Denver Healthcare Facility Emergency Planning Workshop · 2018-04-25 · Denver Healthcare Facility...

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Denver Healthcare Facility Emergency Planning Workshop

Wednesday, April 25, 2018

Denver Post Auditorium

Agenda• Welcome and Introductions • Denver Emergency Management• Healthcare Coalition Overview• Centers for Medicare & Medicaid Services (CMS)• Elements of an Effective Healthcare Facility Emergency Plan• Discussion of Boulder Floods and Impacts to Healthcare• Panel Discussion• Wrap Up and Next Steps

Introductions• Name• Organization/Facility• Position/Role

Denver Emergency Management

Ryan BroughtonExecutive Director,Denver Office of Emergency Management (OEM)

Office of Emergency Management

City & County of DenverCommunity Profile

• “Mile High City” (5280ft)• $180B metro economy (~Greece)

– 67,500 businesses• 155 square miles (249 km2)

– Plus 14,000 acres of Mountain Parks• 5th Busiest U.S. Airport

– 18th Busiest Airport in the World– 61.8 million passengers in 2017

• 2016 “Best Place to Live”• Geographic Isolation

– Largest city in 500 mile radius6

City & County of DenverCommunity Profile

• 704,164 residents– 19th Largest U.S. City– 1M daytime population – 32.5M annual visitors– 2.9M in Denver Metro– 3.4M in Denver CSA– 32% speak English as

second language• 78 Neighborhoods• 11 Council Districts

City & County of DenverEmergency Management Infographic

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City & County of DenverEmergency Management Strategy

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City & County of Denver Local Risk Management

• Denver Risk Assessment– OEM manages multi-

agency risks from natural, technological, terrorism, and intentional threats and hazards

– Focused on prevention, protection, mitigation, response, and recovery operations

• Disease Outbreak/Bioterrorism• Hazardous Materials Incident• Terrorism• Flooding• Destructive Weather• Utilities Interruption/Failure

• National State of Emergency• Earthquake• Fire (Structural, Industrial, Wildland)• Active Shooter• Aviation Incident• Cyberterrorism• Drought• Civil Unrest• Ground Subsidence/Sinkholes• Agricultural Disease Outbreak• Cyber Crime• Nuclear Weapon Accident/Incident 10

City & County of Denver Healthcare Risk Management

• Healthcare Risk Management– Healthcare planning should address risks specific the

facility and to healthcare operations as a whole

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Healthcare-specific RisksDisease OutbreakCyber CrimeCriminal ActivityFloodingUtilities Interruption/FailureHazardous Materials IncidentDestructive Weather (wind, hail)Fire (Structural, Interior)Food-borne DiseaseIntentional Threats (shooting, attack)Civil UnrestEarthquake

Denver-wide RisksDisease OutbreakHazardous Materials IncidentActs of TerrorismFloodingDestructive WeatherUtilities Interruption/FailureNational State of EmergencyEarthquakeFire (Structural, Industrial, Wildland)Active ShooterAviation IncidentCyberterrorism

City & County of DenverEmergency Management Planning

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City & County of Denver Healthcare Emergency Planning

• Healthcare Emergency Planning– Healthcare planning should address healthcare

processes to support prevention and response

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Healthcare-specific PlanningFacility RisksManagement ProcessStaff Contact Information/ProcessDelay or Closure AuthorityWarning Process for FacilityPublic Information ProcessScreening and Physical SecurityCybersecurity ActivitiesCrime Prevention/DeterrenceHealthcare OperationsFacility Response CONOPSFacility Recovery CONOPS

Denver-wide PlanningLaws & AuthoritiesPlanning ResponsibilitiesConcepts of Operation (CONOPS)Department/Agency FunctionsAnnexes for Public Info & Warning,

Prevention, Mitigation, Response, Recovery, & Continuity capabilities

Appendices for each Risk

City & County of DenverEmergency Management Capabilities

From Foundation…

… to Capstone …

… to Fully Integrated

• Federal (National Planning Frameworks)

• State (Colorado State Government)

• State Regions (Colorado All-Hazards Regions)

• Tribal

• County

• Local (City, Town)

• Non-governmental Organizations

• Facilities

• Businesses

• Private Industry

• Individual Residents

The use of a consistent framework allows organizations at all levels to work together more efficiently

