Is Your Facility Ready for Ebola?

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Polsinelli presents Crisis Management: a multi-part series (culminating in a webinar on 11.20.2014) on what companies must know to stay ahead of external interruption that risks serious impact to their business concerns. Second in this series, Kara Friedman of the Health Care practice explores strategies from past global health epidemics and hospital preparedness plans:

U.S. health care providers and the agencies that regulate them and oversee public health concerns are scrambling to ensure pandemic readiness in the face of isolated incidents of Ebola virus disease (EVD) exposure in this country. The unfortunate cases of EVD transmission to two health care workers treating the first patient to be diagnosed with EVD on U.S. soil caused near havoc in the impacted community and beyond. Fortunately, it also provided a learning opportunity for hospitals managing the disease on the front-line. EVD, which is much more straightforward to contain than a disease like SARS, is an extremely rare frequency, but high consequence event. EVD is not the first U.S. pandemic threat, and in recent years, HIV/AIDS, SARS and drug resistant tuberculosis containment efforts all demonstrated how health authorities and providers successfully mobilize to implement effective protocols to prevent the spread of infectious diseases.

As providers mobilize resources, they should have written EVD preparedness and response plans based on historical Centers for Disease Control and Prevention (CDC) guidance, which ensure:

  • Proper structure for planning and decision making;
  • Staffing needs and personnel policies, including training and education;
  • Availability of requisite supplies and equipment;
  • Clinical evaluation of symptomatic persons;
  • Infection control and isolation practices, including engineering and environmental controls;
  • Proper surveillance and triage methods;
  • Facility access controls;
  • Exposure reporting and risk evaluation; and
  • Public health communication.

These priorities were developed by the CDC in response to the SARS pandemic. Following a plan with this focus will allow for hospitals to adeptly manage an EVD incident.

Ultimately, the U.S. has robust systems for the treatment of patients with contagious diseases, and hospitals operate in a regulatory framework tailored for infection control. Despite some alarm, hospitals are generally well-prepared to implement procedures to contain and treat a patient with EVD. Isolation techniques and infectious disease containment is a high priority in the regulation of health care providers and general standards are well-developed. The Centers for Medicare and Medicaid Services Conditions of Participation for Hospitals Infection Control standards, along with similar state laws and accreditation standards, govern the conduct of hospitals relating to the management of infectious disease.

On October 20, 2014, the CDC published new guidance on personal protective equipment to be used by health care workers managing EVD patients. This update is one of the few new elements for providers to implement into their practices.

As a testament to the suitability of the existing regulatory framework to manage the EVD risk, on October 24, 2014, the Joint Commission updated its publications to delineate the accreditation chapters, which are central to identifying hospital capabilities to safely and effectively manage an EVD patient while minimizing the risk of transmission to others. The Joint Commission placed emphasis on the basics of preparedness and response which provide structure and enable the rapid detection, reaction, information gathering, communication and leadership templates needed to effectively design and execute a plan. The Joint Commission highlights standards, which are fundamental to an EVD response: Leadership, Environment of Care, Emergency Management, Human Resources, Infection Control and National Patient Safety Goals.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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