CMS Emergency Preparedness Booklet

CMS Emergency Preparedness Booklet

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Major Change to Centers for Medicare & Medicaid Services Emergency Preparedness Guidelines

Centers for Medicare and Medicaid Services communication, a change from the old approach which didn’t require coordination between health organizations during an emergency or have contingency planning and emergency response training for staff in place. With the new CMS Emergency Preparedness Guidelines, healthcare organizations will need to coordinate their plans with federal, state, regional, tribal and local emergency preparedness systems.

Contrary to what may be assumed by first look, an “All-hazards” approach is not a one-sized-fits-all solution. Instead, the response (individual or community) is phase and hazard specific. For example, what are the challenges, how are people behaving, and how are needs different in first

minutes, days, weeks, etc? These answers all help determine what phase you’re responding to.

What is the hazard? Are you managing an active shooter situation? Fire or flood? Earthquake? Depending on the situation, your situation, response, and critical partners will change.

The “bones” (or structure) will be the same, but the need for flexibility and scalability is key.

In this booklet you will find a set of resources designed to help you ensure you meet the CMS Guidelines, specifically in terms of communication. This will protect your organization from penalties and ultimately, be better prepared for emergencies.

Additionally, we’ve included one Everbridge customer use cases for your reference.

Resources included are:

CMS Emergency Preparedness: Final Rule

Critical Communication Points For CMS Emergency

Preparedness

CMS Emergency Preparedness Requirements by Provider Type

Provider and Supplier Types Covered by The CMS Emergency

Preparedness Rule

CMS EMERGENCY PREPAREDNESSFINAL RULE

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What You Need to Consider to Meet the CriteriaThe Centers for Medicare and Medicaid Services, for the first time, have added an Emergency Preparedness Rule that all hospitals and healthcare facilities must meet by November 17, 2017. We have prepared a brief overview of what you should consider as part of your plan but suggest you thoroughly review the final guidelines with your team.

The core elements of the regulation are ones most hospital emergency preparedness teams will recognize:

1. Build an emergency plan2. Develop and maintain policies

and procedures3. Develop and maintain a

communication plan4. Develop and maintain a training

and testing program

The Emergency Preparedness Plan for your hospital or healthcare system is based on an all-hazards risk assessment. The plan must cover the following areas:

• Epidemic/pandemic• Biological• Chemical• Nuclear/radiogical• Explosive-incendiary• Natural Incidents

In addition, the plan must take into account threats possible in the local community, for instance, wildfires in the West or blizzards in northern states. The plan must include a process for interacting with the local community groups such as police, fire, local government, and other nearby healthcare facilities, and other emergency responders.

Emergency Preparedness Requirements

Your plan must meet the following six steps to receive approval from CMS:

• Perform a risk analysis for your facility/facilities• Establish a plan to address those risks (as listed above)• Develop procedures and polices to protect against those risks• Develop a communication plan to support patient, staff and community safety• Train staff to readily impliment the plan• Test the plan with at least one full-scale exercise and one other exercise which may be another full-scale exercise or a table-top drill review

Meeting Communications Criteria

Focusing on natural, man-made, and or facility emergencies that including: care-related emergencies; equipment and power failures; interruptions in communications, including cyber-attacks; loss of a portion or all of a facility; and, interruptions in the normal supply of essentials, such as water and food. We encourage you to review the guidelines with your team, but you should consider the following (quotes are directly from the Federal Register Vol. 81, No. 180 guidelines on the CMS Final Rule):

Speed of Response

“It is essential that hospitals have the capacity to respond in a timely andappropriate manner in the event of a natural or man-made disaster.”

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You must respond immediately when an incident occurs. It is important that your communications network be ready to go at the touch of a button. Things to consider are ready-made communication that can be tailored quickly to the specific incident and a communication system that can send out messages via multiple options (mobile, robocalls, text, email, etc). to ensure everyone is reached “in a timely and appropriate manner.”

Tailored to Your Population

“At-risk populations are individuals who may need additional response assistance, including … from diverse cultures, have limited English proficiency, or are non- English speaking.”

The messaging you deliver needs to reflect your local population. Perhaps you have a large Hispanic community near your facility – messages may need to be in two or more languages. Again, using prepared templates that require only a few modifications tailored to the incident will ensure your community gets the message and knows how to act on it.

Coordinate with the Local Community for CMS Emergency Response

“A hospital [must] have a process for ensuring cooperation and collaboration with local, tribal, regional, state, or federal emergency preparedness officials’ efforts to ensure an integrated response during a disaster or emergency situation.”

Hospitals are often at the center of their communities when it comes to the health of the local population. During a crisis, patients may appear in the

Emergency Department seeking aid. The local community of police, fire, EMTs, state and local officials need to know if your hospital is available to take patients or if it needs to be evacuated. You’ll likely need to work with other hospitals to be able to send or receive patients during an event.

You’ll need two levels of communication in this regard:

• The ability to communicate easily with off-hospital coordinators to send and receive information• The ability to communicate HIPAA-compliant patient information for incoming patient and those being evacuated.

Requirement to Track Patients and Staff

“Providers [must] develop policies and procedures regarding a system to track the location of staff and patients in the hospital’s care both during and after anemergency.”

