One of the things ASC directors should keep in mind while putting new emergency preparedness regulatory compliance on their to-do lists is that this advance work can prove to be a figurative and literal lifesaver in the event of an actual disaster.
Here’s an example of how an unanticipated hazard can be disastrous without proper planning and training: A man was smoking in the courtyard of a nursing home, fell asleep, and started a fire, recalls Patricia Howell, RN, BSN, clinical support manager at McKesson Medical-Surgical in Richmond, VA.
“They did not follow procedures for putting out the fire,” Howell says. “There was a fire blanket container on the courtyard wall, but there was no fire blanket in there.”
Because of the lack of preparedness, the smoker suffered terrible burns, she says. This fire disaster would have been averted if the facility had conducted a risk assessment and discovered that no one was checking emergency supplies to ensure they were in place and working.
“An ASC might have fire extinguishers and fire blankets, but are they functioning? Are you checking these things?” Howell asks.
The following are some strategies for assessing risk, creating an emergency preparedness plan, and complying with CMS’ new disaster preparedness regulations:
• Assess all risks and potential disasters. “The first thing to think about is any kind of disaster often comes with little or no warning,” Howell says. “You’re not going to hear sirens or receive a phone call that you need to evacuate.”
Power could go off or pipes could burst without warning. Tornadoes and storms can whip up in a flash.
“When I was in Omaha, NE, this storm came out of nowhere during tornado season, and we were sitting in front of big glass windows,” Howell says.
During a risk assessment, ASCs should determine where they would move patients and staff in the event of a sudden storm or tornado. Their risk assessment might address whether there are drapes or storm shutters to cover windows.
“Or what if a snow storm suddenly hits and people cannot get out? Now you have those people there,” Howell says. “Do you have the resources to shelter people in place for any period of time?”
Crescent View Surgery Center in Metairie, LA, is well-prepared for storms, hurricanes, tornadoes, and power outages, as these are not rare occurrences in the area. “We have policies in place to safeguard our patients against any of these types of incidences,” says Stephanie Danielson, RN, MSN, CNOR, administrator of Crescent View Surgery Center.
“If we have an extreme thunderstorm, we’re on watch. If we lose power, we’re on a generator, and surgeons complete the case as quickly as possible and get the patient into recovery,” Danielson says.
The purpose of risk assessment is to identify potential threats to the facility and include these threats in an emergency plan, says Mary Wei, assistant director of accreditation services at AAAHC, which provides disaster and emergency preparedness standards for ASCs that will be revised to reflect the new CMS regulations.
Threats can include the type of natural disasters that typically occur in an ASC’s geographical region, as well as the types of threats that any facility would face, such as fire, flooding (either from outside storms or busted pipes inside), or cyberattacks.
Also, threats can be problems that have never occurred in a region, but are increasing in frequency nationwide, such as active shooter situations, Wei says.
“At AAAHC, we don’t say you have to do XYZ drills,” she adds. “It’s up to the organization to decide on which drills to do for that year, but it could be based on the risk assessment and their priorities of disasters that would most likely impact them.”
• Set reasonable and actionable policies. “The best thing facilities can do is create a functional plan to deal with disasters that would provide details on what to do and how to operate during an emergency,” says Brendan McCluskey, JD, MPA, CEM, CBCP, director of emergency preparedness and operations at the New Jersey Department of Health in Trenton, NJ.
Also, they might create a continuity plan that is separate or part of the emergency plan, he says.
“The emergency plan can be designed to accommodate all hazards, so that no matter what the situation, the plan is applicable and appropriate,” McCluskey says.
At a minimum, ASCs should have emergency supplies on hand that include flashlights, bottled water, shelf-stable food, and emergency generators.
CMS provides templates on its website for writing disaster plans, but each plan and risk assessment should be unique to a particular ASC, Wei says.
For example, in the New Orleans area, the surgery center’s emergency preparedness plan for hurricanes includes instructions for how to handle evacuations. “We do not participate in catastrophic relief,” Danielson says. “We close the doors during a hurricane and evacuate.”
The ASC also prepares staff for what to do during a hurricane and keeps all emergency contact information updated. Also, employees can communicate with the ASC and each other on the facility’s website.
“We move all of our equipment into an area with no windows, and I take the week’s schedule with me, along with all essential phone numbers,” Danielson says. “Our computers are backed up on a digital, remote server.”
• Outline how the ASC will communicate with all stakeholders during an emergency. “Communication does make a difference,” Danielson says. “Communicate with your staff and municipality during a disaster.”
When an ASC does not know when it can get back into its building or, even, its area of the city, it’s important to know where all employees are, how to reach them, and how to stay in touch with local emergency preparedness officials.
“We have learned that communication is the most crucial part of it, from the lowest level to the highest,” Danielson says.
An ASC could designate a communication captain who makes sure they put lines of communication in place and keep them open, Howell recommends. If something happens, send out email blasts to staff and patients. If the only available communication devices are cellphones, then the communication captain should spread the word, calling people and setting up a chain of calls, she suggests.
Receiving emergency information also is important. For instance, ASCs should have some type of situational awareness for advance warning. For instance, they can purchase a NOAA All-Hazards/Weather radio and store it in a place where it’s easy to hear when there’s an alert, McCluskey suggests.
By building relationships with local emergency preparedness officials prior to a disaster, ASCs could learn more about ensuring their facility, staff, and patients’ safety and security, he adds.
Organizations can get involved with their state’s emergency preparedness-oriented coalitions, which are a forum for members to build relationships, exchange ideas, and gain access to situational awareness information, McCluskey says.
Also, healthcare professionals can participate in medical reserve corps units, which exist in some places to bring clinical and nonclinical providers together to help their communities deal with disasters, he explains.
“There are also opportunities for these facilities to interact with and build relationships with local emergency management offices, as well as local public health emergency preparedness personnel,” McCluskey says.
• Train staff and test procedures. Training staff should begin in-house, followed by drills to test the facility’s response, Wei says.
The new CMS regulations for disaster preparedness require drills, but allow for some tabletop exercises, she notes.
If an organization is unable to conduct its own mock disaster drill, then it can hold a tabletop drill in which there is a discussion among staff about what to do during a particular disaster. Risk managers and administrators lead the drill, Danielson says.
“AAAHC standards basically require one emergency preparedness disaster drill per quarter,” she says. “We specify that the drills are based on scenarios derived from the internal disaster and emergency preparedness plan, and it must include a CPR technique drill.”
AAAHC also requires organizations to evaluate their disaster drills and identify what worked and did not work, modifying and implementing changes accordingly. ASCs should assess and update their policies and test procedures at least annually, Wei advises.
“As they run drills throughout the years, they might find opportunities within those activities to make updates to their plans,” she explains.
One of the things ASC directors should keep in mind while putting new emergency preparedness regulatory compliance on their to-do lists is that this advance work can prove to be a figurative and literal lifesaver in the event of an actual disaster.
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