Usa.hospital.preparedness.2013.apr

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John R. Wible, 2012 1

ARRTC – 2013
Judgment – Proofing
and Contracts
John R. Wible, J.D.
General Counsel (Retired)
Alabama Department of Public
Health

Disaster Comes in Many
Forms


It Could Be Anywhere

Complete Evacuation of NYU Langone Medical Center, 10/30/12

New York Patients
Transferred

Patient transferred from NYU Langon 10/30/12


But, Even Before Then . . .


DCH Could Have Been Hit-
What If ?????


Government Authority to Act
in Emergencies: Model

► Legal authority is at its
peak at the emergency’s
peak
► As crisis comes under
control, legal authority is
subject to greater legal
constraints
► And attention shifts to
responsibility for costs
and damages/losses

-The Eye of the Storm-
What Really Happens in a
Disaster


Disaster/Planning
► Disaster -Any emergency that disrupts
normal community function causing concern
for the safety of its citizens.
► Planning - Prime function to minimize the
resulting loss of property, injuries, suffering
and death that accompanies a disaster.
► Goal - to minimize resulting injuries,
suffering, and provide continued quality care
to those patients in the hospital

So, what really happens?
► How do people’s relationships change?
► Do people think and react differently?
► Are the consequences the same as if you had
reacted “in the sunshine?”
► The “Outback Steakhouse Question,” are there
really “no rules?”
► How can you “rank” people in order or precedence
to receive vaccine, ventilators or treatment
according to ethical principles?
► Can you invoke “altered standards of care?
► What are the rights of staff to desert?


Effects on Victims and Staff
Psychological, physiological and physiological Symptoms:
► Irritability or anger, blaming or denial, mood swings, fear of
recurrence, hyperactivity, feeling stunned, helpless, numb,
or overwhelmed;
► Loss of appetite and energy, headaches, chest pain, and
fatigue;
► Isolation, withdrawal, diarrhea, stomach pain, nausea;
► Increase in alcohol or drug consumption;
► Nightmares and inability to sleep;
► Concentration and memory problems;
► Sadness, depression and grief;
All leading to BAD CHOICES


What if Power is Lost?
Also lost are:
► Sewage / water systems
► Lights/Cooling and heating elements
► Elevators and automatic doors
► Internal and external communications
► Ability to track ID and patients


Other Contemplated Losses
► Food, water and utensil supply
► Shortages of meds, disposables and DME
 You should anticipate the most critical
 Personal Hygiene / Sanitary Supplies
 PPE needed
 Food, meds and water w/evacuees
► Staff and Security losses
► Handling waste: medical and other
► Transportation and fuel

Don’t Be Bait for Liability
► Federal Issues
► Criminal Issues
► Administrative Issues
► Civil Issues
 Torts
 Contracts


Federal Law Causes of Action
► 1963 Civil Rights Act violations
 ADA, ADEA
 Section 504, Rehabilitation Act
► HIPAA
► EMTALA
► FMLA
► FLSA (wage and hour)
► OSHA
► FDA

The Health Portability and
Accountability Act (HIPPA)
(Amended by HITEC)


The “Golden Rule of
Documentation”
If it ain’t wrote down it didn’t
happen!

The way it is wrote down is
the way it happened
regardless of the way it

Confidentiality-
Access to Records

► General rule – (Privacy Rule) All patient
information is strictly confidential. You must
maintain patient information confidential
outside the necessary situation
► However – exceptions in emergency situations
 45 CFR 164.512 – emergency personnel and LE


Imperatives for Protecting PHI
► Improvements in health care and community
health require responsible sharing of some
PHI
► In the absence of privacy protections, patients
and others may avoid some clinical, public
health and research interventions to their
detriment
► Individual privacy protections must balance
with legitimate community uses of PHI, i.e.,
health research and public health

Methods to Avoid Liability
-DCH to media and
► Have only one or two voices
the public, IE., thousands of calls
► Train employees to route pts. to triage
regardless of ingress
► Use AIMS system or your own system for pt.
tracking (names only) external to your EMR
tied to central clearing house
► Follow up pts later with your EMR
► Document, document, document

Disaster Applicability
DHHS Says:
► Responding agencies will need to get PHI to
respond to emergencies
► Therefore a covered entity can disclose PHI
to emergency authorities in such an event.
► Attempt to have prepared systems that
minimize non-emergency disclosures
► See 45 CFR 164.512(b) public health
activities