Reading through the guidelines, it becomes apparent that a hospital or healthcare facility will need a database that allows contact with all staff based on their schedules, their areas of expertise and the hospital needs. Setting up groups of contacts such as clinical staff vs. facilities staff will speed coordination of aid during an event.

The guidelines specifically say you will need more than one mode of communication in case backup forms of communication are needed. Just sending an email or a text will not be enough and your team should evaluate the best ways to interact with your community.

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You will need to know where on-duty staff are, if they are safe, and if they are able to care for patients. It goes without saying that you’ll need to keep track of your patients specifically around safety, care, and patient transfers.

CMS elaborates:

“We would expect the facility to include in its emergency plan a method for contacting off-duty staff during an emergency and procedures to address other contingencies in the event staff are not able to report to duty which may include but are not limited to staff from other facilities and state or federally-designated health professionals.”

Documenting Communication

“Providers and suppliers must document efforts made by the facility to cooperateand collaborate with emergency officials.”

If you have an emergency preparedness communications platform that automatically archives messages, that will relieve emergency responders from worrying about manually tracking interactions.

The Deadline is Real

CMS is quite clear the November 2017 deadline must be met: Specifically:

“We do not agree with … a provision that will allow for facilities to apply for extensions or waivers to the emergency preparedness requirements. We believe that an implementation date that is beyond 1 year after the effective date of this final rule for these requirements is inappropriate and leaves the most vulnerable facilities and

patient populations without life-saving emergency preparedness plans.”

Stability of Platform

While not a specific requirement, emergency planners should consider the stability of their platform to perform during an event. Severe weather and mass casualty events can knock out civilian-grade networks. During a terrorist attack, local officials may bring down civilian networks to slow terrorist coordination.The Everbridge platform, for example, is on par with FEMA, if civilian networks are down, Everbridge systems have federal clearance levels that allow our messages to still get through.

Planners have met emergency guidelines for years with the Joint Commission Accreditation Program. As a planner, you likely already have most of these elements in place. We suggest you review your current situation, find the gaps in the plan, and begin speaking to providers who can fill in those gaps.

Everbridge was born from the lessons learned in emergency communication gaps during the 9/11 tragedy. We can meet all of the needs outlined for the CMS Emergency Preparedness Final Rule and we’d be happy to talk to you about how we can get your facility ready by that November 2017 deadline. Our goal is to partner with you and your team with smart, usable information.

CRITICAL COMMUNICATION POINTSFOR CMS EMERGENCY PREPAREDNESS

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OverviewThe Interpretative Guidelines (IGs) for the CMS Emergency Preparedness Final Rule are released. The 72-page document clarifies several issues about communication as hospital and healthcare facilities work towards meeting criteria by the Novemberdeadline.

Below is a breakdown of the critical communication points to consider, along with excerpts from the IGs. We know some planners are still getting up to speed and we invite you to read through this blog post, and also check out our CMS Emergency Preparedness Library for additional resources.

Our overall impression is the IGs emphasize two important aspects of preparedness:

Planners need to think of the worst-case scenarios related to a myriad of threats and plan for those. The IGs repeatedly emphasize like evacuations, power failures and supply and staff shortages. While large scale emergencies are rare, they cause the greatest threat to facilities and put the most lives at risk. CMS wants you prepared for the worst, so take those scenarios into serious consideration when you’re doing risk assessments.

Whether managing broad-impact or localized events, community cooperation is key and the IGs strongly emphasize planning with the response community outside of the healthcare facility. They want to see active drills that include responders from local and state agencies and other healthcare facilities. That was repeated several times and you must document the reason why you can’t have a multi-

organization active drill or risk not being accredited.

Now let’s dive into the communication points that are emphasized in the IGs.

Communications for Essential Personnel

Whether on-duty or off-duty, planners need to take into consideration who needs to be at the facility for each planned hazard, and there needs to be a succession plan in place in case the planned responder is unavailable. You should develop primary and secondary means of communication with your essential personnel, contractors, and volunteers) and you’ll need to think about how to contact them before, during, and after an incident.

Excerpts from the IGs:

On-Duty Staff: E-0018, Facilities must have “a system to track the location of on-duty staff and sheltered patients in the [facility’s] care during an emergency.” (pg. 25)

Off-Duty Staff: “Facilities are expected to include in its emergency plan a method for contacting off-duty staff during an emergency and procedures to address other contingencies in the event staff are not able to report to duty which may include, but are not limited to, utilizing staff from other facilities and state or federally-designated healthprofessionals.” (pg. 35)

Succession Planning: “The Emergency plan must identify which staff would assume specific roles in another’s absence through succession planning and delegations of authority … Succession planning increases the availability of experienced and capable

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employees that are prepared to assume these roles as they become available … At a minimum, there should be a qualified person who ‘is authorized in writing to act in the absence of the administrator or person legally responsible for the operations of thefacility.’” (pg. 13)

Communications for Essential Functions

There are many essential functions for a healthcare facility, you need to think about aspects of business continuity as well as patient care. Beyond adequate staffing, you need to think about power supplies, vendors that provide essential services such as food, water, medical equipment, and medicine. Do you have a way to reach them before, during, and after an incident? Are there things you can stockpile? And things that you can bring on site as needed? Do those requirements change depending on thethreat you’re preparing for (i.e. a chemical spill vs. a natural disaster).

