Emergency Operations Plan (EOP) Review and Compliance Overview

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Emergency
Operations Plan
(EOP) Review
 
Objectives:
 
Review Healthcare Preparedness Program Structure
Recognize Healthcare Preparedness & Response Capabilities
Detail the CMS Emergency Preparedness Rule
Understand accreditation requirements of the EOP
 
Things to Remember…
 
EOPs
Organize into one manual and tab each section
Have a limited number of hard copies
Have a distribution page
Have a changes page
Use job aids and checklists that coincide with each specific type of incident
identified in the risk assessment
It should be specific to your facility
 
CMS Emergency
Preparedness Rule
 
Overview and impacts
 
CMS Compliance
 
Centers for Medicare & Medicaid Services
Conditions of Participation (CoPs) and
Conditions for Coverage (CfCs)
Health and safety regulations
Must be met by all Medicare & Medicaid-
participating providers and suppliers.
Conditions of reimbursement.
The EP Rule’s purpose is to:
Enhance patient safety during an emergency.
Enhance healthcare delivery system resilience.
 
Who is Impacted?
 
Hospitals
Religious Nonmedical
Health Care Institutions
Ambulatory Surgical
Centers
Hospices
Psychiatric Residential
Treatment Facilities
All-Inclusive Care for the
Elderly (PACE)
Transplant Centers
Long-Term Care (LTC)
Facilities
 
Intermediate Care
Facilities for Intellectually
Disabled
Home Health Agencies
Outpatient Rehab
Critical Access Hospitals
Community Mental Health
Centers
Organ Procurement
Organizations
Rural Health Clinics
End Stage Renal Disease
Facilities (Dialysis)
 
Goal of EP Update
 
Goal of EP Rule Updates:
Address healthcare system gaps.
Establish consistent emergency preparedness practices across
provider & supplier types.
Encourage emergency coordination with region & localities.
 
Four Requirements Apply to All
Provider Types
 
 
Risk Assessment &
Planning
 
Perform risk assessment using an “all-hazards” approach.
Update annually
Risk Assessment to include:
Care-related emergencies
Equipment and Power Failures
Communications interruption, including cyberattacks
Loss of all/portion of facility or clinical supplies
 
Risk Assessment, contd.
 
Develop an emergency plan (updated annually) based on the risk
assessment.
Key elements:
Integrated approach- demonstrate ability to address a broad range of
hazards.
Addresses shelter-in-place/evacuation
Business Continuity & Continuity of Care
Collaboration with local/regional/state Emergency Mgmt
 
Policies & Procedures
 
Develop and implement policies and procedures based on
the emergency plan and risk assessment.
Policies and procedures must address a range of issues
including subsistence needs, evacuation plans, procedures
for sheltering in place, mutual aid, patient tracking,
medical records, etc.
Review and update policies and procedures at least
annually.
 
Assumptions
 
Scenarios
Single Facility / Isolated Incident (e.g., Fire, Loss of Emergency Power);
Single Facility / Local or Area-wide Incident (e.g., Flooding, Ice Storm, Blizzard);
Multiple Facility / Statewide or Regional Incident (e.g., Derecho, Hurricane,
Tornado).
 
Incident Management Background
 
CMS EP Rule
Internal Emergency Operations Plan
National Preparedness System
NIMS
Nursing Home Incident Command System
LTC-MAP
Pg. 7-Internal Emergency Operations Plan
 
Communication Plan
 
Develop a communication plan that complies with both
Federal and State laws.
Coordinate patient care within the facility, across health
care providers, and with emergency management systems.
Review and update plan annually.
 
Communication Plan, contd.
 
Communications Plan must include:
Names/Contact info for stakeholders
Primary and alternate means of communicating
with stakeholders
Process/method for sharing medical records and
patient information
Process for sharing logistical information such as
census, needs, and ability to provide assistance to
other facilities.
 
Training & Testing Program
 
Develop and maintain 
training
 and 
testing
programs.
Facilities encouraged by CMS to engage local/state
EM and health care coalitions to meet this
requirement.
Training program
 must include:
Initial EP training for new & existing staff, individuals
providing services on behalf of facility, and volunteers
(consistent with their expected roles).
Documentation of training activities
Provision of annual update training for all staff.
 
