Whereas most healthcare organizations are familiar with HIPAA requirements for protecting personally identifiable information, CMS’ requirements for emergency preparedness are much different. Consequently the questions you should be asking when researching a clinical preparedness notification tool are also much different.
In 2016, the Centers for Medicare and Medicaid Services (CMS) published its Emergency Preparedness Rule. The Rule requires all healthcare organizations in receipt of Medicare or Medicaid payments to plan for both natural and man-made disasters, and to coordinate with federal, state, tribal, regional, and local emergency preparedness systems to improve emergency response and recovery.
In order to comply with the Emergency Preparedness Rule, healthcare organizations have to develop a communications plan that ensures all employees, patients, and other necessary persons (i.e. patients’ physicians) are alerted to an emergency in a timely manner and kept informed during the emergency. The plan also has to factor in contingencies for how contact will be maintained with personnel and emergency managers in the event of a communications infrastructure outage.
What is a Clinical Preparedness Notification Tool?
A clinical preparedness notification tool is a mass communications solution specifically designed to meet the requirements of CMS’ communication plan. The tool integrates and synchronizes with employee, patient, and contact databases in order to ensure contact lists are constantly up-to-date, and has multi-modal communications capabilities to overcome the consequences of an infrastructure outage.
Certain clinical preparedness notification tools may have additional capabilities that translate emergency notifications into multiple languages, segment databases by role, location, or other attributes, and facilitate SMS opt in/out so that agency workers, contractors, and family members can be alerted to emergency incidents and kept up to date as an emergency develops. They may also have geo-poll capabilities to help healthcare organizations recover from an emergency much quicker.
What Questions Should You Ask When Conducting Your Research?
The questions you should ask when researching a clinical preparedness notification tool are not so much “what is a specific tool capable of?” but rather “what do we need the tool to do in order to comply with CMS' communications plan?” Once you have compiled a list of “must haves” it is easier to eliminate the tools that do not meet your requirements and focus on researching those that do.
One of the ways to compile a list of must haves is to apply the “five W’s” - Who, What, When, Where, and Why. Each healthcare organization will have its own specific answers to these questions; but, as a guide, we have compiled our own set of questions and answers to help healthcare organizations get started with the process. If you require any further information about the points raised in our Q&A, do not hesitate to get in touch.
Who are we trying to notify?
In order to comply with the CMS’ communication plan, you will need to notify and maintain contact with employees, patients, emergency services, and incident managers. This will involve communicating with parties beyond your Covered Entity network, so it is not necessary to have a HIPAA-compliant solution. Indeed, HIPAA-compliant solutions are not practical tools for emergency notifications due to the requirement devices are automatically logged out following a period of inactivity. Nonetheless, whatever clinical preparedness tool is implemented will have to be used in compliance with HIPAA.
What are we notifying?
Emergency notifications usually consist of alerts relating to natural and man-made disasters, but certain healthcare organizations have added requirements. For example, senior care facilities may need to use their clinical preparedness notification tool to initiate a search for missing residents. In this respect, an option to send emergency notifications by geographical area can limit disruption, while an SMS opt in/out facility can be used by members of the public to report a missing resident, or by members of the missing resident´s family to keep up-to-date with the search’s progress.
When might we need to use the tool?
An emergency can occur at any time of the day or night, so healthcare organizations need to have personnel capable of using the tool available around the clock. As it is totally understandable an employee could become stressed during an incident, one way to overcome a potential miscommunication is to have templates prepared for every CMS-required scenario - plus any unique threats identified in the organization's risk assessment - with the required audience and message delivery paths already configured into the clinical preparedness notification tool.
Where might we need to use the tool from?
This is an important consideration because a desk-based clinical preparedness notification tool will be of no use if an emergency incident results in a facility evacuation, nor if the healthcare organization experiences a cyberattack that knocks out its internal communications infrastructure. Therefore, the most appropriate type of tool to research is an Internet-based solution that can operate via Wi-Fi or a network provider's 4G service. This will mean emergency alerts, situational updates, and liaisons with emergency agencies can be conducted from any Internet-connected device in any location.
Why do we need a specialized clinical preparedness notification tool?
This is a good question because many commercial messaging services have group messaging capabilities that could be used to alert employees, patients, and other contacts to an emergency simultaneously. However, commercial messaging services lack the multi-modal component to overcome the consequences of an infrastructure outage, there are limits on how many contacts can be included in a group message, and - during a disaster - it is likely the networks these services use will be overrun. They also lack multi-lingual and SMS opt in/out capabilities.
How Does a Geo-Poll Capability Help Organizational Recovery?
An additional factor healthcare organizations may want to consider when researching clinical preparedness notification tools is how the tools can help organizational recovery. One capability to look for is a geo-poll feature. This feature enables system administrators to send notifications in a question and answer format and was originally developed to check on the wellbeing of employees so that resources could be prioritized to where they were most needed. Geo-polling can still be applied in this use case, but it can also be applied to organizational recovery.
Following a disaster, it is likely there may be shortages of staff, supplies, and beds. System administrators can use the geo-poll feature to solicit staff about their availability to fill vacant shifts, or solicit neighboring healthcare facilities about the availability of additional supplies or the capacity to accept extra patients. Through streamlined communications of this nature healthcare organizations can recover much quicker from a disaster - even when some communication channels may be experiencing infrastructure outages.
To find out more about the geo-poll capability, or for further information about any of the points raised in our Q&A, you are invited to contact us. Our team of safety experts will be happy to discuss your existing communication strategies and how they comply with CMS’ communication plan.
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