Facilities must be able to provide for adequate subsistence for all patients and staff for the duration of an emergency or until all its patients have been evacuated and its operations cease. There are no set requirements or standards for the amount ofprovisions to be provided in facilities. Provisions include, but are not limited to: (pg. 22)

• Food• Pharmaceuticals• Medical Supplies

Communications with the Local Community

The definition of local community was purposely left vague so planners could

consider what is available in their region, but planners are expected to work with various agencies and responders in their area. They should also take into groups such as public health, neighboring states, any group that could aid or coordinate with a facility during an incident. Again, there must be primary and secondary means of communication. This was emphasized several times in the IGs, below is one excerpt that summarizes the expectations.

Facilities must have a written emergency communication plan that contains how the facility coordinates patient care within the facility, across healthcare providers, and with state and local public health departments. The communication plan should include how the facility interacts and coordinates with emergency management agencies and systems to protect patient health and safety in the event of a disaster. The development of a communication plan will support the coordination of care. (pg. 41)

Facilities are required to have primary and alternate means of communicating with staff, Federal, State, tribal, regional, and local emergency management agencies. Facilities have the discretion to utilize alternate communication systems that best meets their needs. (pg. 46)

Communications During Evacuations

If the worst happens and a facility needs to evacuate, planners need to keep several things in mind. [Page numbers in the numbered list below are summary reference, not direct quotes]

1. What staff are needed to help with

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the evacuation and if staff travel with patients to maintain care (pg. 28)

2. What essential resources (food, water, medical supplies, etc.) are needed during an evacuation (pgs. 6, 10)

3. What outside agencies would assist in a patient move (pg. 31)

4. What facilities would receive the patients (sometimes this means a primary receiving facility and a secondary receiving facility (pg. 14) as well as transport options pg. 37)

5. Planning to maintain HIPAA while relaying patient information, including the sharing of medical documentation (pg 48)

6. Planning to be the receiving facility – thinking about staffing and supply needs and other aspects of a patient surge (pg. 11)

7. Facilities also need to have the ability to include and share occupancy information including bed availability (pg. 49)

8. Logging all the information in a way that is trackable and reviewable (pgs. 27-29, 32, 54)

Facilities are encouraged to leverage the support and resources available to them through local and national healthcare systems, healthcare coalitions, and healthcare organizations for resources and tools for tracking patients. (pg. 27)

Facilities must develop a means to track patients and on-duty staff in the facility’s care during an emergency event. In the event staff and patients are relocated, the facility must document the specific name and location of the receiving facility or other location for sheltered patients and on-duty staff who leave the facility during the emergency. (pg. 26)

Facilities are expected to provide patient care information to receiving facilities during an evacuation, within a timeframe that allows for effective patient treatment and continuity of care. (pg. 48)

Critical Communications and Your Emergency Preparedness Plans

We recommend taking the following steps to review your emergency preparedness communication plans to meet the CMS criteria:

1. Perform a risk assessment of your facility using an all-hazards approach

2. Reach out to other facilities and local agencies to ensure a primary and secondary means of communication

3. Ensure you have a primary and secondary way to reach staff, contractors, and volunteers in the event of an emergency, make sure the lists are regularly updated

4. Ensure you have a system in place to log steps during an event for review purposes and to submit to federal, state, and local agencies as needed

5. Ensure you have a system in place to track patients during an emergency including hand-offs to other facilities, ways to notify family members, and maintain HIPAA-compliance.

Working with healthcare emergency preparedness leaders, Everbridge has developed a CMS Emergency Preparedness Library to help facilities achieve compliance with CMS’ new rule. You can also contact us for more information with a specific issue.

Centers for Medicare and Medicaid Services (CMS)Emergency Preparedness Requirements by Provider Type

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Hospital Develop a plan based on a risk assessment using an “all hazards” approach, which is an integrated approach focusing on capacities and capabilities critical to preparedness for a full spectrum of emergencies and disasters. The plan must be updated annually.

Develop and implement policies and procedures based on the emergency plan, risk assessment, and communication plan which must be reviewed and updated at least annually. System to track on-duty staff & sheltered patients during the emergency.

Develop and maintain an emergency preparedness communication plan that complies with both federal and state laws. Patient care must be well coordinated within the facility, across health care providers and with state and local public health departments and emergency systems. The plan must include contact information for other hospitals and CAHs; method for sharing information and medical documentation for patients.

Develop and maintain training and testing programs, including initial training in policies and procedures and demonstrate knowledge of emergency procedures and provide training at least annually. Also annually participate in:

• A full-scale exercise that is community- or facility-based;

• An additional exercise of the facility’s choice.

Generators—Develop policies and procedures that address the provision of alternate sources ofenergy to maintain:

(1) temperatures to protect patient health and safety and for the safe and sanitary storage of provisions;

(2) emergencylighting; and

(3) fire detection, extinguishing,and alarm systems.

Provider Type

EmergencyPlan

Policies andProcedures

Communication Plan

Training and Testing

Additional Requirements

Critical Access

Hospital

* * * * Generators

Long TermCare

Facility

Must account for missing residents (existing requirement).

Tracking during and after the emergency applies to on-duty staff and sheltered residents.

GeneratorsShare with resident/ family/ representative appropriate information from emergency plan.

In the event of an evacuation, method to release patient information consistent with the HIPAA Privacy Rule.

*

PRTF Tracking during and after the emergency applies to on-duty staff and sheltered residents.

* * *

Inpatient

Boston University School of MedicineHealthcare Emergency Management Department of Anatomy and Neurobiology

Medical Campus650 Albany Street, X-140Boston, Massachusetts 02118-2526T 617-414-2315 F 617-414-2316

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Inpatient

ICF/IID Must accountfor missing residents (existing requirement).

*(current requirement)

Share with client/ family/representative appropriate information from emergency plan.

Provider Type

EmergencyPlan


Communication Plan



RNHCI Does not include the requirement to coordinate with state or federallydesignated healthcare professionals.

No requirement to conduct drills.

* *

TransplantCenter

* * * * Maintain agreement with transplant center & OPO.

Outpatient ProvidersOutpatient providers are not required to provide subsistence needs for staff and patients.

Hospice In home services —inform officials of patients in need of evacuation (additional requirement). Home-based hospices not required to track staff and patients.

In home services —will not need to provide occupancy information.

*(current requirement)

* Share with client/ family/representative appropriate information from emergency plan.

Provider Type

EmergencyPlan


Communication Plan



AmbulatorySurgical Center

Will not need to provide occupancy information. Not required to develop arrangements with other ASCs and other providers to receive patients in the event of limitations or cessation of operations. Not required to include the names and contact information for "other ASCs" in the communication plan.

Community-based drill not required.

* *

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PACE * * *Inform officials ofpatients in need ofevacuation (additionalrequirement).Tracking during and after the emergency applies to on-duty staff and sheltered participants.

CORF *Must developemergency plan with assistance from fire, safety experts (existing requirement)

Will not need to provide transporta-tion to evacuation locations, or have arrangements withother CORFs to receive patients, and not required to track staff and patients.

Will not need to provide occupancyinformation.

CMHC ** *Tracking during and after the emergency applies to on-duty staff and sheltered clients.

Home HealthAgency

* *Will not require shelter in place, provision of care at alternate care sitesInform officials ofpatients in need ofevacuation.

HHAs not required to track staff and patients.

Will not need to provide occupancyinformation. Not required to include the names and contact information for other HHAs in the communication plan. Not required to develop arrangements with other HHAs.

HHAs must have policies in place for following up with patients to determine services that are still needed. In addition, theymust inform State and local officials of any onduty staff or patients that they are unable to contact.

Provider Type

EmergencyPlan


Communication Plan




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OPO Address type ofhospitals OPOhas agreement(additionalrequirement).

Needs to have system to track staff during & afteremergency and maintain medical documentation(additional requirement).

Does not need to provide occupancyinfo, method of sharing pt. info,providing info on general condition &location of patients.

Only tabletop exercise

Must maintain agreementwith other OPOs & hospitals.

Clinics,Rehabilita-

tion,and

Therapy

Must developemergency planwith assistancefrom fire, safetyexperts. Addresslocation, use ofalarm systemsand signals &methods ofcontaining fire(existingrequirements).

*Not required to track staff and patients.

Does not need to provide occupancyinformation.

*

RHC/FQHC

* Does not have to track staff and patients, or have arrangements withother RHCs to receive patients or have alternatecare sites.


*

ESRD Must contactlocal emergencypreparednessagency annuallyto ensuredialysis facility'sneeds in anemergency(existingrequirement).

Policies and procedures must include emergencies regarding fire equipment, powerfailures, care relatedemergencies, watersupply interruption & natural disasters (existing requirement).Tracking during and after the emergency applies to on-duty staff and sheltered patients.

Ensure staff demonstrate knowledge of emergency procedures, informingpatients what to do, where to go, whomto contact if emergency occurs while patient is not in facility (alternateemergency phone number), how todisconnect themselves from dialysis machine. Staff maintain current CPR certification, nursing staff trained in use of emergency equipment & emergencydrugs, patient orientation (existingrequirements).


Provider Type

EmergencyPlan


Communication Plan




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Affected organizations:

Requirements affect both providers and suppliers (17 in total)(alpha list):

1. Ambulatory Surgical Centers (ASCs)(Outpatient)

2. Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services (Outpatient)

3. Community Mental Health Centers (CMHCs) (Outpatient)

4. Comprehensive Outpatient Rehabilitation Facilities (CORFs) (Outpatient)

5. Critical Access Hospitals (CAHs)(Inpatient)

6. End-Stage Renal Disease (ESRD) Facilities (Outpatient)

7. Home Health Agencies (HHAs) (Outpatient)

8. Hospices (Inpatient and Outpatient)9. Hospitals (Inpatient)10. Intermediate Care Facilities

for Individuals with Intellectual Disabilities (ICF/IID) (Inpatient)

11. Long-Term Care (LTC) Facilities (Inpatient)

12. Organ Procurement Organizations (OPOs)(Outpatient)

13. Programs of All-Inclusive Care for the Elderly (PACE)(Outpatient)

14. Psychiatric Residential Treatment Facilities (PRTFs) (Inpatient)

15. Religious Nonmedical Health Care Institutions (RNHCIs) (Outpatient)

16. Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)

17. Transplant Centers (Inpatient)

*Indicates that the requirements are the same as those for hospitals. Exceptions are noted for individual provider/suppliers.

