Emergency Preparedness/Evacuation Planning for Health Care Facilities in NYS

(Aug. 8, 2025) In the face of natural disasters, public health emergencies, and unforeseen crises, nursing homes must be equipped with comprehensive emergency preparedness and evacuation plans. In NYS, these plans are not just best practices; they are mandated by both state and federal regulations to ensure the safety and continuity of care for some of our most vulnerable citizens.

Providers in NYS That Require Emergency Preparedness and Evacuation Plans

Nursing homes, hospitals, assisted living residences (ALRs), adult care facilities (ACFs), hospices, and home care agencies (licensed home care services agencies (LHCSAs), certified home health agencies (CHHAs), and long-term home health care programs (LTHHCPs)) must comply with 10 NY Codes, Rules, and Regulations (NYCRR) and the Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Rule.

Understanding the Regulatory Landscape

Nursing homes in NYS must comply with:

Federal CMS Emergency Preparedness Rule, which outlines four core elements: risk assessment, communication, policies and procedures, and training
NYCRR, including 10 NYCRR § 415.26(f), which sets state-specific standards for disaster planning

These regulations ensure that facilities are not only reactive, but also proactive in their approach to emergencies.

Building the Foundation: Facility Profile and Risk Assessment

Every emergency plan begins with a clear understanding of the facility:

Basic details like name, location, and resident capacity
Identification of special populations (e.g., residents with dementia or mobility impairments)
A risk assessment follows, evaluating potential hazards such as fires, floods, severe weather, pandemics, and utility failures. This analysis helps tailor the plan to the facility’s unique vulnerabilities.

Preparedness Measures and Staff Readiness

Preparedness is more than stocking supplies; it is about building a culture of readiness:

Staff must be trained in emergency protocols and assigned specific roles.
Facilities should maintain emergency kits, backup power sources, and reliable communication systems.
Coordination with local emergency services and health departments is essential for integrated response efforts.

Defining Roles and Responsibilities

A clear Incident Command Structure (ICS) ensures that everyone knows their role during a crisis. Key positions include:

Emergency Coordinator
Department leads (nursing, dietary, maintenance)
Health Commerce System (HCS) contacts, including a 24/7 emergency contact

This structure streamlines decision-making and accountability.

Communication Is Critical

Effective communication can save lives. Plans must include:

Internal alert systems for staff and residents
Procedures for notifying families and guardians
Media protocols to manage public information
Integration with the Health Alert Network (HAN) for real-time updates

Evacuation Planning and Resident Tracking

Evacuation is one of the most complex aspects of emergency planning. Facilities must:

Use the Evacuation of Facilities in Disasters Systems (eFINDS), a statewide tool for tracking residents during evacuations using barcode bracelets
Maintain mutual aid agreements with alternate care sites
Arrange transportation that accommodates medical and mobility needs
Document every step to ensure continuity of care and legal compliance

Sheltering in Place

Not all emergencies require evacuation. In some cases, sheltering in place (SiP) is safer. Plans must include:

Backup utilities, food, water, and medical supplies
Safety protocols to secure the facility
Strategies to maintain normalcy and reduce resident stress

Recovery and Continuity of Operations

After the emergency, the focus shifts to recovery:

Repatriation of residents to the original facility
Damage assessment and restoration
Continuity of medical records and care plans
Staff debriefings and mental health support

Training, Drills, and Continuous Improvement

Preparedness is an ongoing process:

Facilities must conduct annual full-scale evacuation drills.
Tabletop exercises simulate scenarios for staff practice.
Post-drill evaluations identify gaps and drive improvements.

Supporting Documents and Resources

Every plan should include:

Contact lists for staff, emergency services, and vendors
Facility maps and floor plans
Copies of mutual aid agreements
Equipment and supply checklists
Sample forms for tracking and documentation

In NYS, specifically within NYC, all health care facilities are required to submit the Facility Evacuation Planning Application (FEPA) annually. This includes hospitals, nursing homes, and ACFs.

These facilities must complete and attest to their FEPA data each year as part of the Department of Health's (DOH) coastal storm and flood planning activities, typically between Jan. 1^st and March 31^st.

What FEPA Involves

Facilities must:

Assign a Facility Evacuation Planning Coordinator in the HCS
Review and update:
- Critical Asset Survey in the Health Electronic Response Data System (HERDS)
- Population to Evacuate (PTE) screen
- Send/Receive Arrangements with other facilities
- SiP requests (if applicable)

FEPA Coastal Storm Planning Attestation

These steps help ensure that facilities are prepared to evacuate or shelter residents safely during emergencies like hurricanes or floods.

Conclusion

Emergency preparedness in nursing homes is a moral and legal imperative. By developing a thorough, well-practiced plan, facilities can protect