EMTALA
► Section 1867, Social Security Act
► Must triage and stabilize then treat or transfer
► What if you are in a disaster?
 DHC found the Statewide Trauma System to be
very helpful
 Plan to set up emergency triage sub-stations
 Have transfer agreements – where and how
►Ambulances – is there prohibitive (exclusive) ordinance?
►ADPH bus kits

► If in a true disaster, unlikely HHS will pursue
23
John R. Wible, 2013

WHERE DOES EMTALA
APPLY?
Outpatients “I have a med. cond.”
EMTALA APPLIES
250 yds

Main Hosp. CAMPUS DED
Prov#444

DED “I have EMC” EMTALA
Women’s Ctr.
Prov. #444 applies
Sample

EMTALA Off campus DED = Dedicated Emerg. Dept.
does not Prov. #444 fac. No DED. 23
apply John R. Wible, 2013

Evacuation Plan – Have
One
And Stick to It
► Does it violate EMTALA?
► Plan w/ other facilities to take pts.
► Plan w/city, county and schools to use
vehicles and (importantly) drivers
 N.O. didn’t evacuate in part because though
they had busses, they didn’t have drivers who
had deserted
► Tenet-Memorial Hospital (N.O) settled suit
involving evacuation plan

OSHA in a Disaster – Plan!
► Have pre-emergency drills implementing plan,
practice sessions using the ICS System
► Establish lines of authority and communication
between incident site and hospital personnel
► Designate disaster team including ED MDs,
nurses, aides and support personnel w/PPE
► Designate alternate sites
► Post-emergency critique of the hospital's
emergency response – OSHA Pub. 3152
(1997) John R. Wible, 2013 26

Fair Labor Standards Act
► Plan should include use of reserves and
time off where possible
► Time off may be given later or
► Overtime pay required for non-exempt
employees
► If you have a Gov.’s Proclamation, a
Stafford Act declaration and are executing
your approved disaster plan, it is possible
that you may be designated a state entity
and eligible for 80% reimbursement

Pure Food, Drug & Cosmetic
Act
► Be careful about transferring
legend drugs to unlicensed aid
stations w/o pharmacy or pharmacist
► Plan a work around of this. Work with city to
have pre-established aid stations
w/pharmacist coverage
► Pharmacists can be obtained and
dispatched through ADPH volunteer
network

Licensure Issues
– Bed Capacity
► Code of Ala.1975 Chapter 21 of Title 22
requires you to be designated with
maximum bed capacity
► This may be exceeded in emergency by
contacting ADPH Bureau of Health Provider
Standards for a temporary waiver
► Probably can be done through AIMS
► This will not be your biggest problem


The Joint Commission (TJC)
On Nov. 24, 2008, TJC imposed requirements
related to emergency management
► The hospital has Emergency Operations Plan
► The hospital engages in planning activities
prior to developing its written EOP
► The hospital prepares for how it will:
communicate, manage resources, provide
security, staff, and grant privileges to other
practitioners during emergencies

Criminal Complaints
It can happen – just ask Dr. Pou in N.O.
 Trespass
 Assaults and
Batteries
 Theft of property
 Conversion
 Offenses involving
sexual misconduct

Civil Liability, Lawsuits,
Defenses and Immunities
Torts
Contracts
Defenses
Immunities
Insurance
Loss Prevention


Torts
► Anactionable wrong
under the law
 Negligent torts
Not This
 Intentional torts
 Strict liability -Probably not
a concern here
► Recoverable in a civil
action against you This
► Filed in Circuit Court
► The plaintiff wants money
damages John R. Wible, 2013 33

Types of Torts
► Malpractice and professional liability
► General tort liability – negligence for an act or
omission
 Economic loss
 Non-economic loss
► Gross neg., wanton misconduct, bad faith
► Vicarious liability and Respondeat superior
► Negligent recruitment/training/supervision
► Premises Liability (slip and fall, glass in
beans)


Negligence
The failure to act or perform in a
particular situation as any
other reasonable prudent
dispatcher with similar training
would act under the same or
similar circumstances.