Training & Testing Program
 
Testing (Exercise) 
Program must include:
Annual exercises to test emergency plans
Tabletop Exercise (recommends HSEEP, but not
required)
Community-based Full-Scale Exercise
If full-scale with community not possible, document why
and conduct individual facility-based exercise.
Facility is 
exempt
 from full-scale requirement for 1
year if an actual or man-made emergency results in
activation of the emergency plan.
Documentation required
 
 
Facility-Specific Rules
 
Outpatient providers not required to have policies
on provision of subsistence needs.
Home Health Agencies and hospices required to
inform local EMA of patients in need of evacuation
during an emergency.
Long-Term Care and residential Psych facilities
must share emergency plan information with
residents & their family members.
 
Facility-Specific Rules
 
Outpatient providers not required to have policies
on provision of subsistence needs.
Home Health Agencies and hospices required to
inform local EMA of patients in need of evacuation
during an emergency.
Long-Term Care and residential Psych facilities
must share emergency plan information with
residents & their family members.
Additional requirements for Emergency Power
and Standby Systems for hospitals, critical access
hospitals, and Long-Term Care
 
Expectations for Emergency
Management
 
NOT local EMA’s responsibility to ensure or
assist with successful certification.
Local EM’s CAN expect entities to contact them
about:
Obtaining copies of jurisdictional HVA or THIRA
Plan/policy integration
Engaging in training/exercise opportunities
Basic information on emergency preparedness and
healthcare system preparedness
 
Expectations for Emergency
Management
 
EMAs are not required to certify plans!
EMAs (collaborate with CVEMA?) should develop
a standard level of service for requesting
facilities:
Standard One-Pager
Set platform for relationships and collaboration despite
limited resources
Encourage collaboration with Public Health and
Healthcare Coalition
 
Questions?
 
Pete Svoboda
MVP Coordinator
Central Virginia Healthcare Coalition
pete.svoboda@central-region.org
 
RHCC 24/7 Activation: 1-800-276-0683
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This comprehensive review covers the objectives of the Emergency Operations Plan (EOP) including healthcare preparedness, CMS Emergency Preparedness Rule, and accreditation requirements. It discusses key aspects to remember when organizing an EOP manual and highlights the impact of CMS compliance on healthcare providers. The content emphasizes the goal of updating the EOP to address system gaps, enhance coordination, and establish consistent emergency preparedness practices across different provider types.

  • Emergency Operations Plan
  • Healthcare Preparedness
  • CMS Compliance
  • Emergency Preparedness Rule
  • Accreditation

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  1. Emergency Operations Plan (EOP) Review

  2. Objectives: Review Healthcare Preparedness Program Structure Recognize Healthcare Preparedness & Response Capabilities Detail the CMS Emergency Preparedness Rule Understand accreditation requirements of the EOP

  3. Things to Remember EOPs Organize into one manual and tab each section Have a limited number of hard copies Have a distribution page Have a changes page Use job aids and checklists that coincide with each specific type of incident identified in the risk assessment It should be specific to your facility

  4. CMS Emergency Preparedness Rule Overview and impacts

  5. CMS Compliance Centers for Medicare & Medicaid Services Conditions of Participation (CoPs) and Conditions for Coverage (CfCs) Health and safety regulations Must be met by all Medicare & Medicaid- participating providers and suppliers. Conditions of reimbursement. The EP Rule s purpose is to: Enhance patient safety during an emergency. Enhance healthcare delivery system resilience.

  6. Who is Impacted? Hospitals Intermediate Care Facilities for Intellectually Disabled Religious Nonmedical Health Care Institutions Home Health Agencies Ambulatory Surgical Centers Outpatient Rehab Critical Access Hospitals Hospices Community Mental Health Centers Psychiatric Residential Treatment Facilities Organ Procurement Organizations All-Inclusive Care for the Elderly (PACE) Rural Health Clinics Transplant Centers End Stage Renal Disease Facilities (Dialysis) Long-Term Care (LTC) Facilities

  7. Goal of EP Update Goal of EP Rule Updates: Address healthcare system gaps. Establish consistent emergency preparedness practices across provider & supplier types. Encourage emergency coordination with region & localities.

