Nov 15, 2017 - Medicaid Services published the Final Rule on Emergency. Preparedness Requirements for Medicare ... An al
HE A LTHCARE FACILITY ALERT! Medicare Emergency Preparedness Compliance Deadline Fast Approaching by Dan Williams, AKF Group
prior to, during, and after an emergency or disaster. The requirements are focused on three key essentials necessary for maintaining access to healthcare during disasters or emergencies: • Safeguarding human resources • Maintaining business continuity • Protecting physical resources
Image: © Anton Grassl / Esto
The past 10 –12 years have brought increased awareness on the part of federal agencies about the need for healthcare institutions to be better prepared to plan for and deal with natural, man-made, and / or facility-based disasters. Following the devastation caused by Hurricane Katrina in 2005 in New Orleans, Cuba, Louisiana, Alabama, the Bahamas, and Southern Florida, FEMA 577: Design Guide for Improving Hospital Safety in Earthquakes, Floods, and High Winds was introduced in June 2007. Then, in 2012, Superstorm Sandy resulted in severe damage to the Caribbean Islands and the entire eastern seaboard of the USA from Florida to Maine, with particularly severe damage in New Jersey and New York. As a direct response to the frequency and increased strength of these mega-storms, on September 16, 2016 the Department of Health and Human Services Centers for Medicare and Medicaid Services published the Final Rule on Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. This rule affects all 17 provider and supplier types eligible for participation in Medicare. The rule became effective on November 15, 2016 and will be implemented on November 15, 2017. The Final Rule assists providers and suppliers with adequately preparing to meet the health, safety, and security needs of the facility, its staff, their patient population, and community
Successful adoption of these requirements will enable all providers and suppliers, wherever they are located, to better anticipate and plan for needs and rapidly respond as a facility. Additionally, providers and suppliers will be able to integrate with local public health and emergency management agencies and healthcare coalitions’ response activities to rapidly recover following the disaster. This white paper is intended to focus on issues specifically related to healthcare facilities and the systems that support them, to alert healthcare institutions about the need for compliance with the new rules, and to plan ahead for future emergencies. What types of emergencies do these regulations cover? An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities critical to preparedness for a full spectrum of emergencies or disasters. This approach is specific to the location of the facility considering the types of hazards most likely to occur in the area. • Natural disasters (e.g., earthquakes, hurricanes, floods, tornados, etc.) • Man-made disasters (e.g., terrorist attacks, fires) • Facility-based disasters (e.g., equipment and utility failures, including but not limited to power, water, and gas; interruptions in communication, including cyber-attacks;
loss of all or a portion of a facility; and interruptions to the normal supply of essential resources, such as water, food, fuel (heating, cooking, and generators), and in some cases, medications and medical supplies (including medical gases, if applicable) Risk Assessment: The First Step The Emergency Preparedness Program requires that healthcare institutions create a risk assessment that evaluates the following: • Risk to patients from natural disasters • Risk to patients from external man-made disasters and acts of terrorism • Risk to patients from internal failure of equipment • Risk to patients from utility failures
be in accordance with local and state laws, as well as relevant LSC requirements. The following are potential options for providing alternate sources of energy to maintain temperatures, emergency lighting, fire detection and extinguishing systems, and sewage and waste disposal: • Portable emergency generators could be installed in advance of a known natural disaster • Permanent emergency generators — please note that LSC provisions such as generator testing and maintenance will apply and the facility may be subject to LSC surveys to ensure compliance is met Engineering Survey: An Important Part of the Emergency Preparedness Process
Compliance Requirements A wide range of systems constitute the operational infrastructure that permits safe and reliable patient care to be performed. Some of the most important utilities include mechanical (e.g., heating, refrigeration, ventilation, and cooling); electrical (i.e., normal power and emergency power); domestic hot and cold water as well as other plumbing systems; waste; technology systems including the myriad communications and datatransfer systems; vertical transportation utilities; fire alarm and suppression systems; fuel systems; access control, duress alarm, and surveillance systems; medical gases, air, and vacuum systems; and pneumatic tube systems. Healthcare organizations are expected to establish policies and procedures that determine how required heating and cooling of their facility will be maintained during an emergency situation if there were a loss of the primary power source. Facilities are not required to upgrade their electrical systems or to have / install generators or any other specific type of energy source. However, after review of their risk assessment, facilities may find it prudent to plan for alternate sources of energy to maintain temperatures to protect patient health and safety during an emergency, and for the safe and sanitary storage of provisions; emergency lighting; fire detection, extinguishing, and alarm systems; and sewage and disposal. Whatever alternate sources of energy a facility chooses to utilize must
An engineer’s survey of existing MEP / FP systems is highly recommended to ensure that a healthcare facility is in compliance with the new guidelines for providing alternate energy services as required by the Final Rule on Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. The survey will include a failure analysis with recommendations for upgrading to meet compliance. It will also provide options and recommendations for providing alternate power to address heating and cooling, as well as water, air conditioning, lighting, etc. Where applicable, it will also address smoke purge and back-up chillers for operating rooms. A formal report will indicate to government officials that the healthcare facility is making every effort to comply with the new regulations which go into effect on November 15, 2017.
AKF Group is an award-winning, full-service engineering firm providing a broad range of core engineering and integrated services to public and private sector clients across the United States and around the world.
akfgroup.com
