Out-Patient Rehabilitation, Public Health Agencies, and Clinics
A rehabilitation agency is an agency that provides an integrated, multi-disciplinary program designed to upgrade the physical functions of handicapped, disabled individuals by bringing together, as a team, specialized rehabilitation personnel.
A clinic is a facility established primarily for the provision of outpatient physicians' services. To meet the definition of a clinic, the facility must meet the following test of physician participation:
- The medical services of the clinic are provided by a group of three or more physicians practicing medicine together, and
- A physician is present in the clinic at all times during the hours of operation to perform medical services (rather than only administrative services).
A public health agency is an official agency established by a state or local government, the primary function of which is to maintain the health of the population served by providing environmental health services, preventive medical services, and in certain instances, therapeutic services.
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 Out Patient Rehabilitation facilities, including clinics and public health agencies as providers of outpatient physical therapy and speech-language pathology services. 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 OPRs, 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.
These facilities 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. It must also include strategies for addressing emergency events identified by the risk assessment, address patient population, including, but not limited to, the type of services the facility has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
Facility EOPs must also address the location and use of alarm systems and signals and methods of containing fire. There must also be 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.
Facilities in this category should develop their emergency operations plan and maintain it with assistance from fire, safety, and other appropriate experts.
Policies and Procedures
Policies and procedures should be developed and maintained based on the risk assessment, emergency operations plan, and communication plan. Policies and procedures must be reviewed and updated annually.
Facilities should have policies and procedures in place for the following:
- Safe evacuation from the facility, which includes 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.
Facilities in this category are not required to track staff or patients.
Outpatient rehabilitation, clinics, and public health agencies 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.
At a minimum, the Communication Plan must include:
- Names and contact information for staff, entities providing services under arrangement, patients’ physicians, other OPT, Clinics, PHAs, and volunteers.
- Contact information for federal, State, tribal, regional, and local emergency preparedness staff, and other sources of assistance.
- Primary and alternate means of communicating with staff and federal, state, tribal, regional, and local emergency management agencies.
- A method for sharing information and medical documentation for patients under the facility's care, as necessary, with other health care providers to maintain the continuity of care.
- A means of providing information about the facility's needs, and its ability to provide assistance, to the authority having jurisdiction or the Incident Command Center, or designee.
Facilities under this category do not need to provide occupancy information in the Communication Plan.
Training and Testing
Rehabilitation Agencies, clinics, and public health agencies 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.
All staff must receive an initial training in emergency preparedness in regard to the facility's emergency operations plan, policies and procedures, and communication plan. This training should be given to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.
Facilities must also provide a refresher emergency preparedness training annually that demonstrates staff knowledge of emergency procedures, and maintain documentation of the training.
Facilities are required to conduct at least two 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. 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.
Rehabilitation agencies, clinics, and public health agencies 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.
Clinics, Rehabilitation Agencies, and Public Health Agencies as providers of Outpatient Physical Therapy and Speech-Language Pathology Services must develop the emergency plan with assistance from fire and life safety experts. The plan must also address the location and use of alarm systems and signals, as well as the methods of containing fires.