Crafting a Written Emergency Disaster Plan for Your Medical Practice

February 4, 2014

Would your medical staff know what to do in the event of a power outage, active-shooter incident, or data breach? An emergency plan is a critical first step.

While your practice may have rock-solid employees or other policies in place, you need to make sure your plans for what to do in the event of unexpected emergencies are well-documented. Otherwise, staff could be scrambling when a hurricane or other emergency hits.

This means crafting policies on what to do to cover unexpected emergencies - whether power loss from a hurricane or a data breach, said Nicole K. Martin, a Flanders, N.J.-based healthcare regulatory and corporate attorney and founder of Martin Law, LLC.  For example, in the event of a breach, a written document should outline a plan of action to mitigate the damage and contact patients. For information on what to do if your practice experiences a data breach, see bit.ly/post-breach-MD.

"The best way to protect is to have your policies, your procedures, your education training and your plans for any type of disaster in place," said Martin. "It's important for there to be effective implementation of processes and plans. And I think it's critical for there to be education or training of staff … so there's a familiarity of what your organization, large or small, would do in case there was that type of emergency."

To start creating a plan, Martin advised the following steps:

1. Establish Guidelines: First, practices should figure out who will be tasked with creating an emergency preparedness plan. Have management identify those employees who will be key in developing and administering an emergency preparedness program - and then check into existing minimum requirements of what policies should include. "Since federal, state, and local laws and regulations define minimum requirements for emergency management, physician practices should [look to] legal requirements and obligations as a guide when developing an emergency preparedness and response plan, and crafting related policies," said Martin. "Practices should consult with legal counsel to navigate the laws and establish a clear understanding." Another place practices might want to look for guidelines is FEMA's business emergency preparedness and response website, as well as HHS' Office for Civil Rights' emergency preparedness guidance.

2. Plan the Plan: Next, figure out what the emergency preparedness plan will include.  Once practice management has identified the laws and legal requirements that must be included in a policy, they should also make sure it leaves space for the policy to include information on identifying and assessing risks to emergencies (such as data breach or weather-related incidents), and methods to avoid or minimize risks.

3. Draft the Emergency Plan: Once you know what an emergency preparedness plan should include, it's time to start writing. Since you've already identified risks, now it's time to research and write, in detail, what the emergency responses to various incidents will be - for example, how information technology systems will be managed, and the roles of various staff. It should also include information on education and training of employees to respond to different emergencies, said Martin.

Martin also advocated for practice drills (not unlike fire drills) so that administrative staff or managers can see how well plans work in action.

Finally, make sure your staff is well aware of where to find those written emergency plans so they have some guidance on what to do when the unexpected happens, for example, in the case of a power outage or a fire.

"[Our emergency plan] is posted in our break room and readily available," said family medicine physician Joseph Scalia, whose six-physician practice, Raritan Family Healthcare, in Raritan, N.J., was affected by both Hurricanes Irene and Sandy. "It's really just simple, step-by-step instructions on what to do to get each system up and running again - who to call, how to transfer the system running off the T1 line to the back-up cable line, how to get the telephone system rebooted or transferred to our answering service. It also lists instructions on who to notify … [and] instructions on notifying patients about rescheduling appointments if needed."

Want to read more about preparing for unexpected emergencies? See "Preparing Your Medical Practice for Unexpected Emergencies."