Category Archives: Emergency Preparedness

How to conduct a Hazards and Vulnerabilities Risk Assessment

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-day Countdown to Emergency Preparedness and comment to win helpful EP products! 

THURSDAY, Oct. 19 Giveaway

One of the key components of new Emergency Preparedness Programs which CMS is requiring home health agencies to have in place by the November deadline is an All Hazards Risk Vulnerabilities Assessment.

If you’re still wondering exactly this is and where your agency can download its risk assessment form, we have some disappointing news. There is no standard risk vulnerabilities assessment form agencies can download and fill out to comply. CMS leaves the actual format of the risk assessment – whether it will be a form or even a full, written report with a chapter-by-chapter analysis — to the discretion of the home health agency.

You will see many different versions and samples of suggested risk assessments all over the internet, ranging from basic to complex.

(Because we like things made easy, and because we believe Surveyors appreciate being able to quickly find information, Home Health Solutions suggests using an easy-to-read form for the risk assessment. We provide a fairly simple form in an easy-to-follow 12-step Emergency Preparedness Plan Assembly Kit we sell in the HHS online store.)

Whichever format your risk assessment takes, bear in mind that the easier it is to read, with information presented clearly and concisely, the more likely Surveyors are to look at it favorably. Surveyors are human, too – and no one likes wading through a disorganized mess or too much information.

CMS does provide some guidance about the risk assessment. Your agency will need to determine your vulnerability (based in large measure on your geographic location and the history there of previous events) to all natural or man-made disasters, including weather-related catastrophes such as winter storms, tornadoes, hurricanes, flooding, wildfires, etc. You’ll also need to evaluate your vulnerability to non-weather emergencies, such as nuclear power plant explosions or acts of terrorism.

Each agency’s risk assessment will be based on your particular location and the likelihood of hazardous conditions for you. An agency in North Dakota, for example, will probably devote a great deal of space on its risk assessment to the likelihood of winter storms, so that it can undertake detailed planning for continuity of patient care during ice or blizzards. But an agency in Florida will almost certainly devote most of its space to tropical storms or hurricanes with the potential for high winds and flooding – and may even devote space to the potential for sinkholes.

Your agency’s risk assessment shouldn’t necessarily look just like assessments for other agencies in your state. Is your agency located within a few blocks of a major metropolitan airport? You may want to include the possibility of a major plane crash impacting the building in which your agency is housed. Does the river in your small town flood in years with heavy spring rains, closing roadways? Your risk assessment should highlight that risk. Do frequent rock slides impact roadways in the mountainous areas where you serve clients? That is a risk specific to your area, and should be addressed in your risk assessment.

Remember that CMS loves data, so build your risk assessment to the extent possible around local data showing previous incidences of ice storms, tornadoes, forest fires, etc. which have occurred in your area. Your local Emergency Management Agency should be able to help provide data, or direct you to state web sites where it can be found.

Bear in mind, however, that your risk assessment does not need to be a lengthy and detailed incident report of every power outage or tornado watch experienced in your area over the last few decades. You will only need to provide a comprehensive overview of risks specific to your area.

Think of the risk assessment as your agency’s clear, concise and carefully constructed answer to these two questions:

1. What could possibly go wrong?

2. How will we respond if it does?

The goal is to demonstrate that you have thoughtfully and carefully evaluated many different situations likely to make it difficult for you to care for your patients, seeking input from qualified emergency management officials who are trained in dealing with crisis situations, and that you have set in place mechanisms to maintain continuity of care even under the most challenging circumstances.

CMS specifically uses the term “all hazards” in defining the risk assessment, so be sure to weigh all potential hazards, including those which are not weather related. Your assessment should reflect your agency’s vulnerability to cyber attacks, workplace shootings, hostage situations, acts of terror and other man-made crises which could negatively impact your ability to care for your patients.

On its web site, CMS says the risk assessment should include (but is not limited to):

  • Hazards likely in geographic area
  • Care-related emergencies
  • Equipment and power failures
  • Interruption in communications, including cyber attacks
  • Loss of all/portion of facility
  • Loss of all/portion of supplies

The CMS list above provides the framework for your risk assessment. Flesh it out and make it specific to your agency, and you will have this important element of your Emergency Preparedness Program in place.

The clock is ticking. Check out all the helpful CoPs products HHS offers in our online store, The Solutions Shop:

CMS requires two exercises before November deadline

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-day Countdown to Emergency Preparedness and comment to win helpful EP products! 

