New York’s hospitals and health care systems are a critical element within the disaster response system. IHA works to help ensure our member hospitals and health systems are prepared to respond to any potential threats to public health.
IHA has provided hospitals in our region and across the state with information, resources and services since inception of the federal hospital preparedness program in 2002. IHA works with federal, state and local agencies on behalf of hospital concerns, provides analysis of regulatory and grant requirements and best practice standards, and leads collaborative projects to enhance planning and response capabilities. Below are highlights of Iroquois projects and resources which have supported facility and health care system preparedness.
OSHA COVID-19 Healthcare Emergency Temporary Standard
The Occupational Safety and Health Administration (OSHA) published an emergency temporary standard (ETS) for occupational exposure to COVID-19 in settings where suspected or confirmed COVID-19 patients are treated. Employers must comply with most provisions as of July 6, 2021, and with the physical barriers, ventilation and training requirements by July 21, 2021.
IHA has created a crosswalk of the ETS regulatory text and inspection and enforcement procedures to help hospitals assess their compliance. The crosswalk may be downloaded by clicking the link below. The OSHA ETS webpage has additional resources including a plan template and tools for compliance. AHA issued a regulatory advisory on July 2 which summarizes the standard.
Continuity of Operations Planning
Iroquois is collaborating in a multi-year initiative to assist hospitals in development of continuity of operations plans. The project includes a continuity of operations plan template for hospitals and health care organizations and supportive documents providing guidance through each phase of continuity planning.
Emergency Waivers Granted During the COVID-19 Public Health Emergency
Healthcare providers were granted relief from federal and state laws and regulations during the COVID-19 federal Public Health Emergency and New York State Emergency Disaster Declaration. Below are documents compiled by IHA which identify the scope of relief granted by federal waivers and state Executive Orders.
- NYS Laws and Regulations Temporarily Suspended or Modified During the COVID-19 State Emergency Disaster Declaration
- Federal Waivers Issued During the COVID-19 Federal Public Health Emergency
Emergency Waiver Guidance
Iroquois collaborated with other healthcare associations to develop and publish a guide which explains how to seek relief from statutes and regulations during emergencies (often referred to as “waivers”). After the events of the 2009 influenza pandemic, Hurricane Irene, and Superstorm Sandy, Iroquois convened a workgroup of associations representing healthcare providers across the continuum of care to identify statutes and regulations that are likely to impede care during an emergency. In addition to listing potential statutory and regulatory barriers, the guide provides an overview of legal authorities, a description of the process for requesting waivers, and contact information.
- Temporary Suspension and Modification of Statutes and Regulations During Emergencies: A Guide for Healthcare Providers
Mutual Aid MOU – Capital District & Central Regions of NY
Iroquois developed a mutual aid agreement among 51 member hospitals to support continuity of care and medical surge capacity through mutual aid consisting of equipment, supplies and pharmaceuticals; evacuation and transfer of patients; and communication and information sharing. The MOU reflects cooperative understandings when mutual aid is provided, describing information to be communicated and responsibilities relating to transportation, documentation, costs, insurance, and plan maintenance.
- MOU – Fully Executed (44 pages)
- Outline and Text (10 pages)
- Signatory Tracker
- Summary of Provisions (2 pages) Updated September 2021
- Advisory Group Review and Recommendations December 2019
- Summary & Training Presentation [PPT] I [PDF] Updated September 2020
CMS Emergency Preparedness Conditions of Participation
CMS issued a final rule titled Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers on September 8, 2016. The rule which applies to 17 provider types took effect November 16, 2017. Iroquois has compiled a crosswalk by provider type of rule requirements, interpretive guidance, surveyor procedures and FAQs; and 1135 Waiver and Alternate Care Site compliance recommendations.
- 2019 Revisions to CMS Emergency Preparedness Conditions of Participation for Hospitals
- CMS Emergency Preparedness Conditions of Participation CMS 1135 Waiver and Alternate Care Site Requirements: Recommendations for Compliance (PDF) (Word)
- CMS Emergency Preparedness Conditions of Participation Crosswalk
Hospital Emergency Codes
There has been a trend to standardize overhead emergency codes, with an increased focus on the adoption of plain language announcements. The document below provides an overview of standardization initiatives, including recommendations for adoption of plain language alerts, and the national safety and emergency management recommendations on which they are based.
