CMS Finalizing Disaster Reg; Includes Training, Assisting HCWs
HHS stresses need to preserve healthcare workforce
October 1, 2016
By Gary Evans, Senior Staff Writer
As dealing with natural disasters and emerging infections becomes the new normal for hospitals, CMS will soon issue “all-hazards” emergency regulations that include requirements for protecting and accommodating healthcare workers, Hospital Employee Health has learned.
“That rule is not yet final, but we anticipate that it will be coming out within a few months,” says Melissa Harvey, RN, MSPH, director of National Healthcare Preparedness Programs at the Department of Health and Human Services (HHS). “It would require drills and exercises. It would also require engagement with community partners in healthcare coalitions.”
The CMS regulation has been shelved since it was issued as a proposed rule for review and comment in late 2013.1 The rule, which would apply to hospitals, long-term care, ambulatory surgery centers, and many other settings, allows some flexibility in meeting the following four core components of emergency preparedness:
- risk assessment and planning,
- policies and procedures,
- communication, and
- training and testing.
Provisions on healthcare workers include providing basic sustenance, sheltering in place, establishing a communication list of all employees, and training “all new and existing staff, including any individuals providing services under arrangement, and volunteers, consistent with their expected roles, and maintain documentation of such training,” according to the rule. “We propose that the hospital ensure that staff can demonstrate knowledge of emergency procedures, and that the hospital provides this training at least annually.”
Disasters can undermine healthcare delivery while simultaneously increasing the demand for care by a stricken community. “This makes it essential that healthcare providers and suppliers ensure that emergency management is integrated into their daily functions and values,” the CMS states in the proposed rule.
All-hazards planning is defined as emergency preparedness planning for a “full spectrum” of disasters, with the common-sense caveat that hospitals would tailor their planning to the events most likely to occur in their vicinity. Thus, one obviously does not plan for hurricanes in the Midwest, but that still leaves multiple natural hazards from tornadoes to blizzards.
Fire and Rain
Indeed, this young century has already seen an almost biblical succession of flood, fire, hurricanes, tornadoes, terrorism, and bioterrorism — not to mention emerging infectious diseases from SARS to Zika virus. There are many factors involved, but one a broad consensus of scientists agrees on is that global climate change is contributing to more extreme weather events. Meanwhile, rapid global travel and movement of human populations into animal habitats favors the emergence of infectious diseases of zoonotic origin. (For more information, see related story later in this issue.)
The importance of assuring the safety of healthcare workers and their families has been a recurrent theme as emergency events hit communities. Many healthcare facilities are preparing for disasters, but there are competing priorities in healthcare that can undermine efforts in others.
“We think [the CMS regulation] will be helpful, but there have been for many years now — even if it hasn’t been a regulatory requirement — accreditation requirements for education and drills,” Harvey says. “But healthcare executives may have to decide are they going to pay their staff overtime to exercise and drill or purchase a critical piece of equipment that was needed for patient care yesterday. Those are some tough priorities and choices to make. I think [healthcare] staff certainly see the need to train and drill, especially after reading in the newspaper about other facilities dealing with emergencies, but it is tough in the current fiscal environment.”
That said, planning and foresight may translate to prevention of substantial expenditures and interruption of healthcare delivery during an emergency event. To highlight this aspect, the HHS issued an emergency planning guidance document2 on Aug. 18, 2016, that includes examples of healthcare systems responding creatively and heroically in the face of disaster. The HHS guidance document is designed for healthcare facilities and other community institutions, like schools, that are still operational after an emergency event. In the aftermath, people throughout the community may be reeling from injuries, loss of loved ones, and the need for shelter and food.
“Healthcare providers and staff who maintain facility operations are no exception, and yet they are a critical component of the response phase and expected to care not only for their own loved ones, but community members and the facility, too,” the HHS guidance states. “Leadership plays a vital role in ensuring staff feel cared for and safe. Remind your team that their jobs are important and secure. Provide regular and clear communication regarding how leadership is working to continue and restore operations.”
Immediate needs for healthcare workers may include care for their families, transportation, counseling, and funding. Failing to adequately prepare and accommodate healthcare workers could undermine patient safety and even lead to temporary closures.
“Having worked in this field for many for many years and having visited a lot communities after emergencies, there are two things we have found,” Harvey says. “One is some really excellent examples [of emergency response]. The other is the exact flip side where executives of healthcare facilities have come to us and said, ‘We could stay open right now, but we don’t have enough staff.’ This is largely because, in an emergency, healthcare staff are very concerned about what is happening at home. And I think all of us would feel that way.”
