New Emergency Management Standards Will Require Plan Modification

Accreditation Monthly, August 22, 2007

The Joint Commission has finally unveiled the changes to the Emergency Management standards. The changes represent a much clearer picture of what might be considered best practices for the structure of your emergency operations plan (what used to be your disaster or emergency response plan).

In this post-9/11 world, the hierarchy of regulatory oversight continues to have the requirements of the federal government at its apex. If your organization has any hopes of funding additional improvements to your preparedness activities, adoption of a response structure that is compliant with the National Incident Management System must be your primary goal. Fortunately, the six "critical areas" identified in EC.4.13-EC.4.18 (communications, resources and assets, safety and security, staff responsibilities, utilities management, and patient clinical and support activities), are readily "folded" in to any of the NIMS-compliant structures, such as the Hospital Incident Command System model.

There's little in the way of surprises in the new standards. When the Joint Commission updated the Elements of Performance under EC.4.20 (the standard requiring the conduction of disaster drills), several of the "critical areas" were identified succinctly (communications, resource mobilization, and patient care activities), with the remaining newbies primarily the result of post-Katrina review of hospital response in New Orleans and the rest of the Gulf Coast. The expectation of the Joint Commission is that if your organization is able to get and keep its act together relative to those six areas, then your organization should be able to manage events of every stripe and magnitude.

The important consideration (derived from the Gulf Coast experience) is to know when your organization can no longer safely sustain patient care and must take steps to cease operations, either partially or completely. This may involve relocation of your operations, the migration of your patients to another facility, or even a mix of the two. Every circumstance has a tipping point, and the new defining preparedness characteristic for hospitals is a level of self-awareness that can recognize and act upon that point. I think that there was a tacit understanding in the past that, on the part of everyone involved (hospitals, regulators, and communities), hospitals would not close, or more to the point, could not close. We need to look no further than the legal imbroglios regarding the disposition of patients in the aftermath of Katrina to see that, as an industry, a critical part of our continuity plans is to know when continuation is not possible and could be considered dangerous. With luck, we will never have to face such circumstances again, but I don't think the odds are in our favor.

While the standards changes do not take effect until January 1, 2008, I think we can anticipate a fair amount of learning on the part of the surveyors as we approach the full implementation date. Minimally, organizations should expect surveyors to ask questions about their compliance efforts in this regard. Be prepared to talk about how your drill-planning activities take into account escalating events (up to and including the suspension of support from your community), loss of utilities, reduced manpower, etc. While there is no clear indication of how these changes will be surveyed in 2008, it is likely that the basis of those surveys will be formed in the last quarter of 2007.

So, if you feel like an independent assessment of your program is in order, either as a function of a focused review of your Environment of Care program, or indeed as a specific focus, The Greeley Company stands ready and able to assist you in your compliance efforts. Our Environment of Care expert, Steve MacArthur, brings a wealth of experience in all aspects of survey readiness-and he's just a phone call away!

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