For home health agencies (HHAs) serving Medicare and Medicaid beneficiaries in the coastal Texas region, there is an unseen benefit among preparations for the looming Hurricane Harvey.
Projected to strengthen to a category 3 hurricane with 110 mph winds before making landfall late Friday or early Saturday morning, Harvey promises to test the preparedness of residents in its path. Heavy rain in flood prone coastal areas is a major concern and Governor Abbott has declared a state of disaster for numerous counties along the Gulf of Mexico.
Hurricane Harvey is driving HHAs in the projected area to deploy their emergency preparedness (EP) plans, and begin last-minute preparations for their patients, staff and physical locations. While residents in the hurricane region prepare, home health agencies and hospices must care for some of the most frail and vulnerable people, and therefore take extra precautions.
Federally-mandated EP regulations were instituted for situations such as Hurricane Harvey, so that patients who may have mobility issues or scant resources are relocated, or potentially have the choice to shelter in-place and are tracked and cared for as needed.
One potential perk to the upcoming storm is the opportunity for your HHA to complete requirements for EP. Agencies who experience an actual natural or man-made emergency that requires activation of the emergency plan are exempt from engaging in a community-based or individual, facility-based full-scale exercise for one year following the onset of the actual event.
Agencies in the pending disaster area should record and document actions during the hurricane response. Once the HHA recovers from Hurricane Harvey, processes should be reviewed and policies updated per their experiences. After execution of the EP through Hurricane Harvey, the HHA will only need an additional table top exercise and review, rather than a coordinated, community-wide exercise, before November 15, 2017 to be compliant with the new regulation.
Compliance with emergency preparedness regulations are now tied to Conditions of Participation (CoPs) for Medicare and Medicaid HHAs, which become effective January 1, 2018. Agencies who do not follow the minimum standards of care, safety and quality in the CoPs are at risk of losing their ability to bill Medicare and Medicaid for services delivered.
Updated federal EP regulations became effective November 15, 2016, and highlight standards for HHAs to implement, drill, review and update their emergency preparedness plans yearly. Agencies are required to hold two EP exercises to fulfill this regulation by November 15, 2017, including a community-wide exercise and a table-top exercise.
Both exercises must be executed and reviewed to find possible improvements to processes. Agency EP policies must also factor in federal, state and local regulation to ensure the HHA collaborates with authorities to coordinate evacuations, transfers and home checks for persons who may have sheltered in place and cannot be accounted for, for example. EP policies must be reviewed and updated at least annually.
Updated EP regulation requirements include, among other points:
- Each patient has an emergency plan as part of their comprehensive assessment;
- Agency informs state and local officials about HHA patients who need to be evacuated from their place of residence due to medical or psychiatric conditions;
- Follow up with staff and patients to determine services needed in the event of interruption of services during or due to an emergency;
- Agency staff, whether directly employed or contracted, are trained on the agency’s EP plan and individual responsibilities when the plan is deployed;
- Plans ensure communication and protection of patients’ medical records.
For more information on the updated Federal Emergency Preparedness regulations, go to Axxess’ on-demand video.
