Everbridge and Steven M. Crimando present a training session on the CMS Emergency Preparedness Guideline updates, focusing specifically on interoperability and communicating within the local community.  The new CMS Emergency Preparedness Guidelines apply to inpatient and outpatient centers, including but not limited to hospitals, psychiatric residential treatment facilities, long-term care/skilled nursing facilities, home health agencies, public health agencies, and Hospice.  Today’s conversation will focus on the hospital-setting, as a representative case study.

CMS finalized new emergency response requirements for healthcare providers, aiming to “close the gaps” in earlier CMS emergency preparedness regulations, establishing consistency and encouraging (forcing) coordination with partners.  Shared terminologies, expectations of capabilities, and the trust needed between organizations are key to strengthening internal and external relationships.  Steven Crimando, internationally known _______ expert and presenter, states it simply: “Understand that in many ways the process is as valuable as the product.  The teamwork developed in the planning process will be the teamwork you depend on in an actual disaster.”

Major Change to CMS Emergency Preparedness Guidelines

The major change to the CMS guidelines focus on communication, a change from the old approach which didn’t require coordination between health organizations during an emergency or have contingency planning and emergency response training for staff in place.  With the new CMS Emergency Preparedness Guidelines, healthcare organizations will need to coordinate their plans with federal, state, regional, tribal and local emergency preparedness systems.

Contrary to what may be assumed by first look, an “All-hazards” approach is not a one-sized-fits-all solution.  Instead, the response (individual or community) is phase and hazard specific.  For example, what are the challenges, how are people behaving, and how are needs different in first minutes, days, weeks, etc? These answers all help determine what phase you’re responding to.

What is the hazard?  Are you managing an active shooter situation?  Fire or flood?  Earthquake?  Depending on the situation, your situation, response, and critical partners will change.  The “bones” (or structure) will be the same, but the need for flexibility and scalability is key.

Establishing Contact and Coordination with Local Authorities

When determining what community partners to include in your CMS Emergency Preparedness Plan, it’s recommended to begin by erring on the side of over-inclusion.  Start with a list that’s large, and as you learn more about each organization, scale back as needed.  Not only does this remove the risk of losing out on important assets and valuable contributions, but you’ll also remove the possibility of resistance to the product due to hurt feelings.

Including all community partners also ensures you brought all the right people to the table.  Your team must understand the culture of the state, county, and local government, including their major players before you start developing the plan.

Identifying Critical Partners

Thanks to FEMA and the Stafford Act, identifying critical partners is much easier through the federally-designated State Emergency Management Authority (SEMA).  SEMA ensures every state and territory has a go-to organization, allowing you to start with one main authority.

County-level emergency management agencies are also critical gatekeepers to vital contacts and relationships.  They know the challenges in your area, have local contacts, and maintain “special needs” registries that will be critical to fulfill the CMS mandate.  Post 9/11, SAMHSA (Substance Abuse and Mental Health Services Administration) began creating a list of recommended community projects for mental health resources all over the country.  All will bring something different to the table.   Make the relationships!

Leveraging a whole-community approach also means involving VOAD/COAD programs (Voluntary Organizations Active in Disaster/Community Organizations Active in Disaster).  Often, these important groups specialize in one thing and will be able to play a critical role in that area, from childcare to feeding.

While most (92%) of our live webinar participants had experience working with the local community through their emergency preparedness plans, fewer were familiar with ESFs (Emergency Support Functions) (28% had never heard of ESFs, 42% only understood the basics, 30% were familiar).

Emergency Support Functions and Their Importance in CMS

In government emergency management, planning is largely centered around Emergency Service Functions (ESFs), defined by the National Response Framework as the operational-level mechanism to provide assistance.  It’s important to be aware of all of the ESFs to better understand your partner’s operating environment, especially as some will have greater importance than others to planners when considering the CMS requirements.  It’s a language spoken by the emergency management community to help determine how a given function lines up with a need.