  8. Four Requirements Apply to All Provider Types

  9. Risk Assessment & Planning Perform risk assessment using an all-hazards approach. Update annually Risk Assessment to include: Care-related emergencies Equipment and Power Failures Communications interruption, including cyberattacks Loss of all/portion of facility or clinical supplies

  10. Risk Assessment, contd. Develop an emergency plan (updated annually) based on the risk assessment. Key elements: Integrated approach- demonstrate ability to address a broad range of hazards. Addresses shelter-in-place/evacuation Business Continuity & Continuity of Care Collaboration with local/regional/state Emergency Mgmt

  11. Policies & Procedures Develop and implement policies and procedures based on the emergency plan and risk assessment. Policies and procedures must address a range of issues including subsistence needs, evacuation plans, procedures for sheltering in place, mutual aid, patient tracking, medical records, etc. Review and update policies and procedures at least annually.

  12. Assumptions Scenarios Single Facility / Isolated Incident (e.g., Fire, Loss of Emergency Power); Single Facility / Local or Area-wide Incident (e.g., Flooding, Ice Storm, Blizzard); Multiple Facility / Statewide or Regional Incident (e.g., Derecho, Hurricane, Tornado).

  13. Incident Management Background CMS EP Rule Internal Emergency Operations Plan National Preparedness System NIMS Nursing Home Incident Command System LTC-MAP Pg. 7-Internal Emergency Operations Plan

  14. Communication Plan Develop a communication plan that complies with both Federal and State laws. Coordinate patient care within the facility, across health care providers, and with emergency management systems. Review and update plan annually.

  15. Communication Plan, contd. Communications Plan must include: Names/Contact info for stakeholders Primary and alternate means of communicating with stakeholders Process/method for sharing medical records and patient information Process for sharing logistical information such as census, needs, and ability to provide assistance to other facilities.

  16. Training & Testing Program Develop and maintain training and testing programs. Facilities encouraged by CMS to engage local/state EM and health care coalitions to meet this requirement. Training program must include: Initial EP training for new & existing staff, individuals providing services on behalf of facility, and volunteers (consistent with their expected roles). Documentation of training activities Provision of annual update training for all staff.

  17. Training & Testing Program Testing (Exercise) Program must include: Annual exercises to test emergency plans Tabletop Exercise (recommends HSEEP, but not required) Community-based Full-Scale Exercise If full-scale with community not possible, document why and conduct individual facility-based exercise. Facility is exempt from full-scale requirement for 1 year if an actual or man-made emergency results in activation of the emergency plan. Documentation required

  18. Facility-Specific Rules Outpatient providers not required to have policies on provision of subsistence needs. Home Health Agencies and hospices required to inform local EMA of patients in need of evacuation during an emergency. Long-Term Care and residential Psych facilities must share emergency plan information with residents & their family members.

  19. Facility-Specific Rules Outpatient providers not required to have policies on provision of subsistence needs. Home Health Agencies and hospices required to inform local EMA of patients in need of evacuation during an emergency. Long-Term Care and residential Psych facilities must share emergency plan information with residents & their family members. Additional requirements for Emergency Power and Standby Systems for hospitals, critical access hospitals, and Long-Term Care

  20. Expectations for Emergency Management NOT local EMA s responsibility to ensure or assist with successful certification. Local EM s CAN expect entities to contact them about: Obtaining copies of jurisdictional HVA or THIRA Plan/policy integration Engaging in training/exercise opportunities Basic information on emergency preparedness and healthcare system preparedness

  21. Expectations for Emergency Management EMAs are not required to certify plans! EMAs (collaborate with CVEMA?) should develop a standard level of service for requesting facilities: Standard One-Pager Set platform for relationships and collaboration despite limited resources Encourage collaboration with Public Health and Healthcare Coalition

  22. Questions? Pete Svoboda MVP Coordinator Central Virginia Healthcare Coalition pete.svoboda@central-region.org RHCC 24/7 Activation: 1-800-276-0683

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