane 0 0 0 0 Tornado 0 0 0 0 Fire 0 0 0 0 Ice Storm 0 0 0 0 Earthquake 0 0 0 0 Floods 0 0 0 0 Blizzard 0 0 0 0 Electrical Failure 0 0 0 0 Water Interruption 0 0 0 0 Drought 0 0 0 0 Hazardous Material Spill 0 0 0 0 Terrorism Act 0 0 0 0 Bomb Threat 0 0 0 0 Active Shooter 0 0 0 0 Nuclear Plant Accident 0 0 0 0 Civil Disturbance 0 0 0 0 Pandemic 0 0 0 0 Cyberterrorism / Ransomware 0 0 0 0 Other Local Event 0 0 0 Facility Name: Facility #: Preparer: Date: Only values of 0, 1, 2 or 3 will be accepted for Probability, Risk and Preparedness.

  9. Hurricane Mitigation Strategies Type of Disasters • Procedures to determine the need to evacuate prior to a hurricane have been established. • A Memorandum of Understanding with an engineering firm to complete a Building Damage Assessment is in place. Ensure you have contact information for the engineering firm. • Plastic sheeting and duct tape are on hand to cover up equipment and windows if necessary.

  10. Hurricane Mitigation Strategies Type of Disasters • Portable pumps and sandbags are available • Secure all items susceptible to blowing away, bring these items inside if possible. • Store and secure all critical records at least 2’ above the floor in the event flooding occurs. • Fill up the fuel tanks in vehicles and generators prior to landfall. • Hotel accommodations are available to house staff if necessary. • Frozen cool packs are available to place in medication refrigerators if needed.

  11. Hurricane Mitigation Strategies • Medical equipment, dialysis machines and computers are secure, elevated and covered in plastic. • Regulated medical waste is collected, secured and stored in locked Medical Waste room • Weather Radio with a warning alarm tone and battery backup is available. • Facility shutdown procedures are in place. • Warning and evacuation plans and procedures are in place. • Transportation assistance is available if needed. • Hurricane shutters are in place or 5/8” marine plywood is on hand to protect windows.

  12. Components of the Facility Emergency Plan Emergency Operations Center • Contact your local EoC and discuss your capabilities during a disaster and understand their role in emergency preparedness and response • Seek and join local healthcare coalitions • Surveyors will ask: Which Coalition do you belong to? • Determine location of medical/special needs shelters; • Determine if patient registration is required; • Determine re-entry requirements post mandatory evacuation; • Participate in community drills

  13. Components of the Facility Emergency Plan • Create a facility manual to provide an overview of the facility emergency plan and depository for all documents • Define roles and responsibilities for each staff member: • Facility Administrator as Incident Commander; complete authority over the event, authorizes resources, declares the disaster and when event is over • Social Worker: Contact missing patients and arrange transportation • Administrative Assistant: Coordinate staffing needs and transfer/admit patients • Registered Dietitian: Coordination with local hospital and other external agencies • Direct Patient Care staff: RNs and PCTs to assist with patient emergency education, participate in facility evacuation drills, assisting patients • Medical Director and attending physicians : help in locating your patients after a disaster, provide orders for patients who present to clinic with no medical records

  14. Components of the Facility Emergency Plan • Create Facility Emergency Contact Information Form • Hierarchal contact information; Admin/Area/Regional, Med Dir • Facility: Landlord, Electrician, Plumber, HVAC, Fuel • Community: Police, Fire, Telephone, Water, Power • Regulatory: FEMA, EOC, Network, Red Cross, NKF, National Guard • Emergency Housing: Hotels, Campgrounds • Back up Facilities • Volunteer groups or local agencies that may provide assistance

  15. Components of the Facility Emergency Plan • Create Staff Emergency Contact Information Form • List all staff contact information including cell and emails • Know staff driving distance form facility • Include secondary contact information • Pull electronically from exiting data fields • Print quarterly for review and compliance ‘If we don’t take care of our staff, we can’t take care of our patients’

  16. Tracking Patient Emergency Contact Information • Create Patient Emergency Contact Information Form and update at least quarterly • Know how to get in touch with your patients, include family members and alternate contact information • Know their expected evacuation plan • Identify who will go to special needs shelter during evacuation • Register for shelter if required • Review/update with patients prior to event if possible • All patients must be accounted for during a disaster

  17. Homeland Security Re-Entry Authorization Know what your EoC Requires

  18. Facility Authorization Letter To Whom It May Concern: The individual carrying this letter is authorized by the National Incident Commander for Fresenius Medical Care North America to respond to the medical and infrastructure needs of patients who require life sustaining medical treatment in a Fresenius Medical Care facility. As such, this individual should be allowed to travel freely and without interruption or interdiction to and from whatever location that requires his/her assistance. If you require any further authorization or information, please contact me immediately at 813-843-4423. Robert P Loeper National Incident Commander Fresenius Medical Services Disaster Response Team Vice President of FMS Strategic Project Management

  19. Facility Emergency Supplies and Equipment • Does facility have a back up analog phone and line available? • Emergency equipment to include AED (checked daily), O2 tanks, suction, Ambu bag, IV solutions, back board, oral airways • Are emergency medications checked monthly or after use for expiration dates, cleanliness and proper function

  20. Agreements to include in your Facility Emergency Plan • Facility Back up Agreement, with multiple facilities • Alternate water source agreement • Alternate power source/emergency generator agreement • HVAC maintenance and repair agreement • Emergency response agreements with electricians, plumbers, contractors • Emergency transportation agreements • Rental car/van/truck agreements • Security services agreements • Environmental testing agreements, Arcadis • Physical Pant Mitigation Agreements; ServPro, ACT, Service Master • Debris removal services

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