Jun 6, 2018
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Joint Commission issues advisory on continuity of operations planning

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On May 22, 2018, the Joint Commission released an advisory addressing the importance of continuity of operations planning (COOP).  When an emergency strikes, an ill-prepared health care organization can put patients at risk.  The goal of an COOP is “to protect the organization’s physical plant, information technology systems, business and financial operations, and other infrastructure from direct disruption or damage so that it can continue to function throughout or shortly after an emergency.”

The Joint Commission found that accredited entities need to address COOP in order to be more resilient in the face of an emergency or disaster.  In September 2016 the Centers for Medicare & Medicaid Services (CMS) published the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers final rule.  The final rule established national emergency preparedness requirements.  Health care providers and suppliers had to implement the new requirements by November 15, 2017.

The advisory states that COOP “is a significant concern in community-based settings as well as inpatient settings”.   The Joint Commission suggests the following best practices:

  • Continuity of facilities and communications to support organizational functions.
  • A succession plan that lists who replaces the key leader(s) during an emergency if the leader is not available to carry out his or her duties.
  • A delegation of authority plan that describes the decisions and policies that can be implemented by authorized successors.

In addition, the advisory offers six safety actions for health care organizations when implementing COOP:

(1) Succession and delegations – The designation of successor individuals for key positions and the delegation of authority for specific purposes and duties.

(2) Essential functions – Identifying the essential functions capabilities and assets necessary for the organization to survive a disaster.  A chart containing the essential functions in continuity of operations planning is available here.

(3) Mitigation – Prioritizing risks and determining the appropriate investments for implementing mitigation activities.  The Joint Commission notes that mitigation priorities should be considered in the context of prioritized risk and the organization’s role in community response and recovery.  This includes notifications to patients about alternative sources of care, securing equipment and supplies, and ensuring staff compensation while the organization is closed.

(4) Communications – Establishing redundancy in case primary communications systems are compromised, such as the staff reporting hierarchy; communication with the incident command structure; communicating with providers and suppliers; and coordinating patient visits.

(5) Recovery – Determining the organization’s essential functions, capabilities and assets; digitizing paper assets and treatment records; ensuring a flexible workforce according to the needs of the organization during the transition from response to recovery; coordinating with local emergency management, service providers, and contractors to prioritize the restoration and reconstruction of critical building systems and information technology and communications systems.

(6) Alternate Care Sites – Consideration should be given to the types of services that would be offered at alternative care sites including, but not limited to: how the site would be staffed; supplies, transportation, and communication; and the regulatory requirements.

The advisory closes by providing several items “integral” to the recommended safety actions, including processes for medical and non-medical supplies and managing its supply chain; alternative means to provide critical utility systems; evacuation procedures to protect physical infrastructure, space, and equipment; addressing changes in workforce levels; and ensuring the COOPs have been tested in real-world situations.

Additional information about the CMS requirements for Emergency Preparedness can be found here.

The post Joint Commission issues advisory on continuity of operations planning appeared first on Health Law Pulse.



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