To address this issue, the HHS recommends options like setting up onsite care for children and elderly family members of healthcare workers.
“No employer should ever forget the loved ones of those who are aiding most in worksite recoveries,” says Cathy Floyd, MS, BSN, RN, DPA, COHN-S, regional manager of occupational health at Memorial Hermann Health System in Houston.
Employee health professionals should know their role in the emergency response plan and communicate it to their colleagues, she says.
“Make sure employees know what employee health will and will not provide in an emergency,” she says. “Think about ‘what if’ scenarios, like ‘what if public disaster services can’t get to us for 24 to 48 hours?’ Be prepared — don’t be part of the problem.”
Floyd cites the following key points as some of the critical issues for employee health, particularly for those new to the field:
- Take ownership of your employee health role in worksite emergency preparations. Public health and community agencies may initially be overwhelmed. Partner with your employer’s disaster preparedness team and external public agencies.
- Know your responsibilities for worksite employee health before disasters occur. If necessary, conduct a needs assessment to determine what is needed in a disaster. Maintain supplies specifically for responding to post-disaster employee health issues. Human resources can identify mental health benefits to help with specific or anticipated problems.
- Know your worksite’s weaknesses and vulnerabilities and participate in all disaster drills. Prepare post-drill debriefings and identify what worked and what didn’t to improve your program.
Forward Thinking
While employees are more likely to report for work if their immediate needs are met, employers can also raise morale and motivate their workforce by assisting healthcare workers.
“The Meridian Health System in New Jersey — near the Jersey Shore area that was affected during Hurricane Sandy — did some really wonderful things, such as giving out gift cards to their staff to Home Depot [and other stores] so they could take care of their very immediate [housing] needs,” Harvey says. “We certainly know other examples where healthcare facilities have kept tarps and sandbags on hand — not for the facility itself, but to give to their staff to shore up their houses either before or after an emergency.”
For those who must evacuate their homes, make sure employees have a list of local shelters. “After Hurricane Sandy, one health system comprised of 16 hospitals placed 62 employees’ families into temporary housing,” HHS notes. In addition to setting up flexible scheduling, HHS recommends appointing a “concierge” employee who could meet with groups of healthcare workers and determine who needs what. One issue that has come up time again is a marked concern for stranded pets.
“Recent experience has shown that survivors may be reluctant to evacuate their homes because they do not want to leave their pets behind,” the HHS emergency guidance states. “Employees may volunteer to ‘foster’ their colleagues’ pets in the short term or make sure the pets have been let out and have an adequate supply of food and water. If practical, identify nearby shelters that accept pets and share this information with your team.”
Understandably, even staff willing to work may have a hard time getting to the facility following floods or other disasters.
“Consider partnering with churches or schools to use buses and drivers to transport employees to and from work,” HHS recommends. “In South Carolina, fire personnel used boats to transport staff through floodwaters to the hospital. Consider setting up a regular shuttle service or volunteer carpool service. After storms, gas can be in short supply. Facilities in Florida have had a tanker come to the hospital, allowing staff to fill their tanks.”
Such concerns may seem mundane for employees who have suffered a deep personal loss, so plans should include having behavioral health professionals ready to counsel and assist the emotionally traumatized. As part of this, staff may need to gather and process the experience, grieve, and share experiences. This could continue in the disaster recovery phase if workers want to meet and discuss continuing challenges they are facing.
“Planning is different by facility, but every healthcare plan should involve some sort of staff ‘resilience’ aspect,” Harvey says. “They need to [address] resilience among their staff, which [could include] encouraging them to create a plan for their family and have emergency supplies in their home.”
The bottom line that is that healthcare facilities that fail to address employee health needs in the wake of a disaster may take longer to get back up to speed, and may find that healthcare workers are less inclined to work there even when the recovery is complete.
“Ultimately, we know that those facilities that take care of their staff very well after an emergency have an easier time retaining their staff and that leads to a much more efficient recovery for healthcare facility,” she says. “Given that healthcare is a competitive market, there is a need for healthcare executives to think about how to retain their staff and keep the knowledge base they have built up within their system.”
REFERENCE
- CMS. Proposed rule: Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. Fed Reg Dec. 27, 2013: 79081-79200. http://bit.ly/1dtMEmx
- U.S. Department of Health and Human Services. Tips for Retaining and Caring for Staff after a Disaster. August 18, 2016. https://asprtracie.hhs.gov/.
As dealing with natural disasters and emerging infections becomes the new normal for hospitals, CMS will soon issue “all-hazards” emergency regulations that include requirements for protecting and accommodating healthcare workers, Hospital Employee Health has learned.
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