Is Your Facility Truly Prepared for an Emergency? The OIG Says “Maybe Not”

Is Your Facility Truly Prepared for an Emergency? The OIG Says “Maybe Not”

Nursing homes play a vital role in keeping vulnerable residents safe, but recent emergencies in facilities (e.g., hurricanes, infectious outbreaks, fires) have revealed critical vulnerabilities. Recently, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a sobering report, shedding light on concerning gaps in how state inspectors are reviewing emergency plans in nursing homes, and it calls for action.

What Did the OIG Find?

The OIG reviewed how State Survey Agencies (SSAs), which inspect nursing facilities on behalf of CMS, are evaluating emergency preparedness. The findings were mixed:

Some states have developed promising practices, offering guidance to surveyors, sharing sample documents with facilities, and providing collaborative training opportunities.

On the other hand, many SSAs reported that CMS guidance is too vague, leading to wide variation in how inspections are conducted. This means some facilities may receive a thorough review while others may have significant gaps that go unnoticed. Specifically, SSAs struggle to consistently assess:

• • • Whether staffing plans are realistic for emergency situations.
    • If evacuation plans are feasible given each facility’s unique challenges.
    • Whether documentation adequately reflects coordination with local emergency services.

Why Is This a Big Deal?

Emergency un-preparedness can cost lives. In past disasters, such as hurricanes in Louisiana and wildfires in California, tragic nursing home outcomes have made national headlines. Power outages, failed evacuations, and staffing shortages during crises leave vulnerable residents exposed to unnecessary risks. And while CMS requires every certified nursing home to maintain an “all-hazards” emergency preparedness program, the OIG report shows that inconsistent state oversight allows serious weaknesses to persist. In the report, the OIG issued two straightforward recommendations to CMS –

1. Give surveyors clear instructions for assessing the contents of facilities’ preparedness documentation.

2. Promote collaboration and info sharing among SSAs to harmonize survey methods.

Clearer guidelines and interstate coordination could reshape how nursing homes prepare for and respond to hazards. CMS concurred with both recommendations.

Recommended Actions for Nursing Homes and Administrators

Take a proactive approach:

• • Review your emergency plans now – do not wait for CMS.
  • Evaluate your staffing contingency plans.
    • Do you have updated, realistic staffing plans for all hazard scenarios (e.g., pandemics, power outages, evacuations)?
    • Are staff roles and responsibilities clearly outlined during emergencies?
    • Have staff received recent emergency preparedness training and drills?
  • Verify evacuation planning
    • Are evacuation routes clearly identified and regularly tested?
    • Do you have transportation agreements secured for various evacuation scenarios?
    • Are you prepared to safely evacuate all residents, including those with complex medical needs?
  • Build partnerships with local agencies and first responders.
    • Are you actively collaborating with local emergency management, fire, EMS, and public health agencies?
    • Do you have documentation of these collaborations and agreements in your emergency plan?
  • Keep your documentation clear and comprehensive. Anticipate how a surveyor might review your plans.
    • Is your plan comprehensive, up-to-date, and tailored to your facility’s specific risks?
    • Are risk assessments current and inclusive of new or emerging threats?
    • Is documentation readily available for surveyors showing training, drills, and collaboration efforts?

The OIG’s report serves as a timely reminder that preparedness is never “one and done.” It requires continuous attention, collaboration, and improvement. Federal action may take time, but facility-level leadership can, and should, act now to strengthen preparedness.

Next Steps:

Would your facility benefit form a fresh set of eyes on your emergency preparedness plan? Contact Proactive to schedule a review, assistance with updates and training for your team to maintain emergency preparedness.

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