Community Mental Health Centers
A community mental health center (CMHC) is an outpatient organization that provides partial hospitalization services to Medicare beneficiaries for mental health services. It is estimated that there are about 100 CMHCs that provide partial hospitalization services through Medicare that are affected by the CMS Emergency Preparedness Rule. There are no CMHCs in Nashua according to the CMS definition.
Before going any farther, make sure your organization has developed a site-specific Hazard Vulnerability Assessment. Use the hazards that make your facility most vulnerable to narrow in on important planning considerations.
Community Mental Health Centers are required to develop an emergency preparedness plan that is reviewed and updated at least annually.
The plan must be based on and include a documented facility-based risk assessment, which should have been completed in Step 1: Assess Vulnerability.
The emergency preparedness plan must include strategies for addressing emergency events identified by the risk assessment and address the facility's client population, including the type of services the Community Mental Health Center has the ability to provide in an emergency and continuity of operations. Continuity of Operations should also include delegations of authority and succession plans.
A process for cooperation and collaboration with local, regional, state, and federal emergency preparedness officials' efforts to maintain an integrated response during a disaster or emergency situation, including efforts of the CMHC to contact the officials and its participation in collaborative and cooperative planning efforts also needs to be included in the emergency preparedness plan.
Policies and Procedures
Policies and procedures should be developed and implemented based on the emergency plan, risk assessment, and communication plan. At a minimum, the policies and procedures must do the following:
- Detail a system to track the location of on-duty staff and sheltered clients in the CMHC's care during and after an emergency. If on-duty staff or sheltered clients are relocated during the emergency, the CMHC must document the specific name and location of the receiving facility or other location.
- Provide safe evacuation from the CMHC, which includes consideration of care and treatment needs of evacuees; staff responsibilities; transportation; identification of evacuation location(s); and primary and alternate means of communication with external sources of assistance.
- Identify a means to shelter in place for clients, staff, and volunteers who remain in the facility.
- Detail a system of medical documentation that preserves client information, protects confidentiality of client information, and secures and maintains the availability of records.
- Define the use of volunteers in an emergency or other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.
- Allow for the development of arrangements with other CMHCs or other providers to receive clients in the event of limitations or cessation of operations to maintain the continuity of services to CMHC clients.
- Outline the role of the CMHC under a waiver declared by the Secretary Health and Human Services, in accordance with section 1135 of the Social Security Act, in the provision of care and treatment at an alternate care site identified by emergency management officials.
CMHCs must develop and maintain an emergency preparedness communication plan that complies with Federal, State, and local laws and must be reviewed and updated at least annually.
The communication plan must include:
- Names and contact information for staff, entities providing services under arrangement, client's physicians, other CMHCs, and volunteers.
- Contact information for federal, state, regional, and local emergency preparedness staff and other sources of assistance.
- Primary and alternate means of communicating with CMHC's staff and federal, state, regional, and local emergency management agencies.
- A method for sharing information and medical documentation for clients under the CMHC's care, as necessary, with other health care providers to maintain the continuity of care.
- A means, in the event of an evacuation, to release patient information as permitted under 45 CFR 164.510(b)(1)(ii).
- A means of providing information about the general condition and location of clients under the facility’s care as permitted under 45 CFR 164.510(b)(4).
- A means of providing information about the CMHC's needs, and its ability to provide assistance, to the authority having jurisdiction or the Incident Command Center, or designee.
Training and Testing
Community Mental Health Centers must develop and maintain an emergency preparedness training and testing program that is based on the emergency plan, risk assessment, policies and procedures, and the communication plan. The training and testing program must be reviewed and updated at least annually.
Facilities are required to conduct a exercises to test the emergency plan annually.
The facility must participate in a full-scale exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based exercise. If the facility experiences an actual natural or man-made emergency that requires activation of the emergency plan, the facility is exempt from engaging in a community-based or individual, facility-based full-scale exercise for 1 year following the onset of the actual event.
The additional exercise may be a second full-scale exercise that is either community-based or facility-based or a tabletop exercise that challenges the facility's emergency plan.
CMHCs are required to analyze the facility's response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise their emergency plan, as needed.