Emergency Preparedness: Addressing Compliance Challenges

Healthcare facilities managers are dealing with important changes in the way their facilities comply with federal requirements for emergency preparedness.

By Dan Hounsell, Senior Editor


The last three years have been challenging for hospitals and other healthcare facilities, to say the least. The COVID-19 pandemic created its own complex issues for facilities, but it also exacerbated a host of existing issues, including shortfalls in funding and staffing and an unreliable product supply chain. 

Beyond these issues, healthcare facilities managers are dealing with important changes in the way their facilities comply with federal requirements for emergency preparedness. 

“The Joint Commission recently published new standards for emergency management, and a lot of those standards are a rewrite of the standards that existed before,” says Leah Hummel, senior associated director of advocacy for the American Society for Healthcare Engineering. “They did a reorganization of a lot of things, but they did add some new things.” 

The added requirements have created new responsibilities for managers, and they have reinforced the central role managers play in the way their facilities prepare for and return to operation after a crisis. 

Understanding roles 

Healthcare facilities managers are key players in emergency preparedness and compliance with federal requirements, but they are hardly one-person operations. 

“The biggest myth is that it’s primarily in the facility manager’s hands in terms of responsibility,” Hummel says. “Facility managers have a really important role to play in emergency management because they're in charge of utilities, and they're in charge of physical space. But emergency management is really intended to be done by a multidisciplinary team. Different members of the organization, whether they represent nursing or pharmacy or security or IT, they all have different needs.” 

Despite this team approach to emergency preparedness compliance, many organizations instinctively turn to facilities managers. 

“The requirements say that senior leadership needs to designate a person to be in charge of the emergency management program,” Hummel says. “What I saw during my time as a surveyor was that oftentimes, that person designated did have some kind of role within the facilities department.” 

Identifying challenges 

One challenge facing managers in their role in emergency preparedness compliance relates to the role of an organization’s leadership in ensuring the team has the required materials to achieve its goals. 

“One of the new (Joint Commission requirements) has to do with leadership, participation and oversight, and specifically leadership providing resources,” Hummel says. “It's not uncommon to go into an organization to survey and meet with their emergency management team and hear lots of things about the challenges that they face. But then when you ask what they have done about those challenges, they haven't been able to acquire the resources they need to be compliant. It's interesting that the Joint Commission made that an element of performance within their emergency management chapter to hold leadership accountable for having that oversight and providing those resources.” 

Hummel says many managers also face compliance challenges related to having a complete understanding of the capabilities of their facilities’ emergency power systems.  

"Most organizations have a diesel generator that is on site that provides power to the facilities when there's a loss of normal power,” she says. “But the amount of power that those emergency electrical systems are required to provide is not really intended to power the whole building and all of the utilities and everything. Organizations really need to understand what their capabilities are in terms of providing heating and cooling and ventilation and appropriate humidity levels.” 

The situation often is complicated by the likelihood that facilities have been expanded since original equipment and systems were installed. 

"A lot of organizations, especially if they've been built onto over time, may have capabilities to provide for heating and cooling during power outages in some wings of the facility and not in others because things have been built out over time. Understanding what the facility is capable of takes some dedicated time and effort.” 

To address these emergency power challenges, facility managers need to assess of their systems’ capabilities.  

"If they're not able to have everything on emergency power, have a plan in place for how they would provide for those safe temperatures and humidities during a loss of power,” Hummel says. 

Assessing risks 

Given the complexity of daily activities in healthcare facilities, it is understandable that planning for possible future crises does not get the constant attention it deserves from the organization. Hummel says managers can help the organization remain focused on emergency preparedness by assessing and emphasizing the growing range of threats to facilities. 

"Organizations are required to do hazard vulnerability analysis or HVA, where they look at the types of emergencies their facilities are subjected to and then think about the likelihood of those occurring,” she says. “With climate change, we’ve seen a change in weather patterns, a shift in the types of natural disasters occurring in different areas. 

“A few years ago, Texas had that giant ice storm, and that was unheard of. I think a lot of facilities probably hadn't planned for an ice storm like that because it's Texas, and they don't normally experience these wild, crazy temperatures. But we're experiencing more of these out-of-the-ordinary things. Organizations need to not set limits when they do their HVA to the things that they're used to happening." 

The nation’s unreliable supply chain also remains a potential roadblock for healthcare facilities that are required to stockpile critical materials. 

"Organizations are required to come up with a plan for 96 hours: How would they sustain themselves for 96 hours?” Hummel says. “They have to have everything they need in terms of being able to maintain safe temperatures in the facility and make sure their patients are fed and their staff is fed and they have potable water and fuel for their generator. 

“Some organizations choose to stockpile supplies and equipment to make sure that they're meeting that 96-hour requirement. But with supply chains, we’ve gone to so many just-in-time delivery systems. And there are organizations that have a lot of sister facilities throughout an area, and they count on each other to fulfill some of their needs.” 

Counting on other nearby facilities can be a risky approach to meeting the 96-hour requirement. 

“What if you're not able to transport anything on them anymore on the main feeder highways or roads coming into their facility?” Hummel asks. “That's one thing organizations need to think about: What would they really need in case of an emergency? Then make sure that they have those on time or on hand and aren't relying on others or on memorandums of understanding with vendors to acquire them in emergency.” 

Dan Hounsell is senior editor of the facilities market. He has more than 30 years of experience writing about facilities maintenance, engineering and management. 



April 27, 2023


Topic Area: Maintenance and Operations


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