FQHCs and Emergency Preparedness: a 2011 Accreditation Odyssey

1. FQHCs and Emergency Preparedness: a 2011 Accreditation Odyssey  Amelia Muccio Director of Emergency Mgt NEW JERSEY PRIMARY CARE ASSOCIATION

2. Prologue • Special thanks to Mollie Melbourne of NACHC for her assistance & research on the material in this PPT <*)))><

3. Objectives • Review FQHC accreditation standards for emergency preparedness: • Bureau of Primary Health Care Policy Information Notice 2007-15 (PIN) • Joint Commission (JC) • Accreditation Association for Ambulatory Care (AAAHC) • National Incident Management System (NIMS)

4. Emergency Management Plan (EMP) • PIN: plans & procedures for EM must be integrated… • JC: EM.02.01.01-the organization has a written EMP… • AAAHC: 7.F-organization has comprehensive written emergency plan… • NIMS: 2008/2009 objective 3-revise and update EOPs and SOPs…

5. What is in an EMP? • EMP is comprehensive, self-contained document that includes the components necessary to guide all emergency activities • Is essential to minimize the disruption of services • Ensure predictable staff behavior during an emergency • All-Hazards approach • Review ESF #8 • EMP should be aligned and integrated in local and State EMPs “unified front”

6. FQHC’s EMP Elements • Continuity of Operations • Command and Control • Staffing • Surge Patients • Medical and Non-Medical Supplies • Pharmaceuticals • Security • Evacuation • Decontamination • Isolation • Power Supply • Transportation • Water/Sanitation • Communications • Medical Records Security and Access

7. Plan/Organization is NIMS compliant • PIN: strongly encouraged… • JC: n/a • AAAHC: n/a • NIMS: 2008/2009 objective 1-adopt NIMS and objective 2-fed preparedness awards support NIMS implementation…

8. What is NIMS? • A comprehensive, nationwide, systematic approach to incident management, including the Incident Command System, Multiagency Coordination Systems, and Public Information • National Incident Management System (NIMS) is a comprehensive, national approach to incident management that is applicable at all jurisdictional levels and across functional disciplines (lowest jurisdictional level) • Applicable across a full spectrum of potential incidents and hazard scenarios, regardless of size or complexity • Improves coordination and cooperation between public and private entities in a variety of domestic incident management activities

9. Hazard Vulnerability Analysis (HVA) • PIN: should initiate emergency management planning by conducting HVA… • JC: EM.01.01.01/EP2-HVA… • AAAHC: 3.F-a program is maintained to assess and where necessary reduce risks (physical hazards, violence in workplace, terrorism, etc)… • NIMS: n/a

10. What is a HVA? • Identifies potential emergencies and the direct/indirect effects these emergencies may have on CHC’s operation and demand for services • The risks identified should be prioritized based on likelihood of occurrence and severity

11. Plan: Four Phases of Emergency Management • PIN: EMP should address 4 phases of EM… • JC: EM.01.01.01/EP4/EP2/EP5/EP6-need for planning, preparedness, response and recovery activities…. • AAAHC: n/a • NIMS: 2008/2009 objective 3- include planning, training, response exercises, corrective actions…

12. What are Four Phases of EM? Mitigation (including prevention): reduce or eliminate impact of hazards (generators) Preparedness: build capabilities to respond and recover from the impacts of those hazards (this training) Response: gain control over on-going negative effects of the hazards (staying open) Recovery: return to pre-disaster condition (normal business operations) • .

13. Plan: Developed by Multi-Disciplinary Team • PIN: Essential that EMP developed by interdisciplinary approach… • JC: EM.02.01.01/EP1-the organizations’s leaders participate in development of EMP… • AAAHC: n/a • NIMS: n/a

14. Possible Planners? • CEO • COO • DON • CFO • Director of Security • Emergency Preparedness Contact • Billing Manager • Medical Director • Facility Manager • Administrative Supervisor • PCA

15. Plan: Patient Surge • PIN: CHCs should describe approach to responding to increased demand on organizaitons’s services… • JC: EM.02.02.11-as part of EMP, the organization prepares for how it will manage patients during emergencies… • AAAHC: n/a • NIMS: n/a

16. Plan: Resource Management • PIN: EMP should address possible roles for CHCs including medical and non-medical supplies… • JC: EM.02.02.03/EP1/EP2/EP3/EP12-As part of EMP, organization prepares for how it will manage resources and assets during emergencies/obtain and replenish supplies... • EMP must address advance preparation to provide resources and assets during an emergency… • AAAHC: 8.C-The organization has the necessary personnel, equipment and procedures to deliver safe care, and to handle emergencies… • NIMS: n/a

17. Resource Management • Standardized seven-step cycle for managing resources during an incident • Step 1: Identify Requirements • Step 2: Order & Acquire • Step 3: Mobilize • Step 4: Track & Report • Step 5: Recover/Demobilize • Step 6: Reimburse • Step 7: Inventory