John R. Wible, 2013
35 35

Negligent Torts Examined
► Negligent torts arise from the failure to use
reasonable care under the circumstances,
causing recoverable damages.
► The “reasonable man” test” is applied
► Bad results aren’t enough
► Professional liability – failure to use the
degree of skill and care expected of a person
in the profession


Proving Negligence
►“Intentto cause harm” is not required
►Four things are required to be proved
 Duty
 Breach of the duty
 Injury or damage
 Proximate cause

John R. Wible, 2013
37

“Punnies” Awarded for:
► Gross negligence - reckless disregard of the
consequences to the safety or property of
another
► Willful acts - intentional, conscious and directed
toward achieving a purpose
 Wanton acts - grossly negligent to the extent
of being recklessly unconcerned with the
safety of people or property
 Reckless behavior–similar to gross
negligence John R. Wible, 2013
38

Exceeding the Scope of Practice

The range of professional activities that a
licensed professional is permitted to
perform under a state licensing statute,
further defined by the professional’s
experience and training
► Licensing statutes
► Training and ability


Standard of Care
► Establishing– can be set by statute or by
governmental rule or by the court
► Measures of determining the standard
 Behavior is compared with others with similar
training and experience
 Compared w/ locally accepted standards
 Compared to statutes or administrative rules
 Compared with professional standards published
nationally
►I have a plan to alter the std. in emergency
John R. Wible, 2013
40

Breach of the Standard of
Care
► The standard of care for a professional is
the “reasonable person” negligence doctrine
in a professional services context.
► Standard liability issues center around
whether the person has maintained the
“standard of care.”
 See Code of Ala.1975 §6-5-548 .
 See also Humana Medical Corporation v.
Traffanstedt, 597 So. 2d 667 (Ala. 1992)
A “Dam” Breach
41
John R. Wible, 2013

Medical Malpractice
► Malpractice: professional misconduct or
demonstration of an unreasonable lack of
skill with the result of injury, loss, or damage
to the patient
► Med-Mal is subject to a special statute
 Code of Ala. 1975 §§ 6-5-480, et seq.
 Code of Ala. 1975 §§ 6-2-38 and 6-5-410
► Hospitals are covered as well
42
John R. Wible, 2013

Corporate or Group Liability
 Corporate Negligence
 Vicarious liability
/Respondeat superior
 Negligent recruitment/training
/supervision
 Premises liability


Premises
Liability–“Shelterees”
► Plan for “sheltrees” – uninjured persons from
neighborhood or brought by LE
► Some unattended pediatrics, some geriatric
w/attendant & inherent problems
► Plan for minimum of 8 hours until ARC can
open shelters, then plan for transport there
► Plan for sheteree animals , bites & ETC.
► Prevent thefts – get supp. lights and security

Negligent Hiring, Training,
Supervision or Retention
► Direct
liability of an employer for acts or
omissions of employees based on the
employer’s failure to use reasonable care in
 Selecting workers
 Training them
 Supervising their work, and
 Terminating their services when necessary
► “No good deed goes unpunished”

John R. Wible, 2013
45

Respondeat Superior
 The master is responsible for the acts or
omissions of his/her servant committed
“within the scope and line of duty”
 Not on “frolic and detour”
 Hospital is responsible for the
acts of personnel in the line of duty
Though not “independent contractors”
 Doctor is responsible for the nurse under
his/her control


Failure to Plan
 Three possibilities for negligence liability:
Absence of a plan
Inadequate plan
Failure to follow plan
 Reasonable care: probability of an event, gravity of
potential injury, and burden in adequate precaution –
See Lacoste v. Pendleton Methodist Hospital .
Supreme Court of Louisiana. 2006
 Forseeability - U.S. v. Carroll Towing Company
 Punitive Damages – wanton and willful misconduct

Who are the Potential Plaintiffs?

And who will represent them?


JUDGMENT PROOFING
AND DEFENSES

Two Very Important Ques.
► Can you make the hard calls?
► How much risk are you willing to plan to
take?


Making Hard Calls - Principles
► To tell the truth, the whole truth
and nothing but the truth
 No Delta Principle
 The Principle of the Plumbline
 Free at Last!
► “We’ll Sing in the Sunshine”
► Casper the Friendly Ghost
► It’s not about me
► The “Nike Principle.”

Planning -“Bryant’s Rule”
Patton’s Corollary
► Have a Plan
► Work your Plan
► Plan for the Unexpected
Coach
► “Plans must be simple and Bryant
flexible. . .made by the people who
are going to execute them.”

