Documentation of Cooperation and Collaboration

The typical facility’s Condition of Participation now reads, “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 hospital’s efforts to contact such officials and, when applicable, its participation in collaborative and cooperative planning efforts.”
The proposed new rule says, “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. The facility must contact the local emergency preparedness agency at least annually to confirm that the agency is aware of the facility’s needs in the event of an emergency.”
In other words, the requirement to document your efforts at collaboration and cooperation are removed.
We have three comments on this rule:
  1. Join your regional healthcare coalition. It’s your best source of “cooperation and collaboration,” and you are likely to get free training and exercises, and often free lunch. It’s where you will get all the answers to the regional questions in our emergency plan, and where you will meet the other facilities and suppliers that you will need in an emergency. If your local emergency manager is going to “cooperate and collaborate” with you at all, he or she will be at the coalition meetings. (Don’t know how to reach your regional healthcare coalition? Ask us!)
  2. Forget about Federal and even state emergency preparedness officials. They don’t want to hear from you, before or during an emergency. There is a strict chain of command in place. You will communicate with either your coalition, if it has a response mode, and/or your local or tribal emergency manager, in an emergency. If neither of those places can help you, then one of them will contact the state emergency operations center to attempt to help you meet your needs. Only the state can contact the Feds.
  3. Send a copy of your emergency operations plan to your local emergency manager and your regional healthcare coalition after each substantial revision. It is a requirement in some states for some provider types (e.g., nursing homes in Florida) and it is good practice. Include a cover letter, and keep a copy of the cover letter in your compliance binder.
Leave your comments on the federal register and let us know what you think!

Continue reading more on this subject in our five-part series!

Categories: CMS Compliance | Healthcare

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