18. Plan: Method for Structuring Staff During Emergency Response • PIN: CHCs should have all-hazards command structure within the organization such as ICS… • JC: EM.02.02.07/EP1/EP2/EP3/EP4-manage staff during emergencies; role and responsibilities of staff; assigning staff; chain of command (reporting structure)… • AAAHC: the organization has the necessary personnel, equipment and procedures to deliver safe care and to handle medical and other emergencies… • NIMS: 2008/2009 objective 11/12-ICS/ICS with IAP…

19. ICS 101 • Incident-Focused organizational structure that can be implemented along side of day-to-day administrative structure of an organization • Allows its users to adopt an integrated organizational structure to match the demands of the incident • Based on best practices • Promotes incident safety • Achievement of tactical objectives • Efficient use of resources • 3 Priorities of ICS • Life Saving • Incident Stabilization • Property Preservation

20. Key Features of ICS • Common terminology • Modular organization • Management by objectives • Reliance on IAP • Chain of command/unity of command • Unified command • Manageable span of control • Pre-designated incident locations and facilities • Resource management • Information and intelligence management • Integrated communications • Transfer of command • Accountability • Dispatch/Deployment

21. ICS Functions

22. Plan: Use of Volunteer Licensed Independent Practitioners • PIN: n/a • JC: EM.02.02.13/15-during disasters, the organization may grant disaster privileges to volunteer licensed independent practitioners and may assign responsibilities to volunteer practitioners who are required by law to have a license, certification or registration; refer to 2009 Standards for Ambulatory Care • AAAHC: n/a • NIMS: n/a

23. Federal Tort Claims Act (FTCA) • FTCA coverage for eligible HRSA grantees was initially legislated through FSHCAA of Public Health Service Act • In the event a medical malpractice lawsuit is filed against a deemed entity or covered provider acting within the scope of his/her employment in grant related activities, the United States is substituted for the deemed entity and the covered employee • The CHC and employee are dismissed from case and the case continues against the United States as the sole defendant

24. Plan: Detailed Communication Section • PIN: EMP should identify policies and procedures for communicating with internal staff and external stakeholders… • JC: EM.02.02.01/EP1/EP3-method for communicating during emergencies and how internal and external stakeholders are notified… • AAAHC: n/a • NIMS: 2008/2009 objective 9, 13, 14-communication standards, public information, PIO, JIC, JIS…

25. Public Information • PIOJICJIS • PIO provides accurate, coordinated, timely and understandable information • JIS provides an organized, integrated and coordinated mechanism for providing info to the public during an emergency (JIC is physical asset) • Public information, education strategies, and communications plans help ensure that numerous audiences receive timely, consistent messages about • Lifesaving measures • Evacuation routes • Threat and alert system notices • Other public safety information

26. Plan: Communication Systems • PIN: EMP has redundant communication… • JC: EM.02.02.01/EP14/EP17-backup communications for internal/external, in advance of emergency… • AAAHC: n/a • NIMS: 2008/2009 objective 8 & 10-interoperability (equipment, communications, data) and accurate information during incident…

27. Communication Features • Integrated communications: • Common interoperable communication plan (modes, planning and networks) • Information and intelligence management: • Critical info for response (gather, share and manage info) • Weather info, risk assessments, surveillance)

28. Plan: Activating and Deactivating Plan • PIN: EMP should describe under what circumstances and how, when and by whom the EMP is activated… • JC: EM.02.01.01/EP5/EP6-process of initiating and terminating the organizations’s response and recovery phases; EMP identifies individuals responsible for activating the response and recovery phase… • AAAHC: n/a • NIMS: n/a

29. Plan: Provisions for Staff Training • PIN: CHCs should provide ongoing training on emergency management and the implementation of the EMP to employees… • JC: n/a • AAAHC: The organization provides documented periodic instruction of all personnel in the proper use of safety, emergency and fire extinguishing equipment… • NIMS: 2008/2009 objective 5/6/7-complete IS 100, 200, 700 and 800 courses, Promote NIMS and ICS

30. Rationale for Staff Training • We are only as prepared as the lowest common denominator • Disaster planning assists with: • Ability to rotate staff • Organizational agility • Plans, drills, and evaluations • Training and education • Staff protection and support • Communications and reporting • Supplies and equipment • Obligation to community • Educating staff is an investment!

31. Plan: Conducting Drills and Exercises • PIN: CHCs should continually test and evaluate the effectiveness of their EMP and make adjustments as necessary; the frequency and methods of testing and evaluation (tabletops, functional exercises, etc) should be determined by org. but should be at least on annual basis…

32. Plan: Conducting Drills and Exercises • JC:EM.03.01.03/EP1/EP2/EP5/EP13/EP14/EP16/EP17-the organization evaluates the effectiveness of its EMP, as an emergency response exercise; the organization activates its EMP twice a year at each site included in the Plan (tabletops not acceptable)-each site of the organization that offers emergency services or is a community-designated disaster receiving station…

33. Plan: Conducting Drills and Exercises (JC Con’t) • at least one of the organization's two emergency response exercises includes an influx of simulated patients; exercises incorporate likely disaster scenarios that allow the organization to evaluate its handling of communications, resources, and assets, security, staff, utilities and patients, representatives from administration and clinical services should participate in response exercise/actual emergency…