These emergency support functions are organized around functional capabilities (eg emergency management, transportation, etc) and include the below.  ESFs 2, 6 and 8 are essential for CMS compliance.  Functions can be activated selectively based on the emergency, and must meet one of the two criteria: Stafford Act Emergency and Major Disaster Declarations or Non-Stafford Act incidents as specified in Homeland Security Presidential Directive 5 (HSPD-5):

ESF #1 – Transportation

ESF #2 – Communications

ESF #3 – Public Works & Engineering

ESF #4 – Firefighting

ESF #5 – Emergency Management

ESF #6 – Mass Care, Emergency Assistance, Housing, & Human Services

ESF #7 – Logistics Management and Resource Support

ESF #8 – Public Health and Medical Services

ESF #9 – Search & Rescue

ESF #10 – Oil and Hazardous Materials Response

ESF #11 – Agriculture and National Resources

ESF #12 – Energy

ESF #13 – Public Safety and Security

ESF #14 – Long-term Community Recovery

ESF #15 – External Affairs

The ESF coordinator is an important role, as they serve as a technical expert, approve and implement mission assignments, maintain situational awareness, and report on ESF operations.  With a sharp focuses on pre-incident planning and coordination, ESF coordinators maintain ongoing contact with primary and support agencies, coordinate with private-sector organizations & facilitate preparedness planning & exercises.

Planning for Special Populations May Require Assistance From Outside Authorities

Emergencies, disasters and terrorism present even larger challenges for the millions of Americans who are elderly or have physical, medical, mental, sensory or cognitive disabilities.  Plans for the unique needs of special populations must be taken into consideration (as part of ESFs 6 and 8) and applied to issues of evacuation, mass sheltering, hospital care and recovery.

Special needs registries are a way emergency agencies can identify people with special needs before a disaster happens to make sure a plan incorporates a timely response during an emergency.  These registries are intended to provide individuals notifications when an evacuation has been ordered, alert local emergency personnel of an individual’s considerations, and allow emergency responders an opportunity to plan and be prepared prior to engagement. For example, Monmouth County’s special needs residency provides stickers for a resident’s car or home that alert first responders about the person’s needs before they even interact.  Community emergency management officials are likely to have ideas and resources available to help healthcare emergency planners structure their approach so it’s interoperable with those of the surrounding community while fulfilling the new CMS Emergency Preparedness Guidelines.

Locating key personnel who can be deployed to other sites during an emergency

Hospitals and healthcare facilities should develop policies and procedures allowing you to track the location of staff and patients in the hospital’s care during and after an emergency and contact staff based on their schedules, areas of expertise and hospital needs.

This includes:

  • Knowing who is in the facility and communicating with them as a situation evolves
  • Automating communications and collaboration for mustering purposes and evacuation plans
  • Automating evacuation rostering during emergencies
  • Target outreach via SMS text, voice, mobile app, digital signage or desktop alerts
  • Using redundant means for recall/redeployment to alternate sites or assignments

Likewise, having a procedure to keep track of patients (specifically around safety, care, and transfers) is necessary until the patient has been transferred to another facility or organization.  The tracking requirement follows the patient.

Planning for flexible communications before, during, and after an emergency

The CMS posture is broad in who we communicate with and how we communicate with them.  However, there are certain stipulations stated by CMS that should be adhered to.  For example: “Providers and suppliers must document efforts made by the facility to cooperate and collaborate with emergency officials.”  So, while logging communication made within the facility isn’t required, your communication platform is required to document all (sent and received) communication to external authorities and partners.  In the healthcare setting, this means two levels of communication:

  • the ability to communicate with off-hospital coordinators and
  • the ability to remain HIPAA-compliant as patients are incoming or being evacuated

CMS guidelines also state “…we would expect the facility to include in its emergency plan a method for contacting off-duty staff during an emergency and procedures to address other contingencies in the event staff are not able to report to duty, which may include, but are not limited to, staff from other facilities and state or federally-designated health professionals.”  Having a solution for how leadership communicates to staff, providers, vendors, suppliers, and others, making sure patient care responsibilities can be carried out, is of the utmost importance.  This also means having backup processes and technologies, should typical communication arrangements fail.  Does your emergency preparedness communications platform automatically archive messages, helping to relieve emergency responders from manually tracking interactions?

Build the model and test it often, keeping in mind the purpose of the exercise isn’t to test the people – it’s to test the plan.  As JFK said, “The time to repair the roof is when the sun is shining.”


cms emergency preparedness, Steve CrimandoSteven M. Crimando is an internationally known consultant and educator specialized in the application of the behavioral sciences in homeland and private security, violence prevention, crisis management, and disaster response.  He is a Certified Trauma Specialist (CTS), a Certified Police Instructor, and holds Level 5 Certification in Homeland Security (CHS-V).  He is frequently called upon by law enforcement agencies, the media and the courts to provide insight on workplace, school, and community violence prevention.