John R. Wible, 2013 Gen. Patton
52

Plan “Beyond Your
Wildest Dreams”
► Plan must be beyond your “wildest dreams.”
 -Janet Teer, General Counsel DCH System
► Expand your concept of “disaster”
 Not 10-100 pts in ED but 800-1500 anywhere
► Get a team on the planning process
w/deadlines
► Plan in accord with TJC
► Reviewed by local EMA

Triage Planning
► Get a Plan. See “Bryant’s Rule”
► Get a Triage Review Committee
 Plan
 Oversee
 Evaluate post-event
► Engage the public in the discussion
► An experienced triage officer


Modern Disaster Triage
► In disasters there is a switch from
standard medical ethics with the
primary focus on Individual
autonomy to an ethics of public health with
a primary focus on the health of the
community
► The overarching goal is to minimize
morbidity and mortality during the pandemic
(according to CDC)
► Will it be most good or greatest need?

Specific Template for
Disaster Planning-Vent.
Triage ESF 8
► ADPH develops a template for disaster
planning and resource allocation, the
Ventilator Triage
► We recommend you adopt it as your plan
► It may give state agency immunity. See
http://www.adph.org/CEP/assets/VENTTRIA
GE.pdf


Statute of Limitations
► Settime period for injured party to file lawsuit
► Torts -Generally 2 years
 Includes wrongful death, PI, and A & B
 Trespass – 6 years
► Contracts – Generally 6 years
 Could include personal injury under contract
 See more later


S/L – Med Mal
►2 years from reasonable discovery
► No more than 4 years from occurrence
► Minors – 4 years after discovery or 8 th birthday
► Award
 Actual out of pocket expenses
 “Non-economic loss” – capped at $400,000
 Punitive damage cap of $250.000 unconstitutional.
► Requires expert of the same discipline
58
John R. Wible, 2013

Damage Caps for HCAs
► Code of Ala.1975 § 22-21-318(2) caps
damages against a “health care authority” at
$100,000
► Does not apply to a for-profit hospital
► Does not apply to a purely county or
municipal owned hospital


Malpractice Insurance
► Covers any [costs & damages the physician/
employer/ employee must pay if (s)he sued
for malpractice and loses [to policy limits]
► All licensed and certified medical
professionals should carry malpractice
insurance or have hospital provided
► Can be an expensive type of insurance for
some disciplines
► Hospital carries general liability and D & O

Types of Med-Mal Insurance
► Claims-made insurance - covers insured
party for claims made only during the time
period policy was in effect
► Occurrence insurance - covers the
insured party for all injuries and incidents that
occurred while policy was in effect regardless
of when claim is made
► Limits – Usually $1-3 Million including
defense costs

Hospital Insurance
► In addition to med-mal
► Should cover premises liability – Agree w/ co. &
know what is (in)(ex)cluded. Ask questions
► “Soft market,” you may be able to negotiate
add’l coverages w/ Pro Assurance, Coastal or
McNeary
► Consider coverage for HHS/CMS civil penalties
► Have high $ “umbrella” gen’l liability coverage
► May have to be re-insured

Goals -Altered
Standards of Care
Goal!
► Maximize the number of lives saved.
► Changes necessary to allocate resources
► Basis for allocation - fair and clinically sound
► Process for decisions - transparent and fair
► Protocols flexible and “scalable”
► Staff concerns addressed pre-event


Focus Change - Altered
Standards
► Critical : Focus Changes from
doing to best for each patient to
maximizing the most lives saved
► The system becomes the pt.
► Affect current patients already in hospital
► The scope of practice changes
► Equipment, meds and supplies rationed
► Record-keeping changes

Emergency Management
Under Code of Ala.1975, § 31-9-2:
 Governor proclaims an “emergency” defined as:
Enemy attack, sabotage
or “other hostile action;”
Fire, flood and “other natural causes.”
 Definition is broad enough to cover public health
incidents or naturally occurring events like
hurricanes and tornadoes.
 Amendments add “Public Health Emergency”


Governor Proclaimed
Emergency
► Activationof State EOP
► Tab A (Pandemic Influenza) to Incident
Annex A (Biological Incident Annex) A
► ADPH is responsible for ESF #8 Public
Health and Medical Services


Governor’s Powers

 In addition to those earlier listed, §31-9-6
also provides authority to:
 Make orders, rules and regulations;
 To utilize all state employees;
 To utilize any state or local officers or
agencies, granting state officer immunity
to such, including volunteers.


Personal Liability Protections
Code of Ala, 1975 §31-9-16 provides
that:
► Except for willful misconduct, gross
negligence or bad faith, any “emergency
management worker” (EMW)is granted
state officer immunity.
► Requirements for licenses to practice do
NOT apply
► “Emergency worker” is anyone helping
out whether paid or not
► The business or corp. is also an EMW

Property Protections

§ 31-9-17 provides similar
liability protections apply to
those permitting the state to
use their real property


Volunteers
► PrivilegingProfessional Staff
► Consider using ADPH volunteer registry to
have volunteers pre-vetted and qualified
► Also, such volunteers may be “state agents”
and thus subject to immunity. Further state
agents do not transfer liability to the agency
► The “guy who shows up with a chainsaw”
should be routed to the Red Cross.

