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.
PPE Stockpile Regulation Changes
A revised hospital/nursing home PPE stockpile emergency regulation was adopted 1/26 and is in effect until 4/25.
Changes described below and at this link.
Existing methodology for calculating 60-day PPE stockpile remains the same BUT…Commissioner is given authority to change it. New reg references possible use of an HHS-developed methodology (HHS has developed a scenario-based PPE calculator for hospitals called DASH but we are unsure if DOH would adopt it)
New reg allows storage at an off-site location within NYS and if:
1. stockpile is accessible within 24 hours
2. hospital maintains at least a 10- day supply on-site
3. vendor maintains unduplicated, facility-specific stockpile
60 day PPE stockpile formula changed. Now based on average daily census rather than number of certified beds listed on operating certificate
New reg allows storage at an off-site location same as for hospitals.
NYS Surge & Flex and PPE Regulations
The Public Health and Health Planning Council adopted emergency regulations relating to Surge & Flex and minimum PPE requirements on July 29, 2021. The emergency regulations were most recently renewed with an effective date of September 20, 2022 to November 18, 2022. A summary of the regulations appears below.
State Executive Orders Issued and Emergency Waivers Granted During COVID-19 and Healthcare Staffing Shortages
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 Declarations due to COVID-19 and healthcare staffing shortages. Below are documents compiled by IHA which identify the scope of relief granted by federal waivers and state Executive Orders.
- Executive Order 11 – 11.9 of 2021: State Disaster Emergency Declaration Due to COVID-19 – NYS Laws and Regulations Temporarily Suspended or Modified Effective November 26, 2021 – September 12, 2022 (Not renewed beyond September 12, 2022)
- Executive Orders 4 – 4.17 of 2021: State Disaster Emergency Declaration Due to Healthcare Staffing Shortages – NYS Laws and Regulations Temporarily Suspended or Modified Effective September 27, 2021 – February 21, 2023
- Executive Orders 202 -202.92 of 2020-2021: State Disaster Emergency Declaration Due to COVID-19 – NYS Laws and Regulations Temporarily Suspended or Modified Effective March 7, 2020-June 25, 2021
- Federal Waivers Issued During the COVID-19 Federal Public Health Emergency Effective January 27, 2020 – May 11, 2023
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
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.
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 December 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
IHA has worked with member hospitals and coordinating work group project to support enhanced active shooter planning, training and exercise activities by identifying best practices, sharing lessons learned and developing supportive resources.
In 2014, IHA and Oswego Health coordinated a work group project to develop an active shooter plan template. IHA developed further guidance outlining critical planning and response considerations based on work group discussions, law enforcement recommendations, and after action reviews. Hospitals were reimbursed $4,500 through their HPP contract for adopting an active shooter plan.
Based on discussions of the 2013-14 work group and best practices, IHA developed a document outlining key planning considerations for developing active shooter plans. The document was updated in 2018 to reflect guidance issued by HHS ASPR. This document is also available to members by contacting Andrew Jewett.
In 2019-20, IHA and Cayuga Medical Center led a work group to identify best practices and share lessons learned for conducting training and exercises.
IHA members may contact Andrew Jewett for a copy of the documents referenced above.
Below are several key resources for hospital active shooter planning:
- Active Shooter Planning & Response in a Healthcare Setting – Comprehensive planning guidance developed by ASPR’s Healthcare and Public Health Sector Coordinating Council in 2017. The guidance incorporates unique aspects of the health care setting and special considerations such as operating rooms, neonatal units, medical gases, and providing care in an area wherein a potential threat exists. Appendix A (p.92) provides an active shooter policy template.
- Incorporating Active Shooter Incident Planning into Healthcare Facility Emergency Operations Plans This document, developed in 2014 by ASPR and other federal agencies, discusses challenges faced by healthcare facilities in planning and responding to an active shooter incident and addresses considerations for risk assessment, planning with law enforcement, training, and incident response.
- Planning and Response to an Active Shooter: An Interagency Security Committee Policy and Best Practices Guide – The Department of Homeland Security developed this guidance and policy document in 2015 for federal facilities. Its preparedness, training, response and recovery recommendations may be referenced and incorporated by healthcare facilities as well.
- Active Shooter Exercise Development Manual – A workshop manual by Texas A&M Engineering Extension Services (TEEX) for developing Homeland Security Exercise and Evaluation Program (HSEEP) compliant Table Top Exercises (TTX) to test active shooter plans.
- Sit Stat – Information Sharing to Support Medical Surge and Emergency Events: IHA launched a situational awareness and information sharing pilot project in October 2021 to support medical surge and other emergency events. Sit Stat is a web-based platform designed to collect and display data on operational status and impacts to enhance preparedness and response capabilities at the facility and regional health system level. The purpose of Sit Stat during COVID-19 response has been to support decision making related to surge management and patient transfers. The platform can support facility and regional response during mass casualty incidents, weather events and other emergency incidents. An overview of Sit Stat and a sample dashboard may be viewed here.IHA is partnering with Greater New York Hospital Association (GNYHA) which developed the platform. The system is regularly used by more than 115 GNYHA-member hospitals downstate. 25 IHA-member hospitals are currently participating
- 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 developed strategies to address them.
- Best Practices: Conducted surveys and research to provide information to NYSDOH and hospitals relating to emergency preparedness 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 HEPC Active Shooter Work Group
- NYSDOH HEPC Continuity of Operations Planning Work Group
- NYSDOH HEPC Volunteer Management Work 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