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City & County of Denver Emergency Management Capabilities

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• FEMA Core Capabilities– 32 Core Capabilities across

five mission areas:• Prevention • Protection • Mitigation • Response• Recovery

– Each capability requires:• Planning• Organization• Equipment• Training• Exercises

POETE Model

Most Capabilities relevant to Healthcare Facilities

City & County of DenverEmergency Management Capabilities

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1) Prepare ourselves, our families, and our neighborhoods for all emergencies through strategic engagement with the public

2) Prepare our employees and our partners to meet the demands of all emergencies

3) Prepare Denver to manage the risks to our communities, residents, businesses, economy, and environment

4) Mitigate potential natural and technological hazards through strategic investment and partnership

5) Prevent terrorism and intentional threats through information sharing, intervention, and deterrence

6) Respond to and Recover from all emergencies impacting our residents, businesses, operations, and environment

City & County of DenverPreparedness Concepts

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• Community Preparedness– Community Outreach (Social

Media, Print/TV Media, Web)– PREP (Prepare, Respond,

Prevent) Outreach Training– CERT (Community Emergency

Response Team)– Local Emergency Planning

Committee (LEPC) Outreach– Ready.gov

“See Something, Say Something, Do Something”

City & County of DenverPreparedness Concepts

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• Business Preparedness– Business and Private

Industry Outreach– Healthcare Outreach– Special Events Outreach– Local Emergency Planning

Committee (LEPC) Outreach

• Employee Preparedness– Denver Ready Campaign

“See Something, Say Something, Do Something”

City & County of DenverPublic Information & Warning

• Warning Systems– Outdoor Warning

System (86 sirens)– Emergency Notification

System (phone/text/ email/social media)

– Reverse911 System (phone/text/email)

– Integrated Public Alert & Warning System (text/radio/TV)

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City & County of DenverResponse Concept

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City & County of DenverEmergency Operations Center (EOC)

• 72-position EOC for Multi-Agency Coordination

• 18-position Joint Information Center (JIC) for Emergency Public Information

• Supporting Departmental Ops Centers (DOCs)

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• Continuity Programs and Critical Infrastructure Protection• 11 Disaster District Offices (DDOs)• 11 Logistics Staging Areas (LSAs)• 100 Commodities – Points of Distribution (C-PODs)• 40 Pharmaceutical – Points of Dispensing (P-PODs)• 100 Mass Care Shelters

City & County of DenverResponse Concept

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City & County of DenverEmergency Management Services

• Denver OEM Contact Information:– By Mail: 1437 Bannock St. #3, Denver, CO 80202– By Phone: (720) 865-7600

• Duty Officer: (720) 865-5500

– By Email: EOC.Operations@denvergov.org – On the Web:

www.denvergov.org/content/denvergov/en/office-of-emergency-management.html

– On Facebook: www.facebook.com/DenverOEM/– On Twitter: @DenverOEM

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Healthcare Coalition OverviewLisa Filipczak, MPHPublic Health Planner,Denver Public Health

Michelle Deland, MARegional Planner,North Central Region Healthcare Coalition

Colorado Healthcare Coalitions –What Are They Good For?

MICHELLE DELAND, MA – NORTH CENTRAL REGION HEALTHCARE COALITION

LISA FILIPCZAK, MPH – DENVER PUBLIC HEALTH/METRO FOOTHILLS HEALTHCARE COALITION

What is a Healthcare Coalition?

Healthcare Coalitions facilitate those activities that serve to enhance and support emergency preparedness and planning activities among diversehealthcare organization within a geographic region

Focus on collaboration, planning, relationship building, and communication

Activities supported by the coalition include: Trainings Exercises/drills Networking opportunities Discipline-specific and/or topic-specific workgroups Promotion of the integration of health and medical

initiatives into the larger region as well as state emergency management system

North Central Region Healthcare Coalition -EST. 2017-

North Central Region Healthcare CoalitionEnhancing regional health and medical preparedness, response, and recovery

capabilities throughout the state of Colorado’s North Central Region.