WEDNESDAY Oct. 18 Giveaway

Are you still working hard to get your home health agency’s new Emergency Preparedness Program in place by November so that you can meet the CMS deadline and begin all the detailed planning for those two exercises you’re required to stage — the full-scale community disaster drill and a second, smaller-scale  table-top exercise?

We sure hope not.

For compliance, your agency will need to have already staged both these required exercises by November. The Emergency Preparedness Requirements Final Rule was posted to the Federal Register more than a year ago, on Sept. 8, 2016, and the regulation went into effect just two months later, on Nov. 16, 2016. Medicare and Medicaid Participating Providers and Suppliers were given one year from the effective date to comply and implement all regulations. When that year is up – in just one more month – home health agencies will be subject to citations for non-compliance if they have not yet staged both exercises this past year.

The Emergency Preparedness Requirement was confusing to many home health agencies. We talk to agencies every day who are so busy caring for patients and taking care of agency business that they have trouble juggling regulatory deadlines – especially this year, when the start date for new Conditions of Participation was originally set for a July implementation, and then delayed until January.

Isn’t the Emergency Preparedness requirement part of the new CoPs, agencies ask us. Don’t we have until January now? Not for your Emergency Preparedness Programs, we explain.

While the Emergency Preparedness requirement is included as part of the new CoPs, and while  the start date for CoPs was pushed back six months, a delay was never granted for the original Emergency Preparedness Requirements Final Rule which posted to the Federal Register back in 2016.

The clock began ticking then.

Time is up.

Some agencies which experienced actual emergencies this year may be exempt from the community-wide disaster drill (please see Tuesday’s Tip #2).

But agencies which did not activate emergency plans this year and conduct an evaluation afterward are expected to comply with the full-scale community-wide drill prior to next month’s deadline.

In either case, agencies also will be expected to have staged tabletop exercises, in which mock disasters are conducted via paper.

If you’re feeling panicked by the approaching deadline, please visit our online store today and check out our 12-step Emergency Preparedness Plan Assembly Kit. We’re not going to mislead you; it’s getting late in the game to comply, and it will be very difficult now to meet the deadline if you have not yet begun. But don’t wait another day. Our Kit will make it faster and easier.

Click here to visit The Solutions Shop, our online store. 


HHS Countdown to Emergency Preparedness offers tips and giveaways

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-Day Countdown to Emergency Preparedness and comment to win helpful EP products! 

Tip #1:  Are your patients prepared?
MONDAY OCT. 16 GIVEAWAY: Our helpful EP Guide to Survey Readiness

CMS wants to make certain home health agencies have adequately prepared patients and their caregivers for the possibility of evacuation or other possible changes in the delivery of care during or immediately after an emergency situation.

One of the ways agencies should do this is by providing patients two lists: a Medication List and a Special Equipment List. These lists are to be kept in the home and constantly updated so that each list is always current. This means it will be necessary to review and update the Medication List at each visit – a big change for most agencies.

Make certain patients and caregivers understand that these lists are to go with them to a shelter if an evacuation is needed.

The Medication List should include the medication, dose, frequency, route, time of day, and any special considerations for administration. The Special Equipment List will identify the equipment needs of the patient.

Note that lists should include the name and phone number of the patient’s physician and pharmacy, and the address of the pharmacy should also be included.

It is also important to include allergies and adverse events as well the name and contact information for the home health agency on these lists.

During the confusion of an emergency situation, this information could be vital to maintain continuity of care for the patient.  HHS recommends that your agency create a form to be used to collect all the necessary information, so that nothing will be inadvertently omitted.

Be sure to document your discussions with patient and caregivers about the importance of these lists, with reminders that the lists should always travel with the patient if there is an evacuation.

Preparing homebound patients for the possibility of an emergency situation is an important step in your agency’s overall Emergency Preparedness Program. 

Read more tips and enter to win daily giveaways on the Home Health Solutions Facebook Page during our “10-Day Countdown to Emergency Preparedness,” as we help home health agencies meet the CMS deadline to have Emergency Preparedness Programs in place. 

Here’s what you need to know about our helpful EP Assembly Kit

THREE MONTHS FROM TODAY.  When surveyors show up at your home health agency in just three months from today, they’ll expect to review your Emergency Preparedness program.

Yes, the start date for new CoPs has been delayed until January 2018 — but don’t get confused. Your agency is still required to have its Emergency Preparedness Plan in place by this November.

Home Health Solutions Owner and President J’non Griffin has been traveling across the country to present workshops to help agencies meet the new Emergency Preparedness requirements in time for November surveys.