Integrating Emergency Volunteers During Medical Surge
This document identifies key planning and operational considerations for managing emergency volunteers in hospitals. It includes a planning checklist, templates, guidance, and resources for integrating emergency volunteers during a medical surge event. Iroquois assembled a work group in 2013 to develop a hospital template plan for using emergency volunteers. Hospitals were reimbursed $4,500 for adopting their own plan, and $2,000 for workgroup participation. Based on recommendations of the work group, Iroquois developed comprehensive guidance for emergency volunteer planning and management which was updated in June, 2015.
- Emergency Volunteer Management: Planning Considerations & Resources for Hospitals Updated November 2017
96 Hour Sustainability Assessment Project
In 2012, Iroquois and HANYS developed a 96 Hour Sustainability Assessment framework for hospitals to determine sustainability periods and gaps for essential resources and assets, enabling the organization to make decisions relating to mitigation and plan review. Iroquois and HANYS developed analysis and calculation tools, guidance, and training to aid hospitals in the assessment process. Hospitals were reimbursed $5,000 in 2013 for conducting a 96 Hour Sustainability Assessment. The project framework and tools are scalable and modifiable based on facility operational needs. Project tools and resources include:
- 96 Hour Sustainability Assessment Calculator, Chart and Tools – Calculates the number of hours resources and assets may be sustained; and provides a visual analysis of sustainability periods and gaps that may impact operations.
- 96 Hour Sustainability Assessment Planning Overview – A one page summary of the sustainability assessment and its value.
- 96 Hour Sustainability Assessment Guidance for Hospital Leaders and Department Heads – Provides a brief overview of the process and the information department heads and leaders may need to provide.
- 96 Hour Sustainability Planning Guidance – Provides step-by-step detailed instructions for collecting data and conducting a sustainability assessment.
The guidance document below provides information on redundant communication systems and communication plan requirements to help hospitals develop emergency communication strategies.
IHA purchased redundant communication equipment systems for hospitals in 2004-2006. The systems include:
- Satellite Phones: Iroquois purchased fixed and mobile satellite phones, laptops, replacement batteries and accessories for rural hospitals throughout the state. Conducted connectivity exercises and provide ongoing assistance statewide for connectivity issues.
- Amateur Radios: Purchased 68 ham radios for all IHA members and all rural hospitals across the state to further ensure communication redundancy. Provided ongoing assistance and direction in operations, contacts and licensing.
- Mobile Command: Equipped a mobile communications command center to provide back-up communications to ten hospitals in the five county North Country RRC region.
Active Shooter Planning Checklist, Recommendations and Resources
Iroquois assembled a multi-disciplinary work group to develop an active shooter plan template. Hospitals were reimbursed $4,500 for adopting an active shooter plan and $2,000 for work group participation. Iroquois developed guidance based on best practices, after action reviews, and recommendations by federal agencies identifying critical planning and response considerations for hospitals.
- Data Sharing Analysis: Iroquois and HANYS designed a statewide survey in 2012 to assess what HERDS survey data would be most useful, if shared, in support of a hospital’s response to an incident through improved planning and decision making, and to query what data hospitals may be willing to share with regional partners. Hospitals indicate that certain data collected from facilities by NYSDOH could, if shared with them, provide information which could effectuate response capabilities.
- Capabilities Survey: Iroquois and HANYS designed and conducted a statewide survey of hospitals to identify hospital priorities and needs related to HPP capabilities and OHEP deliverables for the 2011-12 GY.
- Hospital Preparedness Program Informational Toolkit: Developed and distributed a hard copy and electronic compendium of over 100 essential planning documents and key resources to assist emergency preparedness coordinators.
- CEO Summits: Conducted CEO Summits to educate executives on development and integration of emergency preparedness plans, and communicate with hospital executives on a regular basis.
- Visual Dx: Provided Visual Dx diagnostic and treatment software to hospitals for one year and facilitated discounted contracts for continuation post grant funding.
- Webcasts: Hosted webcasts on issues such as new Joint Commission emergency preparedness standards, after action review of response to the 2009 H1N1 Influenza Pandemic.
- Rural Hospital Preparedness: Identified and reported on barriers to meeting preparedness goals for rural hospitals and develop strategies to address.
- Best Practices: Conducted surveys and research to provide information to NYSDOH and hospitals relating to best practices and capabilities based planning.
Iroquois has contributed to state and federal preparedness priorities and initiatives through participation in workgroups such as:
- Federal Grant Realignment and Reauthorization
- Federal Target Capabilities Review Group
- NYSDOH Situational Awareness Work Group
- NYSDOH HPP Funding Strategy Work Group
- NYSDOH Informatics Governance Team
- NYSDOH Pandemic Influenza Planning Group
- NYSDOH Emergency Volunteer Registry Workgroup
- NYSDOH HERDS Redesign Work Group