Emergency Preparedness

​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​AHCA/NCAL provides information and resources to help members respond to an emergency in a timely, organized, and effective manner. ​​​


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What You Need to Know​​​ ​

Monkeypox
In August 2022, the United States declared the ongoing monkeypox outbreak a public health emergency. Learn more about the disease and the warning​ signs you need to watch out for in LTC.​  

COVID-19 Updates​
​​Find the latest information on COVID-19 for long term care providers. This includes infection control practices, regulatory requirements and resources on COVID-19 vaccinations for long term care staff and residents. 

To meet Emergency Preparedness requirements, providers must be able to demonstrate their experience activating their emergency plans through written documentation. This is most commonly accomplished through ​an After-Action Report (AAR) and Improvement Plan. AHCA has developed a COVID-19 AAR Template that members can utilize to document their response and recovery efforts during the pandemic. 
Long term care facilities should prepare to manage potential flu outbreaks and double efforts to encourage residents and staff to take the influenza vaccine. Individuals 65 years or older are one of the high risk groups who can experience serious complications, even death, from influenza infection. Learn more on how to minimize the flu for residents.​ ​
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Active Shooter Preparedness​
HealthCap® offers a free webinar that focuses on key aspects of active shooter events and what to do if your long term care community experiences a threat or real-life active shooter.

 

 

 

