Workplace Safety

Are you fully prepared when a disaster hits your area? Is your dermatology practice in coordination with federal, state, and local emergency preparedness policies and procedures? It is difficult to know when a disaster will hit your area, but it is essential that your practice be prepared for all manner of unexpected events so that your recovery period is smoother, should a disaster occur. Practices should comply with HIPAA and CMS policies and should update their preparedness plan annually. Fortunately, preparing for disaster is easier than it may seem.

Practices should address the following:

• Define disaster

• Designate a disaster recovery officer

• Conduct a risk assessment of potential disasters

• Identify gaps and vulnerabilities

• Develop policies and procedures for emergency response and disaster recovery

• Train staff on disaster roles and responsibilities, and test emergency response plans

• Establish a plan for annual review

• Ensure adequate insurance coverage

Define disaster

Disasters can be natural, such as hurricanes, earthquakes, floods, fires, or even sustained power outages. Some disasters are catastrophic. But specifically for a dermatology practice, any event that causes lasting interruption of operations can count as a disaster.

A dermatology practice should define disaster by how long operations are interrupted. Many organizations set a four-hour threshold. But each practice should set a threshold suited to its clinical and business needs.

Designate a disaster recovery officer

It is important for someone within the practice to be in charge of implementing and overseeing any policies related to equipment, office procedures, and more during an impending disaster. The person in charge will be the officer to also lead the practice’s response in case of disaster.

The disaster recovery officer(s) at your practice can be any staff that is ready to take charge, especially if a disaster hits the area.

Risk assessment of potential disasters

Develop an emergency plan that is focused on risk assessments. The emergency plan is considered as an all-hazards approach and should include the following: what is at risk; what the hazard may be; location and intensity of the scenario; opportunities to prevent or mitigate the situation; probability of risk occurring; and finally, the overall hazard rating.

The disaster relief officer should lead an effort to assess potential disasters, based on likelihood and impact. A good place to start is by surveying disasters that have occurred historically.

Determine how vulnerable the dermatology practice may be depending on location. The overall hazard rating can be scored how your practice sees fit. For example, a score of 0-4 can be defined as:

0- unlikely
1- distant
2- occasional/sporadic
3- likely
4- frequent

Assess goals your practice needs to meet to prevent these risks from occurring and determine how to achieve the goals and the staff responsible. Once you’re comfortable, implement the plan and update it on an annual basis.

There are a variety of tools available to help practices with disaster risk assessment, some of them free. See the Resources below.

Identify gaps and vulnerabilities

If your practice does have an emergency preparedness plan already in place, identify what the current situation is and recognize any gaps. These gaps may include: disconnect in communication; backup phone and data plan; being fully compliant with HIPAA regulations; having a plan in place that all staff is aware of and that good patient care is available through the event; approaches on training and involving staff; and backups to retrieve medical and administrative resources.

Build off what exists in the current plan and avoid any repetitive efforts by assessing a systemic inventory throughout the practice.

Develop disaster relief policies and procedures

Each practice must develop a disaster recovery policy and emergency response policy. Disaster recovery means restoring operations to normal. Emergency response means how the practice responds to the disaster as it unfolds.

Formulate a communication plan to share with practice and clinical staff that complies with federal and state laws. If your practice participates in the Medicare or Medicaid program, make sure to comply with the Emergency Preparedness (EP) rule. Consider using a phone tree.

The disaster recovery officer should ensure that staff understand their roles and responsibilities in case of disaster or emergency. Tip: Include initial training during on-boarding activities for new staff members. Coordinate emergency exercise drills to test out emergency plans and go through different relevant emergency scenarios that could occur at your practice.

If you participate in the Merit-based Incentive Payment Program (MIPS) and your practice has been impacted by a disaster in the area, don’t forget to apply for an Extreme and Uncontrollable Circumstances Hardship Exemption through the Quality Payment Program.

Insurance

Regular business insurance will cover many disasters and emergencies, but there may be critical gaps.

Business interruption insurance is meant to replace lost revenue and can be important for paying staff salaries.

Contents insurance covers equipment and assets inside the business. If the practice stores expensive pharmaceuticals at risk of loss, these should be included in coverage.

Cyberinsurance covers data and is described more in Protecting Health Information During Disasters.

Learn more about insurance in the DermWorld feature “Disaster Strikes.”

Resources

Kaiser Permanente Hazard Vulnerability Analysis tool*: Needs assessment that provides a systematic approach to recognizing risks and hazards. This tool was designed for hospitals but may be useful for any practice.

FEMA Emergency Response Plan*: This document can help the practice identify important emergency response goals and highlights the need for good planning and documentation.

CMS emergency preparedness requirements*: This document specifies emergency response requirements for practices that take CMS reimbursement.

FEMA risk assessment template*: This table template can be modified to how the dermatology sees fit, but includes important factors such as scenario, probability, impacts of existing mitigation, and more.

* The Academy is able to share these options on an informational basis only. It does not represent an endorsement by the Academy. Please compare, evaluate, and consider which ones best meet your needs.

Additional Academy resources