Home Health Care

A Home Health Agency (HHA) is primarily engaged in providing skilled nursing services and other therapeutic services to patients. HHAs policies are established by a group of professionals (associated with the agency or organization), including one or more physicians and one or more registered professional nurses, to govern the services which it provides. HHAs provide for supervision of above-mentioned services by a physician or registered professional nurse, are licensed pursuant to State or local law, or have approval as meeting the standards established for licensing by the State or locality. HHAs must also meet the federal requirements in the interest of the health and safety of individuals they serve. The term “home health agency” does not include any agency or organization which is primarily for the care and treatment of people with mental illness.

Licensed Home Health Agencies in the State of New Hampshire also must comply with the He-P 809 Administrative Rules for Home Health Care Providers or He-P 822 Home Care Service Providers. He-P 804 Assisted Living Residence -Residential Care Licensing providers are also included in this cohort.

Emergency Operations Plan

The Home Health Agency 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 HHA 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, tribal, regional, State, and Federal emergency preparedness officials’ efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the HHA's efforts to contact such officials and, when applicable, its participation in collaborative and cooperative planning efforts.

Policies and Procedures

Home Health Agencies are also required to develop and update policies and procedures based on the HVA, Emergency operations Plan, 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:

• Plans for the HHA's patients during a natural or man-made disaster. Individual plans for each patient must be included as part of the comprehensive patient assessment
• Procedures to inform state and local emergency preparedness officials about HHA patients in need of evacuation from their residences at any time due to an emergency situation based on the patient's medical and psychiatric condition and home environment.
• Procedures to follow up with on-duty staff and patients to determine services that are needed, in the event that there is an interruption in services during or due to an emergency. The HHA must inform the state and local officials of any on-duty staff or patients that they are unable to contact.
• 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

The communication plan is required to be updated annually and must include all of the following:

• Names and contact information for staff, entities providing services under arrangement, patients’ physicians, 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 the HHA's staff, Federal, State, tribal, regional, and local emergency management agencies.
• A method for sharing information and medical documentation for patients under the HHA's care, as necessary, with other health care providers to maintain the continuity of care.
• A means of providing information about the general condition and location of patients under the facility’s care
• A means of providing information about the HHA'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

HHAs must provide initial and annual 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 documented testing of the emergency plan at least twice, annually. 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 individual, 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.

It is important to note that the exercises need to test at least one component of the emergency plan, an evaluation or analysis of the test needs to be conducted, and the exercise and analysis need to be documented.

Additional Resources

The National Association for Home Care & Hospice has developed an Emergency Preparedness Packet. Even though this resource was developed prior to the CMS Emergency Preparedness Rule, it contains good information and resources for Home Care and Hospice providers, such as information on HVAs, preparedness assessments, the Incident Command System, Business Continuity Planning, and Memorandums of Understanding.