Why Sprinklers Keep Leading to Survey Tagshttps://www.ahcancal.org/News-and-Communications/Blog/Pages/Why-Sprinklers-Keep-Leading-to-Survey-Tags.aspxWhy Sprinklers Keep Leading to Survey Tags2/6/2024 5:00:00 AM​Since August 2013, CMS has required all regulated nursing homes to be fully sprinklered.  This has resulted in a decline in serious healthcare facility fires, along with the injuries and fatalities that can be associated with them.  However, the increase in sprinkler systems has accompanied an increase in life safety deficiencies.  CMS K-tags related to sprinkler system design, components, inspection, testing, and maintenance are consistently in the top five K-tag findings list nationally.  <br><br>There are two (2) commonly cited K-tags that address sprinkler systems.  K351 addresses sprinkler system installation and K353 addresses sprinkler system maintenance.  <br><br>Common survey findings related to sprinkler system installation (K351) include:<br><ul><li>Obstructions (18" rule) – Items are not permitted to be stored within 18" of sprinkler heads.  This is a common problem in areas such as commissaries and storage rooms.  Placing items too close to a sprinkler head could impede the spray pattern from the head.  However, the requirement does not limit the ability to have shelving and storage around the perimeter of a room that extends to the ceiling assuming there are no sprinkler heads directly above the storage or shelf.  </li><li>Piping – Wire, conduit, cables, and similar items are not permitted to be attached to, supported from, or even laid across sprinkler piping.  This is a common issue above the ceiling.  </li><li>Overhangs / Awnings – Any overhang or awning considered combustible and spanning more than four (4) feet from the side of the building is required to have sprinkler protection provided to the space below.  This can include porticos, porte-cochères, and entry/exit awnings and overhangs.  There are special designs and specialty sprinklers that can be utilized to protect these unique areas.               </li></ul>Common survey findings related to sprinkler inspection, testing, and maintenance (K353) include:<br><ul><li>Testing, Inspection, and Maintenance – NFPA 25 outlines very prescriptive inspection, testing, and maintenance (ITM) requirements for sprinkler systems.  Survey findings often relate to incomplete documentation, missing ITM components, or lack of remediation when the vendor identifies an issue.  Make sure your vendors are using the 2011 edition of NFPA 25, providing comprehensive documentation, and clearly notifying you if there is a problem requiring attention.  </li></ul><ul><li>Sprinkler Head Testing or Replacement – NFPA 25 also dictates when sprinkler heads must either be tested or replaced.  The interval depends on the type of sprinkler head.  Standard response sprinklers require testing at the 50-year mark and then again every 10 years thereafter.  Fast response sprinklers, including quick response heads that are commonly found in healthcare facilities, require testing 25 years after installation and then again every 10 years thereafter.  Rather than send out a grouping of sprinkler heads to be tested, you can also replace them at the first or subsequent testing mark.  This will reset the clock for future testing requirements.  Your sprinkler vendor should be knowledgeable in determining the age of your sprinkler heads, when they require testing/replacement, and what labs can provide the testing service.  </li><li><span style="font-size:11pt;">Painted / Dirty Sprinkler Heads – Sprinklers may not operate as intended if they are dirty, grease laden, or painted.  Usually, a simple cleaning or dusting does the trick.  However, if paint or grease won't remove easily, the heads may need to be replaced. </span></li></ul><div><span style="font-size:11pt;">Sprinklers are proven to save property and lives.  Ensuring they are installed and maintained appropriately will keep you in compliance and keep your system in a state of readiness should a fire occur. </span><br></div><div><br><span style="font-size:11pt;"></span><div>Detailed sprinkler system requirements can be accessed via the National Fire Protection Association's (NFPA) website at <a href="http://www.nfpa.org/" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">www.nfp​a.org</a>.  The <a href="/Survey-Regulatory-Legal/Pages/Fire-Life-Safety.aspx" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">AHCA/NCAL website</a> is also a great resource for on-going life safety education, tools and resources.  <br><br></div></div>
Navigating “Safety” in Long Term Care Centers: Separating the Roles of OSHA and the CMS requirements for Emergency Preparednesshttps://www.ahcancal.org/News-and-Communications/Blog/Pages/Navigating-Safety-in-Long-Term-Care-Centers-Separating-the-Roles-of-OSHA-and-the-CMS-requirements-for-Emergency-Preparedn.aspxNavigating “Safety” in Long Term Care Centers: Separating the Roles of OSHA and the CMS requirements for Emergency Preparedness2/6/2024 5:00:00 AM<p><strong style="font-size:11pt;">​Continuation: </strong><br></p><div><span style="font-size:11pt;">In this third article regarding the connection between the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare & Medicaid Services (CMS) Life Safety and Emergency Preparedness (EP) Requirements, the focus will be on how OSHA’s regulations overlap with CMS’ EP requirements, found in 42 CFR 483.73 (Appendix Z).  </span><br></div><div> </div><div>It’s important to note that CMS’ EP requirements <strong>do NOT</strong> apply to assisted living, however any OSHA requirements do apply. </div><div> </div><div><strong>Emergency Preparedness-Overview:</strong> </div><div><br></div><div><ul><li><strong>Emergency Preparedness:</strong> CMS established specific requirements for emergency preparedness in nursing communities that became effective in 2017. The CMS rule, commonly known as the Emergency Preparedness Rule, applies to various health care providers, including nursing communities. Emergency preparedness is typically surveyed by the state survey agency in conjunction with the Life Safety Code survey.  <br><br>Key components of the CMS Emergency Preparedness Rule for nursing communities <span style="font-size:11pt;">include, but are not limited to: </span></li><p><span style="font-size:11pt;">​<br></span></p></ul><ol><ol><li><span style="font-size:11pt;">​​​</span><span style="font-size:11pt;">​</span><span style="font-size:11pt;"><span style="text-decoration:underline;">Emergency Plan</span>: Providers are required to develop and maintain an emergency plan that addresses potential emergencies specific to their geographic location. This plan should include strategies for addressing both natural and man-made disasters. </span></li><li><span style="font-size:11pt;"><span style="text-decoration:underline;">Policies and Procedures</span>: Nursing homes must have policies and procedures in place to implement the emergency plan. These should cover various aspects, including communication, patient tracking, and coordination with local emergency management agencies. </span><br></li><li><span style="font-size:11pt;"><span style="text-decoration:underline;">Communication Plan</span>: Nursing homes are required to establish a communication plan that ensures timely and effective communication during emergencies. This includes communication with staff, residents, families, and external entities. </span><br></li><li><span style="font-size:11pt;"><span style="text-decoration:underline;">Training and Testing</span>: Nursing home providers must conduct regular training for staff to ensure they are familiar with emergency procedures. Additionally, they are required to conduct regular testing and drills to assess the effectiveness of their emergency plans. </span><br></li><li><span style="font-size:11pt;"><span style="text-decoration:underline;">Integrated Healthcare Systems</span>: Nursing home communities are encouraged to coordinate their emergency plans with other health care providers and community resources to ensure a seamless response to emergencies. </span></li></ol></ol><ul><li><strong>OSHA:</strong> OSHA does not have regulations or standards that specifically address emergency preparedness in long term care communities, including assisted living. However, OSHA does have general requirements that may indirectly relate to emergency preparedness and employee safety during emergencies, such as emergency evacuation procedures, personal protective equipment, infection control and respiratory protection.  </li></ul></div><div><br></div><div><strong>Emergency Preparedness - Compare and Contrast of Key Compliance Items: </strong></div><div><br></div><div><ol><li><strong>Emergency Evacuation Plans:</strong> <br><br></li><ol><ul><li><span style="font-size:11pt;">​</span><span style="font-size:11pt;">​</span><strong>Emergency Preparedness</strong>: CMS mandates the development and implementation of comprehensive emergency evacuation plans that consider various potential emergencies, including fires and natural disasters. These plans outline procedures for the safe and orderly evacuation of residents, including the identification of evacuation routes and the assignment of responsibilities to staff members. <br><br></li><li><span style="font-size:11pt;"><strong>OSHA</strong>: OSHA's Emergency Action Plan standard <a href="https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.38" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">1910.38 - Emergency action plans. | Occupational Safety and Health Administration (osha.gov) </a>requires employers to develop and implement emergency action plans. These plans must include procedures for the evacuation of employees and, where applicable, residents during emergencies. <br></span><br></li></ul></ol><li><span style="font-size:11pt;"><strong>Communication Systems: <br></strong></span><br></li><ol><ul><li><span style="font-size:11pt;">​​</span><strong>Emergency Preparedness</strong>: CMS emphasizes the importance of effective communication during emergencies. Communities are required to have communication systems in place to relay information to staff, residents, and, if necessary, external emergency response entities. This includes methods for notifying individuals about emergencies and providing clear instructions. <br><br></li><li><span style="font-size:11pt;"><strong>OSHA</strong>: OSHA regulations also highlight the importance of communication during emergencies (29 CFR 1910.38). Emergency action plans must include procedures for reporting emergencies, including a method for employees to report emergencies or other dangerous situations. <br></span><br></li></ul></ol><li><span style="font-size:11pt;"><strong>Training and Drills: <br></strong></span><br></li><ol><ul><li><span style="font-size:11pt;">​​</span><strong>Emergency Preparedness</strong>: CMS has specific requirements for training and drills to ensure that staff and residents are familiar with emergency procedures. This includes conducting evacuation drills, training on the use of emergency equipment, and educating individuals on their roles and responsibilities during emergencies. <br><br></li><li><span style="font-size:11pt;"><strong>OSHA</strong>: OSHA's Emergency Action Plan standard emphasizes the need for employee training (29 CFR 1910.38). Employers, including long-term care centers, must ensure employees are familiar with the emergency action plan, including evacuation procedures, and conduct regular drills to evaluate its effectiveness. </span><br></li></ul></ol></ol></div><div><br></div><div><span style="font-size:11pt;"><strong>Differences and Synergies: </strong></span></div><div><br></div><div>The CMS rules and OSHA regulations overlap on certain aspects of emergency preparedness, yet each has distinct focuses. Both emphasize the importance of comprehensive emergency preparedness in health care settings, including long term care centers.  </div><div> </div><div>CMS rules, particularly the Emergency Preparedness Rule, require providers to develop and implement plans addressing various emergencies. This encompasses evacuation procedures, communication plans, and coordination with external entities.  </div><div> </div><div>OSHA, while not having specific regulations dedicated to health care emergency preparedness, mandates general emergency action plans for workplaces, emphasizing evacuation procedures and employee training.  </div><div> </div><div><strong>Conclusion: </strong></div><div> </div><div>The CMS rules specifically address the safety and needs of health care recipients and their caregivers, ensuring continuity of care during emergencies, while OSHA's focus encompasses the safety of employees. Aligning with both sets of regulations ensures a universal approach to emergency preparedness, safeguarding the well-being of both health care recipients and staff in health care settings. </div><div> <br></div><p>​</p>In this third article regarding the connection between OSHA and CMS Life Safety and EP Requirements, the focus will be on how OSHA’s regulations overlap with CMS’ EP requirements, found in 42 CFR 483.73 (Appendix Z).