The Volunteer Service Act
§ 6-5-336. Volunteers
Defined.
A person performing services for:
• a nonprofit organization
• a nonprofit corporation
• a hospital
• a governmental entity
• without compensation
“Minuteman”


The Volunteer Service Act
The volunteer is immune from civil liability
► in any action on the basis of any act or
omission
► resulting in damage or injury if:
acting in good faith and within the scope of
duties;
for a covered organization; and
damage or injury was not caused by:
willful misconduct;
or wanton misconduct by the volunteer
► DoesNOT immunize the organization,
however

CONTRACTS


What is a Contract
Simply, an exchange of
mutual promises.
► Written or oral
► To do legal acts


Types of Instruments
► Contracts
► Grants
► Benefit
► Agreements
► Amendments
► Purchase Orders


Elements of a contract
► Offer,
► Acceptance,
► Consideration
► Detrimental Reliance
► “Boiler plate”
► “In writing”

(Sorry, I thought it said, “Elephants of a contract”|

Contract Suggestion - DCH
► Just in time contracts – work with contractor,
IE., Cardinal, to establish pre-packaged kits,
like “push-pak,” for main and alternate sites
► Make sure supplier contracts and contractors
have connections to get your supplies, like
generators, in a hurry and can handle volume
► Make sure it’s in writing or at least followed up
with a letter stating your understanding of the
verbal agreement. (See slide 17.)

Amendments
► Same formalities as the instrument which it
amends
► Same process as the instrument which it
amends


MUTUAL AID
AGREEMENTS
► What is Mutual Aid?
► Types of Mutual Agreements
► State Emergency Mutual Aid Compacts
(EMAC)
► EMAC in the Broader Sense
► Cost Reimbursement Issues
► Characteristics of Private Agreements


Mutual Aid: Key
► Characteristics
Generally by written agreement
► Agreements cover:
 Activation Procedures
 Liability, employment and compensation
 Federal reimbursement where appropriate
► “Voluntary”’ response
 Do not “guarantee” assistance provided
► Indicates mere “desire” to respond when
requested, if able
► Specifies terms/conditions/procedures

Mutual Aid: Key
Characteristics
► Compensated vs. donated
 Most current mutual aid agreements do
not provide for compensation or direct
reimbursement for small-scale incidents
 In most mutual aid agreements are
applicable to major responses,
requesting jurisdiction reimburses the
costs of the responding jurisdiction


Intra state Mutual Aid

The National Emergency Management
Association has developed a Model
Intrastate Mutual Aid Agreement to assist
states in reviewing their existing legislation.
 http://emacweb.org/docs/NEMA
%20Proposed%20Intrastate%20Model-
Final.pdf


The MOU- Alabama
Prospective
► Alabama Hospital Mutual Aid MOU (59 sigs)- See
http://www.adph.org/CEP/assets/Mutual_Aid_Compact_includin
g_Exhibits_final.doc
► MOUs define rights and responsibilities only
► Parties: ADPH, hospitals, other providers, responder
communities, other regional parties
► Disaster – proclaimed, declared or not
► Limitations – players and resources
► The need: identifying & providing resources,
personnel and & care and moving patients

The MOU - Purpose
► Purpose - to identify interested parties and their
resources to support the coordination of local,
state, and multi-state resources to respond to an
emergency or disaster
► MOU is supplementary to participant’s EOP,
procedures and protocols
► MOU supplements States’ EOPs, statutes and
regulations


MOU – Not Obligatory
► No party is legally obligated to accept patients or
send staff, supplies or resources when to do so
would compromise its local service mission
► However, participants agree to try to assist and to
advise of availability of resources through Incident
Management Systems
► The purpose is to coordinate sending and receiving
of patients, staff, equipment, staff and resources
through the EOCs


MOU – Normal EMA Chain
► Participants follow usual system of going through
the local EMA including EMAC
► EMA should be tasked to escalate requests if
necessary and as high necessary
► Each participant identifies a knowledgeable Point of
Contact with authority to commit
► Participants will coordinate non-employee medical
staff who agree to volunteer


