A critical element of the legally-required emergency preparedness procedures at all skilled nursing or long-term care facilities also includes a comprehensive communication plan, which must be devised in such a way that the facility can continue to run effectively.
This is a far harder task than it sounds, because it means not only the preparation of physical means of communication under emergency situations, but also the transfer and confidential handling of patient records and data—which in turn is required under Health Insurance Portability and Accountability (HIPAA) compliance regulations.
The first element is to ensure that there is a means to communicate effectively and quickly with state and local public health departments and emergency systems. An SNF cannot afford to be cut off from important updates or rescue units, as this can have catastrophic consequences for staff, patients—and the long-term viability of the institution itself.
The communication plan must detail how all appropriate staff, patients’ treating physicians, and other necessary persons, can be contacted in a timely manner to ensure continuation of patient care functions throughout the facility and to ensure that these functions are carried out in a safe and effective manner.
In addition, providers and suppliers are expected to have contact information for federal, state, tribal, regional, or local emergency preparedness institutions.
Significantly, SNFs are also expected to have what are called “primary and alternate means” for communicating with staff and federal, state, tribal, regional, or local emergency management agencies. This means that a facility cannot rely solely on a telephone system—which might go down under extreme emergencies—and must have other methods such as two-way radios, shortwave transmitters, etc.
A facility is also expected to have a means of providing information about the hospital’s occupancy, needs, and its ability to provide assistance, to the authority having jurisdiction in an emergency.
Finally, the communication plan must involve detailed procedures for sharing patients’ information and medical documentation with other healthcare facilities to ensure continuity of care—all the while ensuring that all HIPAA regulations are adhered to.
This information release plan must also allow for the dissemination—as permitted by law—of details to family members, particularly by facilities which provide continuous care and have oversight over those receiving services at home.
The Federal Government’s Final Rule on SNF emergency preparedness demands that all aspects of this communication plan be reviewed and updated at least every twelve months.
A failure to do so can result in financial penalties and even disbarment from the Medicaid/Medicare program—which means that all these procedures are not to be taken lightly by any professional institution.