NOTE: These tables are an overview of the regulation with key differences summarized. This is not meant to be an exhaustive list of the requirements norshould it serve as substitute for the regulatory text.

PROVIDER AND SUPPLIER TYPES COVEREDBY THE CMS EMERGENCYPREPAREDNESS RULE

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There are 17 specific provider and supplier types affected by the newly released Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Rule. ASPR TRACIE developed the following definitions based on information gleaned from numerous sources to provide a general description of each type. These definitions should not be interpreted as regulatory or interpretive guidance, but used for general informational and awareness purposes only.

Listed alphabetically, facilities are also categorized based on whether they are inpatient or outpatient, as outpatient providers are not required to provide subsistence needs for staff and patients.

Please refer to CMS publications for final determination of applicability of the rule and compliance questions.

For more information visit asprtracie.hhs.gov/cmsrule.

Affected Provider and Supplier Types

Inpatient Outpatient

Critical Access Hospitals (CAHs) Ambulatory Surgical Centers (ASCs)

Hospices Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services

Hospitals Community Mental Health Centers (CMHCs)

Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)

Comprehensive Outpatient Rehabilitation Facilities (CORFs)

Long Term Care (LTC) End-Stage Renal Disease (ESRD) Facilities

Psychiatric Residential Treatment Facilities (PRTFs)

Home Health Agencies (HHAs)

Transplant Centers Organ Procurement Organizations (OPOs)

Programs of All Inclusive Care for the Elderly (PACE)

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)

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Ambulatory Surgical Centers (ASCs) (Outpatient)CMS defines an ASC as any distinct entity that operates exclusively for the purpose of providing surgical services to patients not requiring hospitalization and in which the expected duration of services would not exceed 24 hours following an admission. An unanticipated medical circumstance may arise that would require an ASC patient to stay in the ASC longer than 24 hours, but such situations should be rare.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/ASCs.html

Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services(Outpatient)

CMS provides the following definitions:

Rehabilitation Agency - An agency that provides an integrated, multidisciplinary program designed to upgrade the physical functions of handicapped, disabled individuals by bringing together, as a team, specialized rehabilitation personnel.

Clinic - A facility established primarily for the provision of outpatient physicians’ services. To meet the definition of a clinic, the facility must meet the following test of physician participation:

• The medical services of the clinic are provided by a group of three or

more physicians practicing medicine together, and

• A physician is present in the clinic at all times during hours of operation to perform medical services (rather than only administrative services

Public Health Agency - An official agency established by a state or local government, the primary function of which is to maintain the health of the population served by providing environmental health services, preventive medical services, and in certain instances, therapeutic services.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/OutpatientRehab.html

Community Mental Health Centers (CMHC) (Outpatient)

CMS defines CMHCs as outpatient organizations that provide partial hospitalization services to Medicare beneficiaries for mental health services. CMS estimates there are about 100 CMHCs that provide partial hospitalization services through Medicare and that will be affected by this rule

For more information: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/CommunityHealthCenters.html

Comprehensive Outpatient Rehabilitation Facilities (CORFs) (Outpatient)

Per CMS, CORFs must provide coordinated outpatient diagnostic, therapeutic, and restorative services,

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at a single fixed location, for the rehabilitation of injured, disabled or sick individuals. Physical therapy, occupational therapy and speech-language pathology services may be provided in an off-site location. Consultation with and medical supervision of nonphysician staff, establishment and review of the plan of treatment and other medical and facility administration activities, physical therapy services, social or psychological services are also provided.

For more information: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/CORFs.html

Critical Access Hospitals (CAHs) (Inpatient)

CMS maintains that CAHs:

• Be located in a state that has established a State Medicare Rural Hospital Flexibility Program;

• Be designated by the state as a CAH;

• Be located in a rural area or an area that is treated as rural;

• Be located either more than 35 miles from the nearest hospital or CAH or more than 15 miles in areas with mountainous terrain or only secondary roads; OR prior to January 1, 2006, were certified as a CAH based on state designation as a “necessary provider” of health care services to residents in the area;

• Maintain no more than 25 inpatient beds that can be used for either inpatient or swingbed services;

• Maintain an annual average length of stay of 96 hours or less per patient for acute

• inpatient care (excluding swing-bed services and beds that are within distinct part units); and

• Furnish 24-hour emergency care services 7 days a week.

For more information: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/CAHs.html

End-Stage Renal Disease (ESRD) Facilities (Outpatient)

A freestanding dialysis center is a facility that provides chronic maintenance dialysis to ESRD patients on an outpatient basis, including dialysis services in the patient’s place of residence. A certified ESRD facility provides outpatient maintenance dialysis services, home dialysis training and support services, or both. A dialysis center may be independent or hospital-based.