Tools and Trainings for Life Safety Code® Compliancehttps://www.ahcancal.org/News-and-Communications/Blog/Pages/Tools-and-Trainings-for-Life-Safety-Code-Compliance.aspxTools and Trainings for Life Safety Code® Compliance1/23/2024 5:00:00 AMThe Life Safety Code® is a complex document, and managing life safety compliance can be a complicated task for any provider. An effective compliance program requires personnel with specialized knowledge in numerous life safety concepts and components. Requirements around egress, fire alarm systems, fire sprinkler systems, smoke barrier wall assemblies, and fire doors are just a few of the many survey focus points. The challenges resulting from staff turnover can compound the difficulty of maintaining compliance and survey readiness. Fortunately, several resources are available to assist providers in obtaining the necessary knowledge to properly apply the Life Safety Code® and be survey ready.<br><br><div>AHCA has developed two webinars focused on life safety, free for members. The first is an <a href="https://educate.ahcancal.org/products/survey-preparation-for-the-new-facilities-manager" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">introd​uction for new Facility Directors</a> while the <a href="https://educate.ahcancal.org/products/life-safety-and-emergency-preparedness-compliance" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">second provides tips for navigating some of the most frequently cited life safety tags</a>.</div><div><br></div><div></div><div>CMS has developed a <a href="https://qsep.cms.gov/pubs/CourseMenu.aspx?cid=0CMSLSCPR_WBT" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">Life Safety Code® orientation program</a>. While it was developed as a surveyor training tool, it is available to anyone free of charge.  It is a self-paced program with six modules that includes approximately four hours of education:<br><br>The National Fire Protection Association (NFPA) offers a menu of healthcare specific on-line training programs.  There are modules focused on The Life Safety Code®, The Health Care Facilities Code®, and Fire Door Inspections. <a href="https://www.nfpa.org/for-professionals/training-for-me/health-care-training/nfpa-101-for-health-care-online-training-series" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">These programs are available for a fee</a>.<br><br>Finally, don't forget to continually monitor the <a href="/Survey-Regulatory-Legal/Pages/Fire-Life-Safety.aspx" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">AHCA life safety web page</a> for additional compliance resources and tools.  <br></div>
Flu or COVID-19 - Which is Worse?https://www.ahcancal.org/News-and-Communications/Blog/Pages/Flu-or-COVID-19---Which-is-Worse.aspxFlu or COVID-19 - Which is Worse?1/5/2024 5:00:00 AMA common misperception that exists is that COVID-19 is no longer a serious virus, and some may even believe that it's less serious than influenza. While the rates of serious illness, hospitalizations, and death from COVID-19 are significantly lower than during the height of the pandemic in early 2020 and 2021, recent data indicates that COVID-19 remains more serious than influenza. <br><br>Key Highlights:<br><ul><li>Seniors who contract COVID-19 are much more likely to experience serious illness, hospitalizations, or death. </li><li>The rates of hospitalizations for individuals over the age of 65 is nearly 10x greater than those with influenza (<a href="https://www.cdc.gov/surveillance/resp-net/dashboard.html" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">see figure 1</a>). </li><li>Among individuals over 65 they are 3-4x more likely to die from COVID-19 compared to influenza (<a href="https://gis.cdc.gov/grasp/fluview/mortality.html" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank">see figure 2</a>).<br></li></ul><div><br></div>Figure 1. Rate of hospitalizations for individuals over 65 with COVID-19, Influenza and RSV.  <br><img src="/News-and-Communications/Blog/PublishingImages/Pages/Flu-or-COVID-19---Which-is-Worse/Figure%201%20Rate%20of%20hospitializations.png" alt="Figure 1 Rate of hospitializations.png" style="margin:5px;" /><br><span class="ms-rteFontSize-1">Source: CDC Respiratory Virus Hospitalization Surveillance Network RESP NET) accessed 1-4-24</span><br><br>Figure 2. Percentage of individuals hospitalized with COVID-19 or Influenza who die by age group. <br><img src="/News-and-Communications/Blog/PublishingImages/Pages/Flu-or-COVID-19---Which-is-Worse/Figure%202%20Percentage%20of%20hospitalizations.png" alt="Figure 2 Percentage of hospitalizations.png" style="margin:5px;" /><img src="file:///C:/Users/atodd/AppData/Local/Temp/msohtmlclip1/01/clip_image004.png" alt="" style="width:1px;" /><br><span class="ms-rteFontSize-1">Source: CDC Pneumonia and Influenza Mortality Surveillance from the National Center for Health Statistics Mortality Surveillance System (FluView interactive) accessed 1-4-24</span> <br><br>Because the vaccine reduces the risk of serious illness, hospitalization and death, this information can be helpful during discussions with residents and their representatives who have reluctance about getting vaccinated, particularly for those who are hesitant to receive the COVID-19 vaccine but got the influenza vaccine. <br><br>Download other <a href="/Quality/Documents/GetVaccinated/Talking%20Points%20.docx" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank"><strong>talking points</strong></a> and <a href="/Quality/Pages/GetVaccinated.aspx?utm_source=ahcancal_homepage&utm_medium=main_rotator&utm_campaign=getvaccinated" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank"><strong>template letters</strong></a><strong> </strong>to use with long term care residents and staff to help encourage they get vaccinated.  <div><br></div><div>Explore other resources in AHCA/NCAL's #GetVaccinated toolkit at <a href="https://getvaccinated.us/" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank"><strong>getvaccinated.us/</strong></a>.​<br><br></div>

