A hospice is a public agency, private organization, or a subdivision that: is primarily engaged in providing care to terminally ill individuals (individuals that have been certified as being terminally ill as per CMS requirements and entitled to Part A of Medicare); meets the conditions of participation for hospices; and has a valid Medicare provider agreement. Hospice care is a comprehensive set of services identified and coordinated by an interdisciplinary group to provide for the physical, psychosocial, spiritual, and emotional needs of a terminally ill patient and/or family members, as delineated in a specific patient plan of care.
Hospice services can also be provided in facilities, such as those located as a part of a hospital, nursing home, or residential facility, or as a freestanding hospice inpatient facility. All hospices must meet specific federal requirements and be separately certified and approved for Medicare participation.
Facilities in the State of New Hampshire that are licensed as a Hospice House are also required to comply with the He-P 824 Hospice House Administrative Rules. Likewise, faciltiies licensed as Home Hospice Care Providers are required to follow the Administrative Rules for He-P 823.
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.
The Wisconsin Department of Health Services has created a toolkit for Hospices. If your facility does not already have a plan in place, this would be a good place to start. This toolkit offers an overview of the requirements for HHAs, as well as some sample templates that can be used in their planning efforts. In topic areas where there was not a tool or template readily available, the toolkit offers planning worksheets that feature a list of example questions to help facilities think through relevant issues that can help them draft their plans and policies.
Emergency Operations Plan
Just like other facilities affected by CMS requirements, Hospices are also required to have an all-hazards Emergency Operations Plan (EOP). This plan must be reviewed and updated annually. The EOP 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, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice’s ability to provide care.
- Address patient population, including, but not limited to, the type of services the hospice 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, or federal emergency preparedness officials’ efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the hospice's efforts to contact such officials and, when applicable, its participation in collaborative and cooperative planning efforts.
Policies and Procedures
Along with an all-hazards Emergency Operations Plan, hospices are required to develop and implement policies and procedures relevant to the HVA, EOP, and the Communications Plan (see below). These policies and procedures are required to be reviewed and updated annually.
At a minimum, the policies and procedures must address the following:
- 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 hospice must inform State and local officials of any on-duty staff or patients that they are unable to contact.
- Procedures to inform State and local officials about hospice 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.
- 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 hospice employees in an emergency and 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.
- The development of arrangements with other hospices and other providers to receive patients in the event of limitations or cessation of operations to maintain the continuity of services to hospice patients.
The facility must also develop and maintain a Communications Plan that complies with federal, state, and local laws and must be reviewed and updated at least annually.
The communication plan must include all of the following:
- Names and contact information for hospice employees, entities providing services under arrangement, patients’ physicians, and other hospices.
- Contact information for federal, state, regional, and local emergency preparedness staff, and other sources of assistance.
- Primary and alternate means of communicating with hospice's employees, and federal, state, regional, and local emergency management agencies.
- A method for sharing information and medical documentation for patients under the hospice'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 patients under the facility’s care as permitted under 45 CFR 164.510(b)(4).
- A means of providing information about the hospice's inpatient occupancy needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.
The following are additional requirements for inpatient hospice care facilities only.
The policies and procedures must address the following:
- A means to shelter in place for patients, hospice employees who remain in the hospice.
- Safe evacuation from the hospice, 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.
- The provision of subsistence needs for hospice employees and patients, whether they evacuate or shelter in place, include, but are not limited to the following:
- Food, water, medical, and pharmaceutical supplies.
- Alternate sources of energy to maintain the following:
- Temperatures to protect patient health and safety and for the safe and sanitary storage of provisions.
- Emergency lighting.
- Fire detection, extinguishing, and alarm systems.
- Sewage and waste disposal.
- The role of the hospice under a waiver declared by the Secretary, in accordance with section 1135 of the Act, in the provision of care and treatment at an alternate care site identified by emergency management officials.
- A system to track the location of hospice employees’ on-duty and sheltered patients in the hospice’s care during an emergency. If the on-duty employees or sheltered patients are relocated during the emergency, the hospice must document the specific name and location of the receiving facility or other location.
Training and Testing
The hospice must do all of the following:
- Initial training in emergency preparedness policies and procedures to all new and existing hospice employees, and individuals providing services under arrangement, consistent with their expected roles.
- Demonstrate staff knowledge of emergency procedures.
- Provide emergency preparedness training at least annually.
- Periodically review and rehearse its emergency preparedness plan with hospice employees (including non-employee staff), with special emphasis placed on carrying out the procedures necessary to protect patients and others.
- Maintain documentation of all emergency preparedness training.
The hospice must conduct exercises to test the emergency plan at least annually. The hospice must do the following:
- Participate in a functional exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based. If the hospice experiences an actual natural or man-made emergency that requires activation of the emergency plan, the hospice 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.
- Conduct an additional exercise that may include, but is not limited to the following:
- A second full-scale exercise that is community-based or individual, facility-based.
- A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
- Analyze the hospice's response to and maintain documentation of all drills, tabletop exercises, and emergency events and revise the hospice's emergency plan, as needed.
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.