U.S. Health Care Facilities Have Duty to Plan for Disasters

Patient Expert

Please allow me to flashback to 2005. I'm in the doctor's office waiting room with my mother. We are watching the television in horror as New Orleans and other parts of the South are flooded in the aftermath of Hurricane Katrina. We see footage of the hospitals that can no longer serve patients because the generators have gone down.

At that time, I was trying to find a place for my mother (who was experiencing memory loss, but who didn't have a formal diagnosis of Alzheimer's quite yet). However, the various retirement communities in my area were filled up with Hurricane Katrina evacuees. Those were the lucky ones who were able to get out of that hard-hit region. That meant my mother was staying with me, for the moment.

About two weeks later, I realized that there was something really wrong with my mother's mental state. After she was hospitalized for heart issues in the city where I lived, my family was faced with a decision about where to send Mom so she could have a geriatric psychiatric evaluation to see if she had Alzheimer's disease. There wasn't a health care facility in my area that could do this evaluation, so the choices we were given were facilities in Houston, Austin and West Texas. We opted for Austin because of family and friends who lived there.

That proved to be a fortuitous decision. Just a few days later, another hurricane - Hurricane Rita - was bearing down toward Houston. All of the interstates out of Houston turned into parking lots prior to the storm's arrival. And then there was the terrible situation when 24 evacuees from a Houston-area nursing home died when the bus they were on caught fire near Dallas. The especially sad part of that situation was that the evacuation of that particular nursing home wasn't mandatory.

These memories underscore for me the importance of emergency preparedness for health care facilities, such as nursing homes and hospitals, that serve elders. I saw the news stories where families didn't know where their elders had been moved. I watched the horror stories where generators went out, thus preventing life-saving machinery, such as kidney dialysis machines, to function.

Fast forward to 2014. The Centers for Medicare and Medicaid Services have proposed a new rule that is intended to ensure the readiness of United States health care facilities, including large hospitals and small group homes, during times of disaster. These proposals are designed to encourage the nation's 68,000-plus health care facilities to make appropriate decisions so they can care for their patients during a crisis. "This proposed rule addresses the three key essentials needed to ensure that health care is available during emergencies: safeguarding human resources, ensuring business continuity, and protecting physical resources," the Centers for Medicare and Medicaid Services stated, adding that these proposals are designed to meet the needs of patients and residents in times of disasters and emergencies. Following the conditions set down in this rule would be required in order to participate in Medicare and Medicaid. However, the New York Times reports that some health care providers are balking at the costs, which could reach approximately $225 million.

So let's look at what the major provisions of the new rule entail:

  • Conducting a risk assessment using an "all-hazards" approach prior to establishing the emergency plan. This type of approach would look at the facility's capacities and capabilities based on the type of hazards that are most probable. Personally, I think a risk assessment based on an individual facility makes a whole lot of sense For instance, a facility in Corpus Christi, Texas probably won't be worried about the risk of a blizzard; instead, its focus will definitely include hurricane preparedness. In comparison, a facility in Seattle, WA might include a risk assessment based on the possibility that Mt. Rainier might erupt at some point whereas a facility in Memphis, TN might include an assessment based on the possibility of an earthquake.
  • Development and implementation of policies and procedures based on the emergency plan and risk assessment. While there may be many similarities between the scenarios listed above, there are bound to be some differences that need to be. For instance, procedures need to be in place for the Corpus facility since with modern weather forecasting, enough time may be given to make evacuation a possibility in the event of a Category 5 hurricane. In comparison, an earthquake in Memphis probably would happen without advance notice, thus limiting evacuation options prior to the event. Thus, a facility in this area would need different procedures.
  • The development of an emergency preparedness communications plan that is compliance with federal and state law.
  • The development of a training and testing program related to emergency preparedness. Hospitals would be required to conduct annual tests of backup generators; currently, they do this every three years.

This planning process is pretty comprehensive in that it not only takes into account staff, but creates contingency plans for key systems, including temperature, lighting, waste disposal and fire safety systems.

Does this requirement make sense? I definitely think so. Having been involved in organizational crisis planning before, I know that developing a thorough plan that takes into account all the realistic possibilities is step one. So I think it's the professional responsibility of the top officials at all health care facilities to develop this plan.

So is the plan too costly? I would point to the cost of the settlement awarded to the families of those 23 Houston-area nursing home residents who died on that bus -- $80 million. Therefore, I'd suggest that regularly going through this type of disaster planning and testing will actually be a bargain in the long term.   And quite frankly, each of those 23 lives lost should be considered priceless.

Primary Sources for This Sharepost:

Budryk, Z. (2014). Hospitals push back against proposed disaster plan regs. Fierce Healthcare.

Fink, S. (2014). Citing urgent need, U.S. calls on hospitals to hone disaster plans. New York Times.

Langford, T. (2009). Settlement over Hurricane Rita bus fire brings closure. Houston Chronicle.

U.S. Federal Register. (2013). Medicare and Medicaid programs: emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers.