Healthcare leaders more often think about their preparedness for disaster response than they do to the process of recovery and resuming normal operations. However, a smooth recovery requires attention to business continuity issues that are integrated across response, recovery and the return-to-normal-operations phases.
A continuity planning team that includes representation and support from executive leadership can provide the structure necessary to accomplish the preplanning needed to minimize the impact of an emergency on operations. The continuity planning team can establishing recovery time objectives, prepare for more effective facilitation of important recovery processes across key time bands and as the event and response evolve. They might even be called upon during the most disruptive events to help the organization prepared for new norms of operations.
The first step is identifying the organization's critical business functions. These can include information systems, the supply chain, documentation of vital records and assets, payroll and finance, staffing, security and patient care.
It is best to think through one or two different scenarios identified in the organization's hazard vunlerability analysis, such as a pandemic and a heavy trauma event (earthquake, hurricane, tornado, tsunami, etc.). The reason is that different types of events will involve different types of risk. For example, staffing may be the biggest challenge in a pandemic event, but an earthquake may disrupt normal supply chain transportation routes.
This team can set triggers for the activation of recovery functions during the response, create processes for assessing and documenting recovery needs and ensure the integration of recovery functions into the organization's emergency operations plan (EOP). Some of the decisions that can be made prior to an event include:
- prioritizing critical communications and computer applications
- identifying and backing up vital records
- identifying alternate payment mechanisms for staff and vendors
- establishing processes to facilitate telecommuting
- preparing for damage assessment and salvage documentation (including photographs and video)
- planning for post-event staff rotation or to return to evacuated areas
Additionally, this team can determine if the recovery phase should be activated in a tiered or scaled manner or all at once.
In cases where sufficient recovery planning has not occurred, there is a greater risk that the disruption of services will last longer and resumption of normal operations will be delayed. Consider the impact of the shift toward just-in-time deliveries and limited on-hand inventories and how pre-established protocols might help preserve critical capacity until replenishment supplies can make their way to the facility.
Or consider the value of understanding in advance when to submit 1135 waiver requests for CMS Conditions of Participation (CoP), licensure for practitioners, EMTALA, Stark Self-Referral Sanctions Medicare Advantage out-of-network providers, Life Safety Code and HIPAA, as well as being prepared to take advantage of CMS flexibilities for increasing inpatient bed capacity and locations without a 1135 waiver.
Continuity planning can also help an organization more quickly prepare for post-event licensing, CoP and accreditation survey visits so they can re-occupy evacuated units or the facility more quickly. It will also help facilitate more organized consolidation of documentation on losses and the cost of the response/recovery in order to increase the accuracy of accounting, so the facility can receive the maximum relief funding due.
The actual presence of a document can even have an impact on the delicate balance of cash flow by resulting in funding being distributed sooner by FEMA, the Small Business Administration and other relief agencies.
