Our hearts go out to the many people affected by the recent dangerous and deadly tornadoes in Kentucky, Illinois, Missouri and Arkansas. It seems as if there isn’t a region of the United States – or the world – that hasn’t been impacted by extreme weather events during the past few years. Power outages and cybersecurity are also issues for all of us. Is your practice prepared for these emergencies? Not only is it a good idea to put an emergency plan in place, it’s required if you participate in the Medicare or Medicaid programs. But where should your allergy practice begin?
According to the Centers for Medicare and Medicaid Services (CMS), there are four provisions you’re required to comply with as part of your emergency preparedness plan:
- Risk assessment and planning
- Policies and procedures
- Communication plan
- Training and testing program
Get an overview of the requirements in CMS’ presentation on the Emergency Preparedness Rule, which outlines the rule that became effective on Nov. 16, 2016. Please note CMS released revised guidance on March 26, 2021 in conjunction with the Burden Reduction rule in 2019. Here are some key steps to put an emergency plan in place.
1. Identify the threats to your practice – Based on your geographic location, create a list of disasters you might face (floods, fires, hurricanes, etc.). Also consider emergencies not based on location, such as cyberattacks, power outages, etc.
2. Gather key contacts and practice information.
Create an emergency packet with key information and keep secure copies both on-site and off-site. Include:
a. List of employees and contact information.
b. List of vendors and contact information.
c. List of federal, state and local emergency contacts.
d. Copy of business insurance policies, including business interruption, flood, hurricane, etc. as applicable. This might be a good time to review your insurance coverage. Make sure it is sufficient and that it provides replacement, rather than cash value, coverage. Also, consider interruption of business insurance coverage.
e. Current inventory of practice property and equipment.
3. Create emergency plans.
a. Develop written plans for each potential threat. Determine when and how to close the practice, and be sure to include steps like cancelling appointments and notifying patients.
b. Make an emergency communications plan to maintain communications with employees and patients. Consider the role social media could play in emergency communications.
c. Create a plan to access critical business and patient data systems – both on-site and off. Determine how you will protect key equipment, such as computers, servers and other expensive items. Consider using cloud storage for data backup, which may enable you to get up and running faster than regular offsite data storage.
d. Investigate options for protecting allergy extract and medications, particularly expensive biologics.
e. Evaluate how to access and protect any paper records.
4. Make emergency plans accessible and perform drills – Even the best plan isn’t effective if your team doesn’t know how to use it or can’t find it during an emergency. Make sure it’s easily accessible and that all staff members know how to implement it. Train staff at least annually and perform drills (real or virtually) to ensure all staff know what to do and to evaluate the plan’s effectiveness.
Don’t get caught off guard by natural disasters or other emergencies. Make sure your allergy practice is prepared by putting emergency plans in place now, in the calm before the storm.