And ma in her kerchief and I in my cap, had just settled down…

For a long winter’s discussion of the The Joint Commission's new Emergency Management chapter (https://www.jointcommission.org/-/media/tjc/documents/standards/prepublications/hap_july2022_prepublication_report_em_chapter_revisions.pdf)

As I look at the latest offerings, I suspect that some of the challenges relating to this stuff are going to manifest themselves over time, but that time will tell. As to what’s changed, at this point, I don’t know that a crosswalk of new to old is in the works or if it’s even really necessary.

The general concepts are really no different than they’ve ever been and it would seem that the primary intent is to ensure that all the elements in the CMS Final Rule are present and accounted for – mostly the recurring hegemony of the Continuity of Operations Plan (COOP) concept and making sure that you well and truly give due consideration to the threat of emerging infectious diseases (or the “what fresh hell awaits us in the future” analysis).

A couple of other thoughts relating to some things I’ve seen in the field:

• Any number of folks have combined the risk categories into a monolithic approach for summarizing risks. I see no particular problem with that as a going concern, but I suspect you may find surveyors looking to see the categories identified in the new EM chapter as distinct entities: natural, human-caused, technological, hazardous materials, emerging infectious diseases. If you don’t have your identified risks clearly broken out into these categories, you might find that you’ll be accompanying a surveyor as they try to verify that each of the required categories is represented. May not be a big deal, but something’s telling me that this could be a sticking point.
• For those of you with bright, shiny Incident Command locations: I think that the more “established” that location, the more scrutiny there will be on the “what happens if you can’t use that space” scenario. There is a requirement to identify primary and alternative locations for incident command, and, as part of your continuity of operations, you probably want your alternative incident command location to have a pretty solid capacity. If your No. 2 site substantially mirrors your No. 1 site, then you should be fine—but if not, might be an excellent planning opportunity for the next year or so.
• The fundamental/critical functions aspects of the EOP remain in place: Communications; staffing plan, including volunteers; patient care and clinical support; safety and security; resources and assets; and essential/critical utilities. Additionally, there is the expectation of a clearly defined Continuity of Operations Plan (COOP) and a Disaster Recovery Plan (I think we all long for the day when we can implement the COVID Recovery Plan).
• The exercise “package:” While less expansive in terms of numbers of elements, seems fairly straightforward, but I’m going to reserve a final on that – as much because of what might be tacit expectations (and we know how those can throw a wrench in the works from time to time).
• The evaluation process moves to a biannual sequence unless a greater frequency is necessary. I don’t know that I wouldn’t be inclined to try to include consideration of emergency management into your EOC annual evaluation (which doesn’t seem to be going anywhere soon), that way you won’t be caught out. If you do choose to fully embrace the every-two-year model, make sure that each of the following is represented in the evaluation:
  
  • HVA
  • EM program
  • EOP, including policies and procedures
  • Communications Plan
  • COOP
  • Education & training program
  • Testing / Exercises

I know that CMS is still not quite pleased with the various accreditation organizations (we’ll likely chat about that next time), but it seems somewhat, oh I don’t know, impetuous came to mind first, but I don’t think that’s quite it. At any rate, given what’s been going on, I don’t know that change is going to be helpful in getting us through the current situation and perhaps might have been delayed until after the emergency declaration had expired. So one more thing for the to-do list.

On that note, I will wish each and every one of you a safe, healthy and sane New Year! I think each of those elements is going to represent its own challenge, but together, we will prevail.

About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is also a contributing editor for Healthcare Safety Leader. Contact Steve at stevemacsafetyspace@gmail.com.