For more information:https://www.cms.gov/Regulations-and-Guidance/Legislation/CFCsAndCoPs/ESRD.html.

Home Health Agencies (HHAs) (Outpatient)

CMS defines HHAs as primarily engaged in providing skilled nursing services and other therapeutic services to patients. HHAs policies are established by a group of professionals (associated with the agency or organization), including one or more physicians and one or moreregistered professional nurses, to govern the services which it provides. HHAs provide for supervision of above-mentioned services by a physician or registered professional nurse, are licensed pursuant to State or local law, or have approval as meeting the

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standards established for licensing by the State or locality. HHAs must also meet the federal requirements in theinterest of the health and safety of individuals they serve.

For purposes of Part A home health services under Title XVIII of the Social Security Act, the term “home health agency” does not include any agency or organization which is primarily for the care and treatment of people with mental illnesses.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/HHAs.html

Hospices (Inpatient and Outpatient)

A hospice is a public agency, private organization, or a subdivision that: is primarily engaged in providing care to terminally ill individuals (individuals that have been certified as being terminally ill as per CMS requirements and entitled to Part A of Medicare); meets the conditions of participation for hospices; and has a valid Medicare provider agreement.

Hospice care is a comprehensive set of services identified and coordinated by an interdisciplinary group to provide for the physical, psychosocial, spiritual, and emotional needs of a terminally ill patient and/or family members, as delineated in a specific patient plan ofcare.

Hospice services can also be provided in facilities, such as those located as a part of a hospital, nursing home, or residential facility, or as a freestanding hospice inpatient facility. All hospices

must meet specific federal requirements and be separately certified and approved for Medicare participation.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/Hospices.html

Hospitals (Inpatient)

CMS defines a hospital as an institution primarily engaged in providing, by or under the supervision of physicians, inpatient diagnostic and therapeutic services or rehabilitation services. (Critical Access Hospitals are certified under separate standards. Psychiatric Hospitals are subject to additional regulations beyond basic hospital conditions of participation.) Inpatient Rehabilitation Facilities and Long Term Care Hospitals are included in the Hospital definition.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/Hospitals.html

Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID) (Inpatient)

The ICF/IID benefit is an optional Medicaid benefit. The Social Security Act created this benefit to fund “institutions” (4 or more beds) for individuals with intellectual disabilities and other related conditions, and specifies that these institutions must provide “active treatment,” as defined by the Secretary of the U.S. Department of Health and Human Services. Currently, all 50 States have at least one ICF/IID facility. This program serves over 100,000 individuals, many of whom are

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non-ambulatory, have seizure disorders, behavior problems, mental illness, visual or hearing impairments, or a combination. All must financially qualify for Medicaid assistance.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/ICFIID.html

Long-Term Care (LTC) Facilities (Inpatient)

CMS includes skilled nursing facilities and nursing facilities under LTC Facilities. They define “skilled nursing facility” as an institution (or a distinct part of an institution) which: is primarily engaged in providing skilled nursing care and related services for residents who require medical or nursing care, or rehabilitation services for injured, disabled, or sick persons, and is not primarily for the care and treatment of mental diseases; has in effect a transfer agreement (meeting the requirements of §1861(1)) with one or more hospitals having agreements in effect under §1866; and meets the requirements for a SNF described in subsections (b), (c), and (d) of this section.

CMS defines “Nursing facility” as an institution (or a distinct part of an institution) which is primarily engaged in providing skilled nursing care and related services for residents who require medical or nursing care, rehabilitation services for injured, disabled, or sick persons, or on a regular basis, health-related care and services to individuals who because of their mental or physical condition require care and services (above the level of room and board) which can be made available to them only through institutional facilities,

and is not primarily for the care and treatment of mental diseases; has in effect a transfer agreement (meeting the requirements of §1861(1)) with one or more hospitals having agreements in effect under

§1866; and meets the requirements for a NF described in subsections (b), (c), and (d) of this section.

For more information: https://www.cms.gov/Regulations-and-Guidance/Legislation/CFCsAndCoPs/LTC.html

Organ Procurement Organizations (OPOs) (Outpatient)

OPOs, as defined by the Health Resources and Services Administration, offer opportunities for volunteering and helping to raise awareness about the importance of registering as a donor. There are 58 OPOs in the United States, each with its own designated service area.

OPOs have two major roles in their service area. They are responsible for:

• Increasing the number of registered donors. To encourage donor sign-ups, OPOs may reach out to communities by: sponsoring advertising campaigns; organizing programs in schools, worksites, or faith institutions; sharing print and electronic materials, and more.

• Coordinating the donation process. When donors become available, representatives from the OPO will evaluate the potential donors, check the deceased’s state donor registry, discuss donation with family members, contact the OPTN computer system that matches

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donors and recipients, obtain a match list for that specific donor, and arrange for the recovery and transport of donated organs. They also provide bereavement support for donor families and volunteer opportunities for interested individuals.

OPOs employ a variety of staff including procurement coordinators, requestors, donor family specialists, and professionals in public relations communications, and health education, as well as administrative personnel.