34. Plan: Conducting Drills and Exercises (JC Con’t) • evaluation of all exercises and actual emergencies includes identification of deficiencies and opportunities for improvement (must be documented); organization modifies its EMP based on evaluations of emergency response exercises and actual emergencies; subsequent emergency response exercises reflect modifications and interim measures as described in modified EMP…

35. Plan: Conducting Drills and Exercises • AAAHC: 8.E-the organization requires at least one (1) drill each calendar quarter of the internal emergency preparedness plan; one (1) of the annual drills must be a documented cardiopulmonary resuscitation (CPR) technique drill; the organization must complete a written evaluation of each drill and promptly implement any corrections… • NIMS: 2008/2009 objective 3/7-revise and update EOPs/SOPs and promote NIMS/ICS in all training and exercises…

36. Homeland Security Evaluation and Exercise Program (HSEEP) • The Homeland Security Exercise and Evaluation Program (HSEEP) is a capabilities- and performance-based exercise program that was developed to provide common exercise policy and program guidance that constitutes a national standard for exercises • HSEEP is designed to be adaptable to any exercise program, regardless of the nature and composition of its sponsoring agency or organization, and to the full spectrum of exercise scopes and scenarios • This includes consistent terminology, design process, evaluation tools, and documentation standards

37. Types of Exercises—Building Block Approach • Seminar (Discussion) • Workshop (Discussion) • Tabletop Exercise (TTX) (Discussion) • Games (Discussion) • Drills (Operations) • Functional Exercises (FXE) (Operations) • Full Scale Exercises (FSE) (Operations)

38. Plan: Integrating CHC Plan and Response with Community • PIN: CHC’s EMP should be integrated into State and local EMPs already in place to maximize alignment and integration… • JC: EM.01.01.01/EP4-organization determines what its role will be, if any, in the community response plan… • AAAHC: n/a • NIMS: 2008/2009 objective 4-participate in interagency mutual aid agreements (public and private sector)…

39. External Partners (Integration) • Feds • State/Regional • Local/Tribal • Non-Profit (voluntary) • Social Services • Healthcare and Public Health • Police/Fire/EMS • Private Sector • Industry • Schools and Academia • Churches and FBOs • Animal Welfare Orgs

40. Plan: Access for Special Populations • PIN: CHCs should plan for assuring access to special populations such as migrants and seasonal farm workers, homeless, residents of public housing, non-English speaking, disabled, elderly and those living with HIV… • JC: n/a • AAAHC: n/a • NIMS: n/a

41. At Risk: CMIST-Functional Needs • At-risk individuals are those who have, in addition to their medical needs, other needs that may interfere with their ability to access or receive medical care. They may have additional needs before, during, and after an incident in one or more of the following functional areas (C-MIST): • Communication • Medical Care • Independence • Supervision • Transportation

42. Plan: Continuity of Operations • PIN: EMP should describe how CHCs will continue to provide primary care health services to current and surge patients to the extent possible during an emergency; the EMP should evaluate the CHC’s ability to maintain normal operations and describe the circumstances that must be met for CHC to discontinue non-emergency primary care services or cease operations for a period of time… • JC: EM.02.02.11/EP1-EMP describes how organization will manage activities related to patient care, treatment and services and disruption of services… • AAAHC: n/a • NIMS: n/a

43. COOP • Normal lines of direction and control may be disrupted • Normal operations will be disrupted for a brief time or until reconstitution is completed after the emergency ends • Normal security arrangements will be disrupted and the organization could be vulnerable to additional disruptions until the COOP site is activated and all employees get home or to a safe location • Normal communication links and methods will be disrupted until the COOP site is up and running and reconstitution is complete • A comprehensive COOP capability will minimize those impacts

44. Continuity of Operations Plan (COOP) • There are 9 elements of a viable COOP: • Essential functions • Delegations of authority • Alternate facilities • Interoperable communications • Vital records and databases • Human capital management • Tests, training, and exercises • Devolution • Reconstitution

45. Plan: Safety and Security Measures • PIN: CHC’s EMP should address the following components: security, decontamination and isolation… • JC: EM.02.02.05/EP1/EP5/EP10-EMP will address internal security and safety during emergency; EMP describes radioactive, biological, chemical and decontamination, organization implements EMP, in advance of incident… • AAAHC: n/a • NIMS: n/a

46. Plan: Staff Preparedness • PIN: the plan should also help staff prepare their families for emergencies-if staff are prepared at home, they are more likely to carry out vital responsibilities and duties at work in the health center… • JC: n/a • AAAHC: n/a • NIMS: n/a

47. Personal Preparedness Personal Preparedness • Do you have a family communications plan? • Do you have a go bag? • Do you have a pet go bag? • Have you made arrangements for childcare if you are needed at work? • What about your other family members including elderly and pets?

48. Wrap-Up • Thanks for your time • Please feel free to contact me with questions • Amelia Muccio, amuccio@njpca.org