POLICY: Emergency Preparedness Plan – Communication Plan
REGULATION: 42 CFR 484.102 (c) 4-6
It is the policy of Bridging Care for Families: a division of Multicultural Community Services of the Pioneer Valley Inc. to plan for sharing of information for evacuation of clients during an emergency. This Emergency Preparedness Communication plan will be reviewed and updated at least every 2 years. The Clinical Nurse Administrator or designee is responsible for activating the Emergency Plan and if required, declaring an emergency. The Clinical Nurse Administrator or designee has the ultimate authority to utilize the Emergency Plan when an emergency or a large-scale event occurs or in the event of any situation warranting the response of the organization. If a known or preparedness event, the Administrator or designee will implement this Emergency Management Communications Plan. The primary mode of communication for any/all emergency events will be secure facsimile, email, phone or cell phone. All communication needs will be reported to the Incident Commander.
This communication plan for sharing information is provided to allow for the proper sharing of information and medical documentation with other health care providers during an emergency to maintain continuity of care.
- All clients plan of care are reviewed at time of admission & at time of emergency and are triaged for care based on the priority rating documented in the medical record.
- All clients are given a priority rating which is utilized during an emergency.
- Continuous skilled nursing clients are either in the care of the agency nurse or primary caregiver. The client is never alone.
- Caregivers are trained in all aspects of the client’s care and must be able to perform the care if needed.
- All clients receive a paper copy of the plan of care once every 60 days or within 24 hours of a major change to the plan of care.
- MCS also has a Memorandum of understanding with Family Lives to provide additional nursing staff in the case of an emergency.
- If the client is no longer able to be treated in the home because of an emergency (e.g., no electricity, staff unavailable due to pandemic illness, caregiver sick with infectious disease), then the client will be considered for transfer to a higher level of care.
- The physician and any other agencies responsible for the client (e.g., DDS or DMH provider agencies as appropriate) will be notified of the transfer.
- Once the health care facility accepts the transfer of the client, the home health agency will share information about the client’s condition with the receiving facility.
- According to 45 CFR 164.510(b)(4) A covered entity may use or disclose protected health information to a public or private entity authorized by law or by its charter to assist in disaster relief efforts, for the purpose of coordinating with such entities the uses or disclosures.
- The agency will make every effort to obtain a verbal authorization from the client/legal guardian informing them of what information will be shared and with whom.
- The primary mode of communication of clinical documentation and sharing of client information during an emergency will be by:
- Paper record transfer with client during evacuation or during shelter-in- place (printout from EHR)
- Secure Email during client transfer,
- FAX if available during client transfer,
- Internal phone or cell phone during or while client in transfer,
- iPhone picture of records using secure text at the time of client transfer.
- vi. If the agency has no electricity but the receiving facility has electricity, a Virtual Private Network (VPN) will be set-up remotely by the IT Director. Only the client’s information will be available to access by the receiving facility. A specific username and password will be assigned to the primary health care provider at the receiving facility.
- All client’s who are transferred will be reported to the Incident Commander for tracking purposes.