CMS 3178 Prepares Us for Events Like Oroville

CMS Compliance

In November 2016, the CMS 3178 Final Rule was enacted, requiring CMS-participating Healthcare providers and suppliers to prepare All-Hazards Plans for Emergency Management, Communications, Training, and Exercises on an annual basis. These are required to be implemented at the site level prior to November 2017 in order to remain compliant under CMS Conditions of Participation/Coverage (CoPs)/(CfCs).

All Hazards Emergency Plans

All Hazards plans require the provider to be prepared for all reasonable natural and manmade emergency events including, but not limited to:

Natural events such as Hurricane, Earthquake, Wildfire, Flood, Tsunami, Tornado, Ice Storm, and Pandemic outbreak. All are becoming increasingly frequent and severe and being influenced to some degree by climate change, regardless of the source of that change.

Manmade events include a broad array of intentional events such as dirty bombs and other explosives, bio-terror/bio-error, active shooting, arson, vehicular homicide, civil unrest, denial of critical infrastructure and other types of attack in the physical or cyber realm.

The threat from both Natural and Manmade Events increases in scope and complexity on a daily basis. The serial failure to protect the public despite existing plans and early warning is evident over the course of the last fifteen years in disasters like Katrina, Sandy, Joplin, the swine and bird flu outbreaks, Ebola and MERS and the terror attacks that have killed dozens on US soil. All Hazards plans should contain a comprehensive view of Location Intelligence to provide a plan tailored to specific threat depending on their assessed risk for both natural and manmade threats.

Real Life Test – Are Oroville / Sacremento Hospitals and Nursing Homes Ready if the Dam Fails?

An excellent example of location intelligence planning is the current flood situation in northern California, where record rains have stressed the Oroville Dam, forcing the rapid evacuation of almost 200,000 residents in the Sacremento Valley. Although the dam looks as if it will now hold, the primary spillway failed in its’ first ever real-life test. The emergency overflow caused major erosion to the embankment as crews scrambled to reduce water levels and pressure on the dam. Residents have been advised to return to their homes. The area is bracing for another week of hard rain and we have to assume that all healthcare facilities in the flood path have developed adequate plans in case of catastrophic failure of the dam.

The question of major infrastructure renewal has been delayed by both political parties for the last two decades as the problem has increased over time.  This is not only a California problem –  as seen in the PDF produced by the American Progress Institute.