State Federal

Current/Future NCR HCC Initiatives

Continued integration and support of Ancillary Healthcare members, in part, through the NCR Ancillary Healthcare Workgroup

Development of a stronger cross jurisdictional health and medical response system

Regional resource and gap analysis Regional communications Healthcare and hospital evacuation and surge planning Continued integration into the larger emergency

management structure within the region

Metro Foothills Healthcare Coalition

Formed in March of 2016 Combined Denver and Foothills Healthcare

Coalitions (HCCs) Co-chaired by Denver Public Health and Jefferson County

Public Health Includes five counties within North Central Region:

Broomfield Clear Creek Denver Gilpin Jefferson

June 2017 - Had 150 members representing 85 agencies Today we have 284 members representing 154 agencies

Metro Foothills Healthcare Coalition

Members: Anyone is welcome to join, and the following disciplines are currently involved in the MFHCC: Behavioral health

Community partners

Coroners

EMS

Emergency management/public safety

Hospitals (Acute and Non-Acute

Local, state or federal government entities

Long-term care facilities

Home health agencies

Outpatient/specialty clinical providers (Clinics, FQHC, dialysis, ambulatory care centers, surgery centers, etc.)

Public and environmental health

Other (schools, private companies, etc.)

www.metrofoothillshcc.com

2017 Member Survey –Benefits of MFHCC

Networking Events – Full Moon Snowshoe Hike Mt. Evans

MFHCC Member Site Visits and Exercises

How Do I Benefit from HCC Membership?

Attend meetings Share questions/lessons learned/resources Participate in trainings/exercises/quarterly drills Schedule a site visit by the co-chairs Ask for assistance Network with members

Takeaway – You get what you give

How Do I Join My Local HCC Chapter?

We are so glad you asked!

Contact Information:

Lisa Filipczak, MPH – Denver Public Health/Metro Foothills Healthcare Coalition Ph. 303-602-3668

Lisa.filipczak@dhha.org

Michelle Deland, MA – North Central Region Healthcare Coalition Ph. 303-588-8488

mdeland@ncrhcc.org

Break

Centers for Medicare & Medicaid Services (CMS)

CDR David LumState Oversight Branch,Centers for Medicare & Medicaid Services

Karen FullerState Oversight Branch Manager,Centers for Medicare & Medicaid Services

Denver Healthcare WorkshopApril 25, 2018

Emergency Preparedness Final Rule and 1135 Waivers

Prepared by the Centers for Medicare & Medicaid Services (CMS), Western Division of Survey & Certification Group

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Emergency Preparedness Final Rule

• Published September 16, 2016• Applies to all 17 provider and supplier types• Implementation date November 15, 2017• Compliance required for participation in Medicare• Emergency Preparedness is one new Conditions for

Participation (CoP)/Condition for Coverage (CfC) of many already required

• Appendix Z contains Interpretive Guidance and survey procedures

• The new EP Tags are E-Tags and will produce a new 2567.

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Four Provisions for All Provider Types

Risk Assessment and Planning Policies and Procedures

Communication Plan Training and Testing

Emergency Preparedness

Program

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Risk Assessment and Planning

• Develop an emergency plan based on a risk assessment.

• Perform risk assessment using an “all-hazards” approach, focusing on capacities and capabilities.

• Update emergency plan at least annually.

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All-Hazards Approach:

• An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters, including internal emergencies and a man-made emergency (or both) or natural disaster. This approach is specific to the location of the provider or supplier and considers the particular type of hazards most likely to occur in their areas. These may include, but are not limited to, care-related emergencies, equipment and power failures, interruptions in communications, including cyber-attacks, loss of a portion or all of a facility, and interruptions in the normal supply of essentials such as water and food.

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Policies and Procedures

Facilities must develop policies and procedures based on the EP plan and communication plan.

Policies and procedures must:

• Be reviewed and updated annually• Address subsistence needs of patients and staff• Include a system to track patients and staff• Include a plan for safe evacuation

Policies and Procedures (cont’d)

Policies and procedures must address:

• How patients, staff and volunteers would shelter in place

• A system of medical documentation that maintains availability of records, protects confidentiality, etc.

