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Operating in the Worst Case Scenario – Business Continuity Planning

Thursday, May 9, 2019

Evacuation of a healthcare facility in an emergency is worst case scenario.  It is a drastic decision caused by catastrophic events. Often control of the decision to evacuate is not in your hands. It’s made by public safety officials – police and fire—who have determined your facility is not safe.  It is a decision that results in extreme disruption. 

In 2012 Superstorm Sandy hit New York City and created havoc in hospitals and skilled nursing facilities.  From that event we learned that hand scrawled messages directing medical staff and nursing staff to temporary in-patient and outpatient locations can be reality.  In New York we know firsthand that Business Continuity Planning is critical. 

Regulatory Requirement

One of the most difficult challenges presented by the Final Rule on Emergency Preparedness adopted by CMS (with compliance required no later than November 15, 2017) is the requirement that your healthcare facility address Business Continuity Planning.   The CMS regulations apply to Hospitals, Long Term Care facilities and other Clinics and Rehabilitation facilities

A Business Continuity Plan is a distinct part of your Emergency Operations Plan.  Emergency Incident Management handles the specific hazard your facility is facing.  Business Continuity Planning focuses on keeping your facility functioning: performing the services patients require and maintaining your revenue stream while the Emergency Incident is handled.   Business Continuity is about resilience: restoring your core operating competency in time of stress to systems. 

How to Get Started

Business Continuity Plans require leadership commitment but cannot be solely driven by your executive. Input is required from the real experts:  medical staff, nursing, facilities, engineering, other department managers, community public safety members and technical experts from the outside.  If your facility is a large campus, the planning must be accomplished campus-wide.

 Steps required in creating Business Continuity Plan:

  1. Identify essential core business functions of your mission,  consider licensure capabilities, contribution to revenue, and reputation
  2. Identify required resources to allow your essential functions to operate
  3. Understand the time frame required to restore these essential functions if interrupted

In a methodic manner, the Business Continuity Team must consider the issues of alternate facilities for each essential function; essential staffing, communication,  and  IT requirements; necessary equipment and vendor support; record-keeping, legal, and HIPAA issues.

Fust Charles Chambers can assist you in facilitating your group developing your Business Continuity Plan.  Or we can review the work you have already accomplished for regulatory compliance.  Stay tuned for a webinar this summer addressing more about Emergency Preparedness and Business Continuity Planning process.

For more information on this topic, please contact:

Mary Ellen Luker, CPA, JD, LLM