The US Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued a new report September 6, 2023, which says that nursing homes reported wide-ranging challenges preparing for public health emergencies and natural disasters.
According to the report, in June 2022, an estimated 77 percent of nursing homes located in areas at greater risk for natural disasters reported experiencing challenges with emergency preparedness activities. Administrators reported concerns across seven topic areas, with activities related to ensuring proper staffing during emergencies and transporting residents during evacuations being the most problematic.
An estimated 62 percent of nursing homes reported at least one challenge regarding staffing and an estimated 50 percent noted at least one challenge regarding transportation. Other challenges reported by some nursing homes included securing beds for evacuated residents and planning for infection control and quarantine during emergencies. The OIG found that even those nursing homes that met the federal requirements for emergency preparedness faced challenges with critical aspects of emergency preparedness.
The OIG identified and measured 49 preparedness activities intended to ensure that nursing homes can meet resident care needs during an emergency. These activities are not delineated in the Centers for Medicare & Medicaid Services’ (CMS) emergency preparedness requirements, but according to the OIG, the activities are important steps in developing nursing home response capabilities. The 49 activities were divided across seven topic areas plus an “other” category for activities that did not fit into one of the topic areas.
To view all OIG topic areas and the 49 activity data measures, access the report here. This information can be used to strengthen your existing Emergency Preparedness Plan.
Compliance Perspective
Issue
CMS requires nursing homes that participate in the Medicare and Medicaid programs to meet a broad range of emergency preparedness requirements. These include (1) having and maintaining an all-hazards emergency preparedness plan that incorporates a facility- and community-based risk assessment, as well as plans for continuity of operations; (2) establishing policies and procedures to be followed in the event of an emergency; (3) maintaining a communication plan to ensure that affected individuals and oversight groups receive needed information; and (4) having a program for training staff and conducting exercises to ensure that the plans will be effective in the event of an emergency.
Discussion Points
- Review your Emergency Preparedness Plan and update as necessary. Review the most current Life Safety codes and ensure that your building meets those requirements. Make sure the Plan is available to staff so they can easily access the guidelines for the various components should an emergency occur.
- Train all staff on your Emergency Preparedness Plan. Conduct drills for the various disaster response plans to ensure staff competency with each. Ensure that the facility Maintenance Director is aware of current Life Safety codes and provide training as needed. An educational program titled Emergency Preparedness Requirements for Nursing Homes is available in the Safety Category of Med-Net Academy Compliance for access by all clients. Document all trainings and drills that occurred, and file the signed documents in each employee’s education file.
- Periodically conduct environmental audits to ensure that Life Safety codes are being followed. Audit staff understanding to ensure that they are aware of their roles during each category of emergency per your Emergency Preparedness Plan. Audit to ensure that thorough documentation of each drill is on file and available for surveyor access when requested, to include participation in an annual area-wide drill with your local emergency response teams.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*
