US HHS: Nursing homes are not prepared; states, coalitions, and local emergency managers need to help
Rick Christ, MEP, CHEC
Preparedness Professional: planning, training, and exercises for all disciplines.
Nursing homes nationwide, and the state agencies that oversee their safety, are under increasing scrutiny by the US Department of Health and Human Services (HHS), the parent organization of the Centers for Medicare and Medicaid Services (CMS).
Healthcare Preparedness Coalitions, and nursing home themselves, need to take CMS Emergency Preparedness Program (EPP) Conditions of Participation seriously. Fines and even facility closures are likely. So is increased oversight, at the facility level, directly by CMS.
On February 16, HHS’ Office of Inspector General (OIG) issued a report on nursing home safety in Iowa. It joins previous reports about North Carolina and Illinois (September 2020), Missouri and Florida (March 2020), Texas (February 2020), California (November 2019), and New York (August 2019). (Message me for copies of these reports.)
These reports are by now very predictable in nature:
- There are numerous significant safety violations at many, if not most, of the facilities that CMS visits without notice.
- State regulatory agencies are criticized for not checking safety at nursing homes often enough, even facilities with prior reports of significant safety violations.
- States are criticized for not conducting sufficient safety training for nursing homes.
- Regional healthcare coalitions are identified as the logical conduit for nursing home safety training and exercises, yet most coalitions have very low participation by nursing homes.
- Local emergency management agencies are typically left out of the nursing home safety process: they typically do not review or approve safety plans, nor coordinate training and exercises for healthcare facilities, nor participate significantly in their regional healthcare coalitions. Many do not even maintain a list of the nursing homes in their jurisdiction.
- The reports criticize the lack of information sharing among state and local agencies; survey notices of deficiency are not shared with local emergency managers, for instance, or, generally, with anyone outside the facility who might assist the facility with improving safety.
Here are our recommendations for all involved (and, yes, we are eager to help you with planning and implantation!):
States: (a) work with CMS to develop life safety training for all healthcare facility staff; (b) require that private pay facilities meet CMS EPP conditions of participation by referencing CMS standards in state licensing requirements; (c) strengthen participation in healthcare coalitions by funding them beyond HPP grants and empowering them to engage nursing homes, and all healthcare facilities, with training and exercises; (d) require information sharing between survey agencies, licensing agencies, local emergency management, and healthcare coalitions; (e) require review of in-patient and residential healthcare facility emergency preparedness plans by local emergency management officials; (f) inspect all healthcare facilities more frequently, and those with poor track records more often; and (g) funding local emergency management agencies accordingly.
Coalitions: (a) lobby states to follow the above recommendations; (b) engage all healthcare facilities in your preparedness activities; (c) provide value-added services, including community risk assessments, training, and exercises that justify modest membership fees by healthcare facilities; (c) better engage local emergency management officials; and (e) conducting training and exercises that not only barely meet CMS EPP requirements but actually improve preparedness.
Local Emergency Management Agencies: (a) lobby states to follow above recommendations; (b) participate actively with coalitions to provide planning, training, and exercise support to healthcare facilities; and (c) review healthcare emergency preparedness plans and strengthen them.
Healthcare facilities: (a) lobby states to follow the above recommendations; (b) participate actively in your regional coalition; (c) engage local emergency management in the review and improvement of your plans.
The most recent report (Iowa) was based on surveys conducted shortly before COVID-19 impacted all healthcare operations (facilities were inspected July – November 2019). There is little doubt that these state-level reviews will resume as soon as it is safe to re-enter facilities. In fact, the first states surveyed – California, New York, Texas, and Florida – were specifically chose shortly after natural disasters ravaged them. CMS shows no indication of reducing its emergency preparedness oversight, and has not eased up since the rules were finalized in 2016, even in the face of significant challenges to healthcare facilities.
YourCrisisTeam stands ready to work with state agencies, regional coalitions, local emergency management agencies, and individual facilities to improve coordination and deliver planning, training, and exercises that improve preparedness.
Capital One | Crisis, Continuity, and Resilience | CEM CBCP
3 年Great piece. I appreciate the actionable items as opposed to “we should”, and “if only” as many of our counterparts like to opine. I remember getting bummed out about LTC preparedness back in 2010 and here is where it landed/s with me: 1. Until there are real financial and operating consequences, there will be limited change in capabilities inside SNF, NF, ALF, IL, memory care, etc. facilities. 2. Until the odds are good enough that #1 will actually happen to a facility, there will be limited or isolated improvement. The idea that facilities should make caring for their residents across the spectrum of “bad days” is simply not in many facility’s business model. It’s a paper-based capability that unfortunately will/would devolve into a 911 call. Like many of you, I’ve lived a SNF evacuation with real consequences and the threshold for “passing the buck” to local authorities (who by the way are not experts in LTC care delivery) is very very low. Effective coalitions have been, are, and will continue to raise the bar and provide operational support. Kudos to those folks. The steps you outline are truly some of the best things we can do to force the issue. Pardon the mildly negative slant. Hope you’re well, Rick!
Community Health & Threat Preparedness Director at Mid Ohio Valley Health Dept
3 年I would agree. One thing I have seen with the pandemic is that there were very few ready not just for a disaster in their own facilities but also, how many facilities were allowed to misrepresent/ even lie about what was happening, and not held accountable for their bad decision making... and all the while expecting health departments, local emergency management to give them the tools they needed to combat the pandemic instead of these private businesses having their own resources especially upfront when things started to happen.
Environmental Services Manager | Safety | Healthcare Industry | Certified Healthcare Safety Professional | Certified Healthcare Safety - Environmental Services | Manage Projects For A 400 Plus Bed Level-1 Trauma Center.
3 年Rick Christ, MEP, CHEC, This is a great article. I wrote a paper during my Master's degree about Nursing Homes and lack of preparedness and knowledge of preparedness a few years back. Incident after incident happens around the country, and Nursing Homes continue to be the epicenter of unpreparedness with a lack of understanding. This is an actual vulnerable population. With each passing disaster, whether natural or human-made, the same accidents and mistakes occur due to Nursing Homes's lack of preparedness or education for change continue. Emergency Management's motto is "to learn from the past." Nursing Homes should be required to meet the same standards hospitals are held to. Why this is not nor has it been the case is beyond me because the same result continues. Not only is this horrible but shameful.
Firefighter / EMT | Public Safety Advocate and Supporter
3 年Great article and thank you for sharing Rick Christ, MEP, CHEC . I will be sharing this article to help promote awareness!
Father | Husband | Emergency Manager | Incident Management Team Coordinator
3 年The states do not have the enforcement resources on the day to day basis let alone gray skies. It is sad conditions in these places and it’s systemic.