Emergency Preparedness for Group Homes

Having been in Florida during Hurricane Nicole, the topic of emergency planning came to mind. The Arizona Administrative Code section pertaining to emergency planning in assisted living facilities is A.A.C. R9-10-818. (Emergency and Safety). The Arizona Department of Health Services has also published a one-page paper outlining requirements and timelines for facilities to conduct drills and other emergency-related activities: AZ Dept. of Health Evacuation and Disaster Drill overview

One important item to note is that a disaster drill is different from an evacuation drill.  Disaster drills must be conducted quarterly, and include only staff onsite at the time of the drill, for each shift maintained by the facility.  Evacuation drills are to be conducted every 6 months and include everyone onsite: staff, residents, volunteers, etc. In the assisted living setting, this does not have to be performed on each shift, but for residential behavioral health homes, an evacuation drill must be performed on each shift. There are exceptions to requiring all persons onsite to practice the evacuation drill. For example, if there is resident whose medical record contains documentation that evacuation from the assisted living facility would cause harm to the resident, that resident does not have to participate. Sufficient caregivers to ensure the health and safety of those residents who are not evacuated, are also expected to remain on the premises. (See A.A.C. R9-10-818(A)(5)(b)).  For those who do participate, some homes try to make a game or activity out of the event. They may have balloons at the gathering spot to “reward” the residents for participating, or a special snack in the kitchen when everyone returns inside. Although the Department of Health expects you to time how long it took to evacuate everyone (and whether they needed assistance, etc.), this is not a race event. Safety is a priority and Management should consult with the resident’s primary care provider in advance of the evacuation drill if they think that it may be contraindicated for the resident to be included with the evacuation exercise. 

The fact that these drills are conducted should also be noted in the home’s documented disaster plan, which should be part of the facility’s overall policies and procedures, and must be reviewed annually. It is not sufficient for the manager to just sign and date the plan every twelve months. There must be a critique of the review itself, and, if applicable, recommendations for improvement, as well as a notation of which employees participated in the review. (See A.A.C. R9-10-818 (A)(3)).  This is, thus, a good chance for management to sitdown with the care team and discuss not only the typical fire, flood, power outage scenarios, but also to brainstorm ways to improve quality of care or the home’s environment.  Checking to ensure that batteries in flashlights are fresh, and coordinating a drill with checking the home’s safety alarm system are good practical ideas.  Even better than flashlights are headlamps, because using them allows both of the caregiver’s hands to remain free to assist the residents in case of a nighttime emergency.

Speaking of the residents, a manager shall also ensure that: a resident receives orientation to the exits from the assisted living facility and the route to be used when evacuating the assisted living facility within 24 hours after the resident’s acceptance by the assisted living facility, and that the resident’s orientation is documented. (See A.A.C. R9-10-818 (B)). In those cases where a resident has advanced dementia, we recommend that the manager or facility operator point out the displayed evacuation floorplan and exit routes, and discuss the quarterly and bi-annual drills that the home conducts in accordance with state regulations with the resident and their authorized representative, so that the representative will have an understanding of how the home approaches such situations.

When was the last time you looked inside the first aid kit inside of the facility? Although there may be several items that can be used for first aid in various locations in the facility, an actual first aid kit is required to be accessible to caregivers and assistant caregivers in Arizona. A.A.C. R9-10-818 (C).

There’s no requirement for backup or generator power, but it is a good idea to have an emergency charging station so that staff can maintain power to their mobile phones, or to run oxygen concentrators or other medical equipment in the event there is a lengthy power outage. Communications to family members should be coordinated, and depending on the circumstances, a proactive call to the state Ombusdman’s office to let them know what the facility is doing and why, may be warranted if a true emergency situation occurs.

While Arizonan’s don’t expect the kind of flooding and wind damage that occurred in Florida during hurricanes Ian and Nicole, an air conditioner breakdown in the heat of summer could constitute an emergency if the temperature inside were to exceed 84 degrees Fahrenheit.  (See A.A.C. R9-10-819 (A)(4)).  Other situations could give rise to implementation of the disaster plan, so the facility manager should be familiar with it and be able to refer to it as needed. As the saying goes, expect the best, but plan for the worst. And for a refresher on disaster drill vs. evacuation drill requirements, refer to A.A.C. R9-10-818.

Footnote: It is interesting that the regulations specify that evacuation drill documentation must be maintained for at least 12 months following the evacuation drill, but there’s no such time requirement for maintaining disaster drill documentation in Arizona. (See A.A.C. R9-10-818 (A) (4-5).

Look for more weekly blog posts on topics of interest to Arizona Assisted Living and Behavioral Health operators.  The information herein is intended to be educational and an introduction to the subject matter presented. It is NOT specific legal advice to be relied upon for specific individual circumstances. Contact your own legal professional or reach out to our firm if you would like specific advice on this topic.  We welcome topic suggestions!  Write to info@pinkowskilaw.com if you are curious to learn more about a certain topic impacting assisted living or other group housing concerns.