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The OIG Report is In – Your Facility May Not Be Properly Prepared for an Emergency

The Department of Health and Human Services Office of the Inspector General issued an alarming report on nursing homes and disaster preparedness on Monday, April 12, 2012. The report, “Gaps continue to exist in nursing home emergency preparedness and response during disasters: 2007-2010” points out, among other issues, that there has been a decrease in compliance rates for nursing homes meeting Federal regulations for emergency planning and emergency training. This means there will most likely be an increase in the emphasis placed on training surveyors to better review your emergency plan and training procedures.

This report provided recommendations to CMS and the AoA, including that CMS should revise Federal regulations to include “specific elements of emergency plans and training,” that the SOM should be updated to “provide detailed guidance for surveyors” regarding planning and training for emergencies, and that CMS should work to promote the use of its emergency preparedness checklists. It was also recommended that the AoA should collaborate with other agencies to identify models for ombudsmen that will work during emergencies.

The increased regulatory attention and media attention that the problem with disaster preparedness will continue to bring means that your facility needs to take a strong look at its emergency plan, ensuring that any gaps are identified and all potential disaster types are detailed (fire, weather, missing residents). Take the time to review the plan with your staff to ensure they are familiar with the procedure and conduct drills routinely.

The OIG report can be found here.

Let’s look at some next steps for your facility to help ensure you are meeting Federal standards. Let us know what else your facility is doing to help prepare for an emergency by commenting below.

A summary of findings from this report show that nursing homes need to be doing a far better job of planning for a worst-case scenario:

  • In 2004 and 2005, 94% of nursing homes met Federal regulations for emergency planning. 80% met emergency training regulations. Instead of seeing this number trend upward after Hurricane Katrina and other natural disasters, this report found that compliance numbers had dropped slightly in 2009 and 2010, to 92% and 72% respectively.
    • Next steps for your facility:
      • Review your emergency plan and provide staff training to ensure everyone is familiar with the plan. As mentioned, surveyors will be trained more stringently to review these plans, so there may be more citations with F517 and 518.
      • Create and maintain a Safety Committee that can also serve as the Emergency Management Committee.
      • Ensure that your Emergency Management Plan is reviewed during staff orientation and at least on an annual basis.
  • 6 areas of concern that were lacking in emergency plans include: Staffing, Resident Care, Resident Identification, Information & Tracking, Sheltering in place, Evacuation and Communication & Collaboration.
    • Next steps for your facility:
      • The nursing homes that had been through an emergency situation reported “substantial challenges” responding to the issues, including transportation and communication issues, resident health deterioration and other difficulties following the emergency plans as documented. When you are reviewing and revising your emergency plan, ensure you take into account all possible types of disaster and document for them, including missing residents, severe weather and fire.
      • Develop and maintain a local agreement/Mutual Aid Plan with other health care providers.
      • Review your transportation contracts and your agreements with host facilities to ensure all parties are on the same page.
      • Ensure your staff is trained on procedures for proactively addressing resident needs ahead of any evacuation/relocation to ensure they receive proper care at the new temporary location.
      • Maintain a list of critical “in-house” supplies with indicators when supplies are running low (72 hours/3 days is a minimum goal).  Make sure that you have a plan for back-up suppliers with phone and fax numbers.
  • Most selected nursing home administrators did not take advantage of the CMS emergency preparedness checklist, and when they did, less than half of the recommended tasks were included.
    • Next steps for your facility:
      • These tasks are not mandatory, but we believe greater emphasis will be put on them going forward as a result of these findings. As you know, CMS has developed a handful of useful tools that more focus will be placed on going forward. These checklists are a good reference point for your plan, and should not be used sparingly. More information can be found on the CMS website.
  • The majority of these nursing homes also noted that they had not worked with local emergency management agencies to proactively plan for disasters. Interviews with the emergency agencies noted that many were not even aware that a documented plan for the facility existed, and that in the great majority of situations, the plan had not been reviewed by the agency. None of the nursing homes interviewed had participated in community-organized drills or exercises.
    • Next steps for your facility:
      • The first step is clear – it’s time that you met with your local emergency management agencies and figure out who is responsible for reviewing your emergency plan and who will be responding in the event of a disaster. These two sets of people may not be the same, so make sure everyone is on the same page.
      • Arrange for internal disaster drill/s or, if possible, plan and hold a disaster drill that includes participation with local emergency management agencies.
  • 50% of the nursing homes used in the sample for the OIG report did not have procedures in place for finding missing residents.
    • Next steps for your facility:
      • Make sure you have developed a plan that includes placing consistent identifying information on each resident if there is intent to transfer, and ensure that the information will be protected (lamination, water-proof pouches).
      • Ensure you have the ability to track evacuated residents, especially if multiple locations may be used.