• Staffing strategies and the use of volunteers• Patient transfer arrangements with other facilities • The provision of care at an alternate site (under an

1135 waiver)

Communication Plan

Facilities must develop and maintain a communication plan that complies with Federal, State and local laws. The plan must be reviewed and updated annually

The plan must include:

• Contact information for staff, patient physicians, volunteers, contractors, other facilities as appropriate

• A primary and alternate means for communication• A method for sharing patient information to other

providers

Communication Plan (cont’d)

The plan must include:

• A means to release patient information due to an evacuation (as permitted under HIPAA rules)

• A means of providing information about the location and general condition of patients (as permitted under HIPAA rules)

• A means to provide information, regarding the facility’s occupancy, needs, and its ability to provide assistance to the authority having emergency jurisdiction

Training and Testing

Facilities must develop and maintain an EP training and testing program. The program must be reviewed and updated annually.

• Initial training required for all new and existing staff, volunteers and individuals providing services under arrangement (contractors, per diem staff, etc.)

• Annual training required thereafter• Must maintain documentation of the training• Training may be tailored to specific staff roles

Testing: Annual Exercises

Facilities must conduct exercises on an annual basis

• Participate in a full-scale community based or individual based exercise (when a community based exercise is not available)

• Conduct a second exercise (may be full-scale community or individual exercise or tabletop exercise)

Testing: Annual Exercises (cont’d)

• If a facility experiences an emergency that requires activation of the emergency plan, the facility is exempt from having to complete a full-scale exercise for one year following the event

• Must analyze the responses to and maintain documentation of all drills, exercises and actual emergencies and update emergency plan as needed

Integrated Healthcare Systems

Facilities that are part of a system consisting of multiple, separately certified healthcare facilities that elects to have a unified and integrated emergency preparedness program (EP), may choose to participate in the system’s unified and integrated EP program.

Integrated Healthcare Systems

If a facility elects to participate in the unified EP program, the facility must demonstrate/include:

• Active participation in the development of the unified program

• The facility’s unique circumstances, patient populations, and services are part of the program

• It is capable of utilizing the unified EP program• A community-based and facility based risk assessment

specific to the facility• Integrated policies and procedures that meet all

requirements

Facilities with Multiple Locations

All locations of a Medicare certified provider or supplier must be included in the facility’s EP program (all locations operating under the same CCN).

Off-campus locations of a Medicare certified provider or supplier that are co-located with another healthcare entity must be part of it’s facility’s EP program but may collaborate with the co-located entity as part of each facility’s community-based risk assessments and community-based exercises.

Be Aware of Slight Differences in Requirements

• Outpatient providers are not required to have policies and procedures for the provision of subsistence needs.

• Home health agencies and hospices required to inform officials of patients in need of evacuation.

• Long-term care and psychiatric residential treatment facilities must share information from the emergency plan with residents and family members or representatives.

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Look at the Resources

• SCG’s Emergency Preparedness Website has an area with FAQs and resources available to the stakeholders

• https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html

• ISTW EP Training Module: https://surveyortraining.cms.hhs.gov/

The SCG Website

1135 Waivers

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• Scope - Federal Requirements only, not state licensure

• Purpose - Allow reimbursement during an emergency or disaster even if providers can’t comply with certain requirements that would under normal circumstances bar Medicare, Medicaid or CHIP payment

• Duration - End no later than the termination of the emergency period, or 60 days from the date the waiver or modification is first published unless the Secretary of HHS extends the waiver by notice for additional periods of up to 60 days, up to the end of the emergency period.

1135 Waivers

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Needed for 1135 Waivers

• The President declares a disaster or emergency under the Stafford Act or National Emergencies Act

• The HHS Secretary declares a public health emergency under Section 319 of the Public Health Service Act

Considerations for Waiver Authority

• Scope and severity of event with specific focus on health care infrastructure

• Are there unmet needs for health care providers?

• Can these unmet needs be resolved within our current regulatory authority?

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Examples of 1135 Waiver Authorities

Conditions of Participation

Licensure for Physicians or others to provide services

in affected state

Emergency Medical Treatment and

Labor Act (EMTALA)

Stark Self-Referral Sanctions

Medicare Advantage out of network

providersHIPAA

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• 1135 waivers are not a grant or financial assistance program

• Do not allow reimbursement for services otherwise not covered

• Do not allow individuals to be eligible for Medicare who otherwise would not be eligible

• Should NOT impact any response decisions, such as evacuations.

