How long has it been since someone at your eye care practice or ASC has evaluated your disaster plan—not just eyeballed it, but really given it some careful thought?
Spending some time and resources to plan for disaster now can save your practice money, time, and headaches later, said Diana Hatsis, BSN, RN, COT, who presented at the 2018 ASCRS·ASOA Annual Meeting. You’re prepping not just for natural disasters—like hurricanes, tornados, blizzards, ice storms, floods, and wildfires—but also for man-made disasters like cyber attacks, active shooters, or terror strikes. You’re thinking about contingency plans for disasters that strike your entire geographical area as well as freak accidents that affect only your immediate surroundings—like a piece of laser surgery equipment catching fire or a disoriented patient driving into the front of your building.
How to Plan for the Unplanned
Planning and staff training can help your practice adapt and respond effectively to an emergency at your practice or surgery center, said Hatsis, a Red Cross volunteer who responded to hurricanes Irma and Matthew, as well as the Parkland shootings near her Boynton Beach, Florida home this past year. Here are some disaster planning tips she shared with ASCRS 2018 attendees:
Know that you don’t have to start from scratch.
If you’re working with some old, slapdash plan that’s been sitting around in a dusty binder somewhere, don’t despair. There are some good, inexpensive (or even free!) resources to help you evaluate and revise your current plan—or launch a new one, Hatsis said. Among her recommendations:
- OSHA’s Emergency Action Plan (EAP) Checklist
- The Medical Practice Disaster Planning Workbook by Owen J. Dhal, FACHE, CHBC (Greenbranch Publishing). This book helps you think through what you’ll need to both to respond effectively during the event itself and to re-establish your business amidst the disaster’s wake. Use the workbook to create policies, training, and grab-and-go checklists that reduce staff confusion and paralysis should an emergency occur.
- FEMA offers a free mobile app that provides real-time updates and disaster-specific checklists and resources during an event—assuming cell towers are intact. Ask your staff to download it so that you’re all ready for anything:
Eyes Open: As of November 15, 2017, you must comply with CMS’s Emergency Preparedness Rule if your practice or ASC receives reimbursement from Medicare. Specific requirements vary by provider or supplier type. Check the resource list at the end of this article for more information.
Understand that your preparedness plan should account for at least two types of emergency.
The two types are those that affect your office specifically or your immediate area only, and disasters that affect you and your larger geographical area. To effectively plan for the second type, you need to imagine what would happen were employees’ homes affected, emergency services overloaded, and infrastructure weakened.
Tip: Streamline planning and training by ranking potential disasters. You don’t want the minutiae of each specific scenario to bog you down as you work, observes a Practice Management Alert article. Instead, rank potential disasters on a scale—from full-fledged, widespread disasters to relatively minor incidents that affect only your practice (like a busted pipe). Then create a response plan for each kind of emergency.
Ensure that you train all your new hires on your emergency preparedness plan.
Retrain all staff annually as a group. Such training not only prepares them to think clearly during an emergency, but also reinforces the importance of seemingly insignificant daily routines. For example, airtight procedures for signing patients in and out can be a lifesaving tool when you are trying to determine who’s still in your building during an emergency. Front desk personnel should always know exactly who is in the practice or ASC—including staff.
Designate a meeting area a short—but safe—distance away from your office or facility.
During an evacuation, you don’t want to be running to different sides of the building to figure out whether all patients and staff are accounted for, so make sure everyone is trained to move to the same post-evacuation location.
List emergency contact information for upper management in your disaster plan and on your employee portal. Include your administrators, physician owners, IT lead, and other key personnel.
Create “buddy teams” of three for everyone at your practice or facility.
A buddy system that organized around three-person groups (rather than two) helps you make more certain you’re accounting for everyone should someone be out sick that day, Hatsis explained. In training, stress that buddy teams should account for one another at your designated meeting place or at their homes should you be dealing with a disaster that affects your geographical area during non-business hours.
Record phone messages as you’re preparing your disaster plan.