For more information:http://organdonor.gov/awareness/organizations/local-opo.html

Programs of All-Inclusive Care for the Elderly (PACE) (Outpatient)

CMS defines the PACE program as an innovative model that provides a range of integrated preventative, acute care, and long-term care services to manage the often complex medical, functional, and social needs of the frail elderly. PACE was created as a way to meet a person’s health care needs while allowing them to continue living safely in the community. PACE is a prepaid, capitated, comprehensive health care program.

For more information:https://www.medicare.gov/your-medicare-costs/help-payingcosts/ pace/pace.html.

Psychiatric Residential Treatment Facilities (PRTFs) (Inpatient)

A PRTF is any non-hospital facility with a provider agreement with a

State Medicaid Agency to provide the inpatient services benefit to Medicaid-eligible individuals under the age of 21 (“psych under 21 benefit”). The facility must be accredited by the Joint Commission or any other accrediting organization with comparable standards recognized by the state.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and- Certification/CertificationandComplianc/PRTFs.html

Religious Nonmedical Health Care Institutions (RNHCIs) (Inpatient)

CMS defines RNHCIs as tax-exempted religious organizations that provide nonmedical nursing items and services to beneficiaries who choose to rely solely upon a religious method of healing, and for whom the acceptance of medical services would be inconsistent with their religious beliefs. RNHCIs furnish nonmedical items and services exclusively through nonmedical nursing personnel who are experienced in caring for the physical needs of nonmedical patients (e.g., assistance with activities of daily living; assistance in moving, positioning, and ambulation, nutritional needs and comfort and support measures). They also furnish nonmedical items and services to inpatients on a 24-hour basis. They do not furnish patients, on the basis of religious beliefs, through its personnel or otherwise, medical items and services (including any medical screening, examination, diagnosis, prognosis, treatment, or the administration of drugs).

For more information:https://www.cms.gov/Medicare/

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Provider-Enrollment-and-Certification/CertificationandComplianc/RNHCIs.html

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) (Outpatient)

An RHC is located in a rural area designated as a shortage area, is not a rehabilitation agency or a facility primarily for the care and treatment of mental diseases, and meets all other requirements of 42 CFR 405 and 491.

FQHCs must serve an underserved area or population, offer a sliding fee scale, provide comprehensive services, have an ongoing quality assurance program, and have a governing board of directors. Certain tribal organizations and FQHC Look-Alikes (an organization that meets PHS Section 330 eligibility requirements, but does not receive Health Center Program grant funding) also may receive special Medicare and Medicaid reimbursement.

For more information:• http://bphc.hrsa.gov/about/what-is-a-health-center/index.html• https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/fqhcfactsheet.pdf

Transplant Centers (Inpatient)

CMS defines a transplant center as a component within a transplant hospital that provides transplantation of a particular type of organ.

Types of organ transplant programs:• Heart• Lung• Heart/lung - The program must

be located in a hospital with and existing Medicareapproved heart and Medicare-approved lung program.

• Liver• Intestine - The program must

be located in a hospital with a Medicare-approved liver program. This program includes multivisceral and combined liver-intestine transplants

• Kidney• Pancreas - The program must

be located in a hospital with a Medicare-approved kidney program. This program includes combined kidney/pancreas transplants.

All organ transplant programs must be located in a hospital that has a Medicare provider agreement.

For more information:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Transplant-Laws-and-Regulations.html

EVERBRIDGE HEALTHCARECUSTOMER USE CASES

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Victoria O’Neal,Promise Regional Medical Center - Hutchinson

Victoria O’Neal knows that every minute counts when acute heart attack victims arrive at Promise Regional Medical Center’s emergency room. With a STEMI, a few minutes can make the difference between recovery and death; there’s no room for communication mistakes or delays.

As the telecommunications manager for Promise Regional Medical Center, a notfor- profit 200-licensed bed medical facility serving more than 65,000 individuals each year, O’Neal is constantly making communication improvements across the hospital to advance patient safety by getting patients life-saving treatment more quickly, increasing efficiency and productivity, and supporting the facility’s Joint Commission accreditation initiative.

Expert Insights: Promise Regional Medical Center

For a STEMI patient, a few minutes can mean

the difference between recovery and death. With Everbridge Aware, patients receive treatment faster.

Everbridge is revolutionizing the way we communicate across the hospital.

Victoria O’NealTelecommunications Manager

Promise Regional Medical Center

Faster STEMI Alerts: When Time is the Enemy

A STEMI is an acute heart attack that deprives the heart of blood and oxygen, leading to irreversible heart damage or death if not treated within hours of the onset of symptoms. The American Board of Cardiology recommends a 90-minute door-to-balloon window for treating a STEMI patient – no small feat for any hospital. O’Neal relies on Everbridge Aware for Hospitals to close the communication gap and get patients the lifesaving treatment they need more quickly.