Her expertise is also condensed into an easy-to-follow 12-Step EP Assembly Kit available for order now in the Home Health Solutions online store.  The Kit takes the cumbersome process of developing Emergency Preparedness policies and procedures and staging a community-wide disaster drill, and makes it simple to execute.

Wondering how the kit works? Check out these EP Assembly Kit FAQs:


1. What format is the Kit presented in?
The Kit comes to you in DIGITAL format so it is available immediately. You can get started on your Plan instantly!

2. What exactly comes in the Kit?

A VIDEO in which Home Health Solutions Owner J’non Griffin explains the Emergency Preparedness Program which new Conditions of Participation will require agencies to have in place by November of 2017.

A 12-STEP GUIDE which breaks down the cumbersome process of developing your agency’s program into 12 easy-to-follow steps. We explain each step and provide the materials you will need to implement it. One of the steps, for example, explains how to set up a community meeting with Coalition Members to plan your community drill. We include a copy of the invitation letter for you to send, a list of other facilities and/or community groups to send it to, and an agenda to follow at the meeting.

A SAMPLE PLAN to show you what your completed Plan should look like.

— A section we call THE TOOL PACKET.  It is filled with all the forms you’ll need to capture the information to fulfill the requirements of the CoPs for creating an Emergency Plan. There’s a sample Phone Tree and Crisis Communications Form for creating your agency’s Disaster Communications Plan, a sample Hazardous Risk Vulnerabilities Assessment, etc. This section includes more than 30 forms and tools.

An EP Survey Readiness Guide. We’ve used Interpretive Guidelines to create an at-a-glance look at exactly what Surveyors will be looking for when reviewing new agency Emergency Preparedness Plans.

3. Does the Kit explain how to stage a community-wide disaster drill? Yes. Our 12-Step Guide explains exactly how to go about planning this event, from who to invite to participate with you to a sample letter to send out to invite participants to a planning meeting. We include an agenda for that meeting and samples of items you will need to discuss and lists you will need to compile at the meeting. We can’t have the meeting or stage the actual drill for you, but we make it as easy as possible!

4. What about the Training and Testing portion of the Emergency Plan requirements? Our Tool Kit includes training materials on various natural or man-made disasters which you will be able to copy and provide to your patients and staff to fulfill CoPs disaster training requirements. Just be sure to document that you have provided these materials and when the training occurred.
We also include some sample evaluation forms to use to review the communitywide drill afterward to help  in conducting an annual evaluation of your Emergency Plan.

5. What is the “All Hazards” Risks and Vulnerabilities Assessment our agency is required to have, and is it included in the Kit? Our kit explains what this assessment is, and we provide a sample for you to follow. We also explain how to create your own Risk Assessment specific to your agency and community.

6. How long is the 12-Step Guide? How much reading will be required? We know you are busy so we have kept the entire Guide – all 12 steps and all the forms and tools included – right at 100 pages. The EP Survey Readiness Guide is a separate document, provided in spreadsheet format.

7. Our agency will need to have a written Policy outlining our Emergency Plan. Does the Kit address this need? Yes. A sample written Policy is included in the Kit. We recommend that you use it as the basis for your agency’s policy. It will meet federal requirements in its current form, and you can easily add any state-specific requirements to it. Some states, including Florida, will have a few extra Emergency Preparedness requirements that CMS does not require. Our 12-Step Guide directs you to work with your local Emergency Management Agency on the development of your plan, and your local office will be able to provide any local and/or state requirements which must be met in addition to what CMS requires.

8. How long will it take to get together our agency’s Emergency Program using this Kit? That depends on how many components of the program your agency already has in place and how quickly you are able to set up a meeting with your Coalition Partners and stage a community-wide disaster drill. In most cases, this project will take weeks of planning and collecting information, so we recommend that you get in started well in advance of the November deadline.

9. Our agency already has an Emergency Operations Plan in place, so we do not want to order the Kit. But we would like to know whether our existing plan meets new CoPs. We have the solution: the piece of our kit known as the EP Survey Readiness Guide may be purchased separately. Based on Interpretive Guidelines, this helpful guide is available in an easy-to-read, spreadsheet format and will review all aspects of the Emergency Program requirement along with bulleted points showing exactly what Surveyors will be looking for. Check our online store to order the Survey Readiness Guide.

Remember, Home Health Solutions also provides customized education and training to home health agencies. Owner and President J’non Griffin will work with your agency to make certain you comply with the new Emergency Preparedness and Infection Control program requirements as well as any other aspects of the new CoPs.