• Do not last forever. And appropriateness may fade as time goes on.

What waivers DON’T do:

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Expectations of Waived Providers

Provide sufficient information to justify actual need

Providers and suppliers will be required to keep careful records of beneficiaries to whom they provide services, in order to ensure that proper payment may be made.

Providers must resume compliance with normal rules and regulations as soon as they are able to do so

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Thank you!

SCGEmergencyPrep@cms.hhs.gov

Sandra PaceAssociate Consortium Administrator, Consortium for Quality Improvement and Survey & Certification OperationsSandra.Pace@cms.hhs.gov

Steven ChickeringAssociate Regional Administrator, Western Division of Survey & CertificationSteven.Chickering@cms.hhs.gov

Robert CasteelSurvey Manager, Western Division of Survey & Certification, Denver Regional OfficeJerry.Casteel@cms.hhs.gov

Karen FullerState Oversight Branch Manager, Western Division of Survey & Certification, San Francisco Regional OfficeKaren.Fuller@cms.hhs.gov

CDR David LumState Oversight Branch, Western Division of Survey & Certification, San Francisco Regional OfficeDavid.Lum@cms.hhs.gov

WDSC Region VIII– Point of ContactEmergency Disaster Team

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Questions?

Elements of an Effective Healthcare Facility Emergency Plan

David PowellPlanning Coordinator,Denver Office of Emergency Management (OEM)

Planning Questions

Why do we need a Plan?

What would I need to do during an emergency?

Who is responsible for what?

How are we going to get it done?

Before you Plan

“If you don't know where you are going,

you'll end up someplace else.”

- Yogi Berra

Define your planning goals.

Assemble a diverse planning team.

Know the facts about your facility and the community around you.

Know your audience.

Why: Facility Background and Risk Assessment

Describe your facility and what it provides to the community.

Describe your technological, natural, and security threats.

What would be the consequences of each hazard or threat? (Why do I need a plan?)

Stop and think of ways you could mitigate any of these hazards.

What: Capabilities Assessment

“Nothing about me, without me.”- Axiom of patient-

centered care

What capabilities would be needed to respond to and recover from these hazards?

Are there any gaps between what capabilities you have and what you need?

What resources can the community provide to fill these gaps? (don’t assume!)

Can I build or contract capabilities to fill capability gaps?

What: Capabilities Assessment (examples)

- Subsistence for staff and patients

- Patient tracking

- Shelter in place supplies and procedures

- Media and government relations/coordination

- Emergency generation

- Evacuation procedures, transportation, and destination agreements

- Notification to staff, patients, and families

- Continued regulatory compliance

Who: Organization and Concept of Operations

“911 is not a plan”- Ryan Broughton

Who is responsible for building and executing each emergency capability?

Define your facility’s all hazards emergency management processes.

Implement a clear chain of command and resilient communications plan.

Include contact information by position and define who will notify staff and how.

How: Annexes, Checklists, and Standard Operating Procedures (SOP)

“[T]he checklist isn’t a crutch… It’s

a way of getting right, every single time, something that needs to be done right every

single time.”

-Chesley B. “Sully” Sullenberger

Use annexes or supporting SOPs for each function.

Staff members should know their roles and have checklists or SOPs to follow.

Make it easy for staff to find the portions of the plan most relevant to them.

This is where you should add the specific details of how things get done.

Equip, Train, and Exercise

“Everyone has a plan 'till they get punched in

the mouth.”– Mike Tyson

Plans aren’t intended to sit on the shelf.

Create a culture of emergency preparedness.

A plan that isn’t implemented and exercised only serves as a liability.

Include exercise, training, and update schedules in your plan.

Questions?

Discussion of Boulder Floods and Impacts to Healthcare

Break

Panel Discussion

Panel Members• Denver Department of Public Health and Environment• Denver Public Health/Metro Foothills Healthcare Coalition• Denver Health Paramedic Division• Denver Office of Emergency Management• Colorado Healthcare Association

• Moderator: North Central Region Healthcare Coalition

Wrap Up and Next Steps

Participant Feedback

https://goo.gl/forms/AkkxAIdOW6bx9rVw2