Nursing Home Disaster Preparedness is essential to the safety of residents and staff. The Department of Health and Human Services (DHSS) Office of Inspector General has identified gaps in preparedness. This article outlines the findings from their report “Gaps Continue to Exist in Nursing Home Emergency Preparedness and Response During Disaster."
Federal regulations require that Medicare- and Medicaid-certified nursing homes have written emergency plans and provide employees with emergency preparedness training. In a 2006 report DHSS found that emergency plans lacked many provisions recommended by experts. In that report, 94 percent of nursing homes met Federal regulations for emergency plans and 80 percent met Federal regulations for emergency training in 2004–2005. However, in a sample of 20 nursing homes, plans often lacked information suggested by experts; nursing home administrators and staff sometimes did not follow emergency plans during the hurricanes; and lack of collaboration between State and local emergency entities and nursing homes impeded emergency preparedness and management. Obviously resident safety is a key part of MDS.
In response, the Centers for Medicare & Medicaid Services (CMS) issued guidance checklists for emergency planning of health care facilities, long-term care (LTC) ombudsman programs, and State survey agencies (SA). This latest report analyzed national survey data to determine compliance with Federal regulations. It was supplemented with site visits to 24 selected nursing homes that disasters in 2007–2010.
What They Found
Most nursing homes met Federal requirements for written emergency plans and preparedness training. Many gaps from the 2006 report still existed.
- Emergency plans lacked relevant information—including only about half of the tasks on the CMS checklist. Of concern were staffing; resident care; resident identification, information, and tracking; sheltering in place; evacuation; and communication and collaboration.
- Nursing homes faced challenges with unreliable transportation contracts, lack of collaboration with local emergency management, and residents who developed health problems.
- LTC ombudsmen were often unable to support nursing home residents during disasters.
- SAs reported making some efforts to assist nursing homes during disasters.
DHSS made three recommendations to CMS and one recommendation to the Administration on Aging (AoA). They are as follows:
- CMS revise Federal regulations by identifying and including in its regulations requirements for specific elements of emergency plans and training. CMS should specify minimum Federal standards for the frequency and extent of disaster response training, exercises, and drills.
- CMS update the Standards Operations Manual (SOM) to provide detailed guidance for surveyors assessing compliance with Federal regulations for nursing home emergency planning and training. The SOM provides no procedural guidance for how surveyors are to assess plans. CMS should develop detailed and clear guidance for use during surveys.
- CMS promote use of the emergency preparedness checklists for nursing homes, State LTC ombudsman programs, and SAs.
- AoA develop model policies and procedures to protect resident health, safety, welfare, and rights during and after disasters. AoA should collaborate with other programs to identify effective models for State and local LTC ombudsman programs during disasters and assist States in their development of policies and procedures.
CMS agreed with recommendations to revise Federal regulations and AoA agreed with the recommendation to develop model policies and procedures for LTC ombudsmen to protect residents during and after disasters.
The Omnibus Budget Reconciliation Act of 1987 established a survey and certification process for CMS and States to verify that Medicare- and Medicaid-certified nursing homes comply with Federal requirements. CMS is responsible for enforcing these requirements. It enters into agreements with SAs to survey each nursing home at least once every 15 months to certify compliance with Federal requirements.
Emergency plans must include procedures to meet all potential emergencies, such as fires, severe weather, and missing residents. If surveyors find that emergency plans are deficient, they can cite nursing homes with a deficiency of Tag F517.
SAs are also responsible for Life Safety Code (LSC) surveys. Surveyors must complete additional specialized training to conduct the LSC survey, and special consultants, such as fire protection engineers or fire alarm technicians, may participate on the survey team.
CMS Emergency Preparedness Checklists
In 2007, CMS published three emergency preparedness checklists as “recommended tools”:
- Health care facilities checklist.
This checklist includes 70 tasks and provides guidance for developing emergency plans; ensuring adequate supplies of food and water; identifying evacuation routes; and transporting patients, critical supplies, and equipment.
- State LTC ombudsman program checklist.
This is a resource for State LTC ombudsmen and includes such tasks as ensuring that all regional and local ombudsmen are familiar with emergency planning pertinent to LTC facilities.
- State SA checklist.
This checklist encourages collaboration between SAs and emergency management agencies and provides guidance on the essential functions of SAs during disasters.