 Featured Video

 Top Resources

 Planning Ahead

​In order to effectively handle disasters and emergencies, it is important for centers to plan ahead and prepare in advance. Long term and post-acute care centers can use a targeted approach to addressing vulnerabilities and hazards to help them best respond to and recover from events. This site seeks to assist centers in creating a plan to address its greatest risks:
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Hazard Vulnerability Assessment
The Hazard Vulnerability Assessment (HVA) is a tool designed to assist centers in evaluating vulnerability to specific hazards. The tool uses various categories, such as probability of experiencing a hazard, human impact, property and business impact and response, to create a numeric value based on various hazards.

 Incident Command System

The Incident Command System is part of the emergency management system in many levels (federal, state, and local). Every significant incident or event, whether large or small, and whether it is even defined as an emergency, requires certain management functions to be performed.

The Nursing Home Incident Command System (NHICS) and Assisted Living Incident Command System (ALICS) outline a management framework that empowers long-term care staff to improve the effectiveness and efficiency of their incident response -- no matter what shift, or what day of the week the event occurs. ​​

Resources


 

 ‭(Hidden)‬ CMS Emergency Preparedness Rule

The Emergency Preparedness Final Rule was released on Friday, September 16, 2016. AHCA, along with guest speakers, will hold a webinar series event​ this year on the new emergency preparedness final rule impacting Skilled Nursing Facilities (SNF), Nursing Facilities (NF) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID). This final rule is not applicable to Assisted Living Providers. 

Providers will need to be in compliance by November 15th 2017. The webinar series will include, special guest speakers, an overview of the key new requirements, a list of tools to assess if you are prepared for the rule, steps to take now to prepare.

On Friday, September 1st, CMS released a memorand​um to State Survey Agency Directors announcing that the Emergency Preparedness Training is now available. All surveyors are required to take the training prior to surveying the Emergency Preparedness requirements. Surveying for requirements begins November 15th, 2017. 

The online course is now available on the Surveyor Training Website On-Demand. Once in the course catalog for provider training, search “emergency” and the course information will appear. Providers will have continued (ongoing) access to the course, so they can review it anytime.

Members are strongly encouraged to review and complete the training as it includes quizzes and exercises to check understanding. The training states to surveyors that the requirements do not prescribe or mandate specific technology or tools nor detailed requirements for how facilities should write emergency plans. The training includes the questions surveyors will ask and how documentation will be reviewed and checked. Links to resources and glossary terms are also included.​

​Emergency Resources

In addition to planning for natural disasters, staff and facilities must be prepared for other emergencies, such as pandemics, influenza, active shooters and more. All emergency situations must be handled swiftly, diligently and with the utmost care for staff and patients.

 Active Shooter

​While many emergencies are caused by natural disasters and are, staff and facilities should also be prepared for other types of emergencies. One emergency for which facilities should have plans in place is an active shooter.
Please note: The policies below are models only and should be modified and tailored to meet the needs of individual communities. 

 
AHCA/NCAL's Active Shooter Resources
External Resources

 Assisted Living Resources

The Emergency Preparedness Guide for Assisted Living is a comprehensive resource that will assist members with developing emergency operations plan and includes the planning process. The guide includes templates and numerous resources for members to utilize.

 

Assisted Living Incident Command System (ALICS)

The Incident Command System (ICS) is one component of the National Incident Management System or (NIMS). The Assisted Living Incident Command System or “ALICS” is a simplified ICS and through its use, long-term care providers can become part of this standardized system of efficient response. ICS was modified by two consultants for assisted living and reviewed by AALNA board members and then reviewed by the NCAL Workgroup of the AHCA/NCAL Emergency Preparedness Committee.

ALICS offers long-term care providers a flexible framework for command and control that is based on the standardized system of ICS. It does this through a system that is designed to:
  • Manage all emergency, routine, or planned events, of any size or type, by establishing a clear chain of command and a process for communication, decision‐making and delegation.
  • Allow personnel from different agencies or departments to be integrated into a common structure that can effectively address issues and delegate responsibilities.
  • Provide needed logistical and administrative support to operational personnel.​

 Shelter In Place

Shelter In Place: Planning Resource Guide for Nursing Homes

For the purposes of this resource guide, shelter in place (SIP) is defined as: A protective action strategy taken to maintain resident care in the facility and to limit the movement of residents, staff and visitors in order to protect people and property from a hazard.

Shelter In Place Guidebook (PDF)

 State Resources

Wisconsin

 Winter Weather

The Centers for Disease Control and Prevention published a comprehensive winter weather health and safety site. Owners and administrators can take tips to prepare for extreme cold conditions and winter storms.​

 In Case of An Emergency

AHCA/NCAL regularly publishes and distributes informative documents for members regarding emergency preparedness, response, and recovery.

During public health emergencies, CMS will post updates on waivers on their Emergency Response and Recovery page. Members should check this page for updates during an event.