The same goes for patient portal messages or emails that inform scheduled patients that the office is closed, where to go for ocular emergencies instead, and instructions about when your office plans to reopen, Hatsis advised. Recording or writing such messages ahead of time increases the odds that you’ve provided all necessary information clearly and calmly. You don’t want to have to think about message content right before or during the emergency when your head is in a million places, she explained.
Check to see if your web site has an “employees only” feature.
Some patient portals offer “staff only” features as well, Hatsis noted. Setting up clear channels for employee communication ensures that your practice is fully staffed as soon as it’s ready to be up and running, which improves patient care and minimizes lost reimbursement and revenue for your business.
Tip: Make staff aware of your office’s return-to-work (RTW) policy after an area evacuation has been lifted. Most offices plan to open 24 hours after the community returns to the area to give staff time to take care of their own homes before they resume work, Hatsis said.
Plan to protect expensive equipment.
During training, designate at least two people at your practice to unplug and cover equipment,” Hatsis suggested. (Appointing two ‘unpluggers’ ensures that at least one person is available to complete the task should one be absent from work that day.) In addition to the covers that come with the equipment, consider keeping tarps and sandbags in your storage room for extra protection. Check that storage room periodically to make sure a doctor hasn’t snagged a tarp or two to “cover his boat—hey, it happens,” Hatsis warned.
Plan to protect your drug inventory.
The inventory control program you already have will come in handy prior to disaster because it quickly tells you the meds you have on hand as well as their monetary value. If your practice has a large inventory of expensive drugs and you have enough advance warning that there will probably be power outages, call the supplier and arrange to ship the drugs back until power is restored. “If I see a hurricane coming to Miami, I’m calling the supplier, buying some dry ice, and shipping the meds back,” Hatsis said. “I don’t want to dump four or five million dollars worth of drug inventory into a hurricane.”
Make sure your insurance plan is up to date.
As you review your disaster plan, make sure that your insurance plan covers the value of the equipment you currently have onsite, Hatsis recommended. Some insurance plans cover lost practice income due to office or facility closures. If you’ve added providers since you last reviewed your insurance plan, you should consider that option. Also, know whether your coverage includes the replacement cost of the equipment, or the current market value. Plan accordingly
Consider having “grab-and-go” kits available ahead of time.
Your physicians can use them to treat basic ocular emergencies during the disaster period, Hatsis suggested.
Make sure that your emergency preparedness plan is a living document that you revisit and revise regularly.
“Don’t make a plan simply to shove it into a folder and forget about it,” urges Ian Mattis, CPC, CEMC, of Century Vision Global’s practice optimization team. If you do that, it may be out-of-date and useless when you need it.
Schedule calendar reminders to review the plan yearly. Make sure that contact information and buddy teams are up to date. During your annual staff training, go over the plan with team members to make sure that everyone understands their roles. Consider a tabletop exercise with team members to uncover areas your plan needs to address.
Prevent HIT Havoc
Your preparedness plan should include steps for safeguarding data—not just medical records but also other data crucial to your practice—such as billing and accounting documents, contracts, scans, and images. Your IT lead should plan not only for emergencies that directly impact your data—such as a ransomware attack—but also for general emergencies that potentially damage data or limit your access to it.
If your compliance policies already take into account the HIPAA Security Rule (and they should), your practice has already done most of this planning. HIPAA requires practices to develop procedures that keep protected health information (PHI) secure and accessible at all times, even during disasters. Here are a few reminders from a recent article published in Health Information Compliance Alert)
- Backup all data regularly, and make sure those backups are encrypted
- Store backups in a secure cloud or at an offsite data center that is fire-, smoke-, and water-resistant.
- Keep an updated list of all desktop and mobile devices that create, submit, or store PHI at your practice so that you have a reference tool in the aftermath of a disaster. Keeping this list should be part of your HIPAA security plan for mobile devices.
OSHA Evacuation Action Plan Checklist: www.osha.gov/SLTC/etools/evacuation/checklists/eap.html
FEMA Mobile App: www.fema.gov/mobile-app.
CMS Emergency Preparedness: www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/index.html; www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Downloads/General-Presentation-Overview-EP-.pptx.
HIPAA Security Rule: www.hhs.gov/hipaa/for-professionals/security/laws-regulations/index.html