Federally Qualified Health Centers

Federally Qualified Health Centers (FQHCs) must serve an underserved area or population, offer a sliding fee scale, provide comprehensive services, have an ongoing quality assurance program, and have a governing board of directors. Certain FQHC Look-Alikes (an organization that meets PHS Section 330 eligibility requirements, but does not receive Health Center Program grant funding) also may receive special Medicare and Medicaid reimbursement.

Emergency Operations Plan

FQHCs must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must:

• Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.
• Include strategies for addressing emergency events identified by the risk assessment.
• Address patient population, including, but not limited to, the type of services the RHC/FQHC has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
• Include 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 documentation of the FQHC’s efforts to contact such officials and its participation in collaborative and cooperative planning efforts.

Policies and Procedures

The FQHC must develop and implement emergency preparedness policies and procedures, based on the emergency plan, risk assessment, and the communication plan (see below). The policies and procedures must be reviewed and updated at least annually. At a minimum, the policies and procedures must address the following:

• Safe evacuation from the FQHC, (including appropriate placement of exit signs; staff responsibilities and needs of the patients).
• A means to shelter in place for patients, staff, and volunteers who remain in the facility.
• A system of medical documentation that preserves patient information, protects confidentiality of patient information, and secures and maintains the availability of records.
• 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.

Communications Plan

Facilities are also required to develop and maintain an emergency preparedness communication plan that complies with federal, state, and local laws that is reviewed and updated at least annually.

Communications plans must include all of the following:

1. Names and contact information for the following: staff, entities providing services under arrangement, patients’ physicians, other FQHCs, and volunteers.
2. Contact information for the following:
   • Federal, State, regional, and local emergency preparedness staff.
   • Other sources of assistance.
3. Primary and alternate means of communicating with FQHC’s staff and federal, state, regional, and local emergency management agencies.
4. A means of providing information about the general condition and location of patients under the facility’s care.
5. A means of providing information about the FQHC’s needs, and its ability to provide assistance, to the authority having jurisdiction or the Incident Command Center.

Training and Testing

There are two sections that apply to the Training and Testing component of the Emergency Preparedness Program. One section covers internal training, and the other external or community exercises and drills.

Training

Annually, all facilities must provide training in emergency preparedness policies and procedures to all new and existing staff, individuals providing on-site services under arrangement, and volunteers. The training must demonstrate staff knowledge of emergency procedures, and the training must be documented.

Testing

The facility is required to conduct testing of the emergency plan at least twice, annually. An analysis of the emergency plan should be conducted after all exercises and events and must be documented. Revisions to the emergency operations plan should be made based on findings from the annual exercises and emergency events.

One of the exercises can be a functional exercise that is community-based (involves more than just the facility), or an individual, facility-based exercise if a community-based exercise opportunity is not available. If the facility experiences an actual emergency that requires the activation of the emergency plan, the facility is exempt from engaging in a community-based or facility-based functional exercise for one year following the event.

The second exercise could include a second functional exercise that is community-based or facility based. However, it can also be a tabletop exercise that includes group discussion led by a facilitator using a narrated, clinically-relevant emergency scenario, a set of problem statements, direct messages, or prepared questions that are designed to challenge an emergency plan.