Florence, the first major hurricane of the 2018 Atlantic season, reached Category 4 status on Monday, Sept. 10, with meteorologists and the National Hurricane Center predicting an “extremely dangerous” trio of threats for southeastern and Mid-Atlantic coastal states such as the Carolinas, Virginia and Maryland: storm surge, freshwater flooding from rainfall and damaging, hurricane-force winds.
Florence is just the most prominent of what is expected to be a handful of tropical storms and hurricanes during peak Atlantic hurricane season.
For example, the HIPAA Privacy Rule mandates protection of individually identifiable health information from unauthorized or impermissible uses and disclosures. The Department of Health & Human Services has issued very limited waivers of sanctions and penalties during declared emergencies, such as Hurricane Irma in 2017, but this never suspends the Privacy Rule.
The considerations of a robust emergency preparedness plan will vary based on size of a medical group and geographic propensity for certain types of natural disasters, but it all starts with having something on the books to refer to and train for when the unthinkable happens.
An August 2017 MGMA Stat poll found that 78% of practice leaders said they have an emergency preparedness plan, while 18% responded “no.”
As outlined in this 2017 article, those who do not have an emergency preparedness plan in place for a variety of potential scenarios should consider taking steps to implement an emergency strategy. The primary questions an emergency plan should address, according to Owen Dahl, FACHE, CHBC, LSSMBB, MGMA consultant, in The Medical Practice Disaster Planning Workbook, include:
- What needs to be done
- When it needs to be done
- How it needs to be done
- Who should do it
If you are having difficulty finding the time to do this planning, Dahl recommends having a planning retreat where the necessary staff can focus their attention on the process. “Once completed, the plan should be written and should include ways to review and evaluate it once it has been implemented and to assess key points along the way,” he explains.1
Steps for developing a medical office disaster plan2
- Keep it simple.
- Obtain copies of disaster plans from hospitals and other physician groups.
- Obtain copies of community disaster plans.
- Model your plan on hospital and community plans.
- Let the plan reflect the abilities of practice staff and resources available.
- Distribute the draft to physicians, nurses and key staff members for input.
- Review the plan with appropriate hospital and community entities, defining the group’s role within the framework of community disaster plans.
- Finalize the plan with approval of group leaders.
- Implement the emergency-response plan.
- Develop training modules.
- Conduct initial and ongoing training program for physicians and staff, including testing and simulation.
- Re-evaluate and update your emergency response plan annually.
Using reverse planningDeveloping a comprehensive general emergency plan can be daunting. One way is to break the process down into manageable steps based on three phases of emergency events and to use reverse planning. Working backwards gives perspective to the plan through this order:
1. RECOVERY PHASE (RE-ESTABLISHING YOUR PRACTICE)
- Find outside help.
- Address continued patient care needs.
- Set communication procedures for recovery.
- Recover practice information.
- Manage staff availability.
- Manage finances and cash flow.
- Manage staff stress.
2. SURVIVAL PHASE (IMMEDIATE ACTIONS)
- First priority is protection against loss of life or injury.
- Run drills of the survival phase.
- Set communication procedures during survival.
3. PREPARATION PHASE (BEFORE DISASTER STRIKES)
- Assess vulnerability.
- Develop an emergency plan for each scenario.
- Categorize whether events affect only the practice or the community.
- Have practice systems prepared.
- Coordinate with the local hospital and community.
- Read about how 2017 MGMA Harwick Innovation Award winner Peter Valenzuela, MD, MBA, CMPE, MGMA member, worked with his medical group to respond during and after the deadliest week of wildfires in California history.
- Learn disaster preparation issues and resources to consider following the devastation of Hurricane Harvey along the Gulf coast in this Fellowship paper by Jennifer Myers, MBA, CPA, CGMA, FACMPE, MGMA member.
- Reprinted with permission from, Owen Dahl, The Medical Practice Disaster Planning Workbook, Greenbranch Publishing, 800-933-3711.
- Wolper, LF. Physician Practice Management: Essential Operational and Financial Knowledge, 6th edition, 2012.