MOU Reimbursement, Non-
Exclusivity, Withdrawal
► No reimbursement is guaranteed but network
will facilitate reimbursement if any from federal
sources if not otherwise able to bill Medicare,
Medicaid or third party payor
► Participants are given opportunity to train
► The MOU is not exclusive
► Any participant may withdraw on 30 days
notice otherwise parties in “for the duration”

MOU - Liability
► Participants assume no liability merely by becoming
a signatory to the MOU
► However, participants may be liable for acts and
omissions of their staff in performance under the
MOU or governmental orders
► Also, in following their pre-approved plan, in case of
Declaration by Governor, there may be certain
immunities for staff


Transportation/EMS Contracts
► Out of state ambulances are forbidden to make
point to point runs within the state.
► Otherwise, state EMS rules
allow full use of ambulances from
out of state into the state
► Rules could be waived
► Would there be enough ambulances in a disaster
if all hospitals contract w/ same EMS ambulance
Co?
► What other vehicles could be used?
 Common carriers
 School & municipal buses

Transfer Agreement Issues
► Got appropriate transfer agreements?
► Could they go out of state perhaps?
► To what types of facilities?
► Do you have agreements with carriers?
► Are there backups for everything?
► Could your EMAC Agreements incorporate
•
cooperation on “transfer agreement”
language and use of resources?
► Security & supplies of personnel and
patients?
► Records be transferred electronically (EMR) ?

Private Agreements
– Should Address
► Voluntary nature, not a legally Reporting of bed capacity.
binding contract; rather it outlines a (In Alabama use AIMS )
general policy of cooperation and
coordination Auxiliary locations
► Communications including: liaison Contribution and sharing of staff
officers, EOCs, and joint public and who is retains responsibility
information centers (JPIC) for staff issues
► Forced evacuation – distributes Staff credentials & privileges
patients equally Volunteers’ issues
► Cooperation with NDMS activation Payment & reimbursement
► Mutual compatibility of and Interchangeability of parts and
adherence to JCAHC and
community disaster plans supplies
Hold harmless clauses
► Applicability to all disasters
regardless of size or proclamation Signatures and capacity


Contractual Liability
► Failure to achieve a promised result
► Failureto use a standard of care to which you
have committed
► Failure to render promised services
► Liability
assumed in a contract with a
response partner (indemnification and hold
harmless clauses in contracts)


Avoiding/Reducing
Liability
►Risk management is approached on two
levels
 Agency level and
 Individual level
►Avoiding liability means not being held
liable in court (it does not mean “can’t be
sued”)


Internal Practices to Reduce
Liability Risk
► Credentialing and assignment to appropriate
duties
► Criminal background checks
► Verifying necessary licenses (professional,
driving, watercraft)
► Clear activation and deactivation procedures
► Employee orientation, training and exercises
► Employee identification badges


Internal Practices to Reduce
Liability Risk (2)
► Written partnership agreements stating
roles & responsibilities
► Written engagement/utilization records
► Procedures for keeping patient treatment
notes
► Rules of conduct and grounds for dismissal
► Communications procedures
► Post-incident debriefing


Practical Advice – Liability,
Out of State Providers
► Disaster Privileges
 Photo ID, copy of current license, proof of
liability insurance, DMAT or MRC ID, (or
personal knowledge by staff member)
 Assign provider to area qualified to work
 Abbreviated orientation program for
emergency personnel
► Brief on state-specific liability issues:
 Lic., Good Samaritan, and Med-Mal Laws
► Consider using ADPH volunteer system to vet

See Also
► Hospitals and Community, Emergency
Response - What You Need to Know,
Emergency Response Safety Series, U.S.
Department of Labor – OSHA #3152 (1997)
► TJC Standards on Hospital Emergency
Planning: CAMH/Hospitals


More Resources - TJC
Healthcare at the Crossroads TJC
http://www.google.com/url?
sa=t&rct=j&q=&esrc=s&source=web&cd=2&
sqi=2&ved=0CCsQFjAB&url=http%3A%2F
%2Fwww.jointcommission.org%2Fassets
%2F1%2F18%2Femergency_preparedness
.pdf&ei=Fig9T7CXMIOltwfjur20BQ&usg=AF
QjCNH4MW08aTuQbRTDAwjj9i4oK6pwtg&
sig2=-KywQYc3ldurvHxWQ-WZ3Q

Example Hospital TJC Plan
An example plan is found at:
http://www.uhb.org/pnp/dsplan.htm . This is
from the State University of New York
Hospital System.


Finished – At Last!


Usa.hospital.preparedness.2013.apr

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