The global impact of COVID-19 has required behavioral healthcare and addiction treatment center executives around the US to adapt quickly and recognize the importance of a robust disaster plan. These plans, when intelligently designed and implemented at a facility, provide the tools necessary to empower employees and management to navigate a multi-dimensional disaster response. This functionality, coupled with the enumerated requirements by state and local statutes and regulations and accreditation standards, create a complete picture of preparedness in the new COVID world. This article will address the regulatory and compliance issues addiction professionals face in modifying and adapting their disaster plans to deal with COVID-19 within these standard frameworks of both compliance and preparedness.
Designing a functional disaster plan
Statutory, regulatory and accreditation frameworks such as CARF and CMS are all designed with a single goal in mind: ensuring facilities have a functional disaster plan installed and maintained. The health and safety of staff and patients are a paramount priority, and facilities are going to be expected in the “new normal” of COVID-19 to actively sustain standards. Overseeing organizations realize that without a plan, incident responses are inconsistent, confused, and lack continuity necessary to maintain the highest standards. The impacts on the disaster plan will be focused on three areas: risk analysis, emergency response, and business continuity (or “continuity of operations” depending on the framework language). Each plan represents a separate phase in the emergency preparedness cycle.
Risk analysis. The risk analysis essentially asks one question: “What threats do we face?” It should identify potential threats to a facility’s operation in the categories of natural disasters (i.e.: hurricanes, COVID-19 etc.), technological disasters (i.e.: power outage, HAZMAT spill), and security emergencies (i.e.: terrorism, active shooters). Typically, these analyses are conducted with the ones perceived by management as the most likely, and sometimes isn’t comprehensive because there are threats that may either be hidden or not considered likely. While there is a temptation to simply do this by “gut” instinct or from past experiences, the risk analysis should be conducted through a multi-prong analysis of data from local, state, and federal sources. Neglecting to do so can miss critical threats. For instance, prior to 2020, few people had a real grasp of the potential for a crippling pandemic, even though the federal government placed pandemics in their national planning scenarios as early as 2003. Pandemic risk identification, and a rotating examination of possible pathogens is likely to become standard. Furthermore, the risk analysis will need to be considered in light of its ability to modify visitor and interaction policies quickly.
Emergency response plan. The emergency response plan is a comprehensive document covering every element of the initial response to an incident on property. This may be termed the “lights and sirens” phase of an emergency. It should cover evacuation, shelter-in-place, and lockdown of the property, and how to set up an emergency leadership structure. However, the plan must also address crisis communication, utilities, worker injuries, equipment, supplies and training.
The procedures are going to be significantly impacted by new enforcement provisions and language contained in various frameworks as a result of COVID-19. One of the major elements to consider is when a second disaster occurring simultaneously during this or future outbreaks. With hurricanes bearing down on the Gulf Coast, and the ongoing California wildfire season, this has become more acute for healthcare facilities of all types, as COVID considerations can change how a facility’s management team responds. For example, tornado plans incorporate some type of shelter-in-place during a warning. This could mean for some facilities that dozens of people are packed together in small, secure areas of the building. With COVID-19 social distancing, mask requirements, and other basic precautions, those plans will have to go through a major modification to ensure compliance with both disaster health and safety as well as COVID preparations.
Business continuity plan. The final piece of a facility disaster plan is the Business Continuity Plan (BCP), which is a purely recovery document. Any inpatient facility will have multiple service processes (intake, treatment, dining, etc.) that will require a comprehensive recovery examination. However, there are pieces of the BCP that should be incorporated into your emergency response plan to COVID because there are elements of recovery that also fit into a property’s initial response phase. Many regulatory frameworks now require at least a management recovery scenario to ensure a smooth operational recovery.
However, with COVID-19, the recovery scenarios will become much more sophisticated than simply converting to Zoom meetings. It is no longer a question of whether a facility can be reopened. It is a question of: Can it be reopened with all COVID-19 precautions available? Some states have made it clear that this will not only include successful policy implementation but also equipment and supplies, and even a jurisdictional analysis of whether the local government can provide any backup support in case of a major disaster declaration. If the facility cannot be opened, there will be questions as to whether the facility has created adequate support to clients/residents if they cannot reopen.
The severe psychological stress that has accompanied the COVID-19 outbreak has affected even very resilient populations. Compounding that with a second disaster occurring simultaneously, facility executives and their teams will have to develop sophisticated recovery programs. However, teams should be aware: BCPs are highly technical documents and should NOT be written by laypeople under any circumstances. They require technical expertise to develop operational recovery times and points that align with a metric of consequence of late recovery for both brick and mortar as well as information technology. Regulatory agencies and enforcement bodies will be looking for a complete program, developed under these standards. The Centers for Medicare and Medicaid Services through the California Department of Health recently announced that they will be actively seeking to “work” with facilities to ensure they remain compliant. This does not mean that standards will be lax. In fact, they anticipate a more rigorous process, but a greater emphasis on correcting behaviors than exacting a punitive regime will be the priority.
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The COVID-19 Pandemic has proven to be a unique challenge for addiction executives and facility staff unlike any other. Management teams from all kinds of facilities should develop and maintain a sophisticated disaster plan, which not only meets the emergency response requirements, but also does so in light of the COVID-19 outbreak. This plan, if implemented and rigorously maintained, will provide them, their staff and the populations they work with the tools to respond to any emergency they face.
Patrick Hardy is a certified emergency manager, certified risk manager and a FEMA master of exercise practitioner.