Promise Regional Medical Center has seen its cardiology caseload increase by 64% over the last decade and has earned a reputation as one of the best cardiac care centers in Kansas. Unfortunately, the communications technology had not kept pace, and Promise previously used a group pager system to issue STEMI alerts. STEMI alerts notify the hospital’s highly skilled healthcare team—from emergency room personnel to cardiac catheterization laboratory technicians to cardiologists— of the urgent need to stabilize a patient and begin moving the patient rapidly toward recovery. An operator in the hospital’s communications center manually contacted and tracked time required to reach the cardiologist, cardiologist response time, team activation, and team response time. Due to the one-way nature of the

pager system, operators did not have complete visibility into communication effectiveness and had to wait for the cardiologist and team to call back to confirm. If there was no response within five minutes, the operator began calling team members one by one, a manual and time-consuming process, especially when the clock is ticking with a STEMI alert. Further complicating the matter, operators needed to balance STEMI alerts with competing priorities in the communications center, which is responsible for manning the hospital’s 500-subscriber LifeLine monitoring program; physician answering service; medical, maintenance, and security incident response center; as well as perform switchboard duties.Everbridge Aware dramatically cuts the time it takes to contact the STEMI team and, with robust confirmation and reporting capabilities, removes the guesswork in team response. The result: critical heart attack patients receive life-saving treatment much more quickly, improving odds of survival and recovery.

Thinking Big Picture

O’Neal didn’t stop at improving the speed and effectiveness of STEMI alerts; she recognized many areas for communication improvement across the hospital using Everbridge Aware. Callbacks were draining the hospital’s outdated telephone system and paging and sending email as text messages proved very difficult to track and audit.

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In addition to emergency notifications and management conference calls, Everbridge Aware provides Promise Regional Medical Center with an audit trail that demonstrates compliance in daily processes, such as communications with physicians about surgery start times and consultation requests. Trauma services can use Everbridge Aware to gather data about team.. and cardiac catheterization lab activations. Security uses polling and escalation to call in more security staff and message the security chief, officers, and county dispatch as needed. The nursing staff is also putting a program in place to leverage the Everbridge system for shift-specific staff callbacks, which are currently done manually in each nursing area.

With Everbridge Aware, Promise Regional Medical Center’s communications department can participate more fully in patient safety via faster response times and faster notification of first responders. The hospital is also bringing together disparate contact information sources to incorporate more contact paths beyond home address and phone number stored in the hospital’s payroll system, the system of record that provides the data for Everbridge Aware.

According to O’Neal, “With the current economic...environment and Medicare reimbursement dwindling, Promise Regional Medical Center is constantly looking for ways to reduce expenses while improving the level of care and safety we provide to our patients with an exceptional experience of care, every time, in every interaction. Everbridge Aware replaces four other tools by streamlining and centralizing processes. It’s fantastic.”

Support From the Top Down

At Promise Regional Medical Center, support for open communication flows from the top down. The hospital’s president and chief executive officer, Linda Harrison, announced the hospital’s rollout of Everbridge Aware during its biannual all-employees meeting. Harrison doesn’t want any employees to be surprised by what they read in the papers. To that end, she made a commitment to use Everbridge Aware to keep the hospital’s 1,200 employees apprised of all situations before the news goes to the media.

Peer-to-Peer: Victoria’s Advice

• Get creative. Think about all the ways you can apply the Everbridge system to operations, from emergency preparedness all the way down the line to patient safety and internal communications. The Everbridge system brings something to the table for everyone.

• Explain the benefits of the Everbridge system to employees and anyone else you will be contacting. By familiarizing them with what you’re trying to accomplish, why, and how, you will get more buy-in and achieve better results.

• Update your emergency preparedness manual to include Everbridge in every disaster protocol. Translate communication processes directly to elements of performance for Joint Commission.

• Use filters and attributes to help you target communications. Specifying job classifications (such as RN and LPN), shifts, and special skills make it faster and easier to reach the right people quickly.

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ABOUT EVERBRIDGE

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Everbridge, Inc. (NASDAQ: EVBG) is a global software company that provides critical event management and enterprise safety applications that enable customers to automate and accelerate the process of keeping people safe and businesses running during critical events. During public safety threats such as active shooter situations, terrorist attacks or severe weather conditions, as well as critical business events such as IT outages or cyber incidents, over 3,000 global customers rely on the company’s SaaS-based platform to quickly and reliably construct and deliver contextual notifications to millions of people at one time. The company’s platform sent over 1.5 billion messages in 2016, and offers the ability to reach more than

200 countries and territories with secure delivery to over 100 different communication devices. The company’s critical communications and enterprise safety applications, which include Mass Notification, Incident Management, IT Alerting, Safety Connection™, Community Engagement™, Secure Messaging and Internet of Things, are easy-to-use and deploy, secure, highly scalable and reliable. Everbridge serves 8 of the 10 largest U.S. cities, 8 of the 10 largest U.S.-based investment banks, all four of the largest global accounting firms, 24 of the 25 busiest North American airports and 6 of the 10 largest global automakers. Everbridge is based in Boston and Los Angeles with additional offices in San Francisco, Lansing, Beijing, London and Stockholm.

Visit www.everbridge.com to learn more.

About Everbridge

Everbridge, Inc. (NASDAQ: EVBG), is a global software company that provides critical communications and enterprise safety applications that enable customers to automate and accelerate the process of keeping people safe and businesses running during critical events. Everbridge is based in Boston and Los Angeles with additional offices in San Francisco, Beijing and London.

CMS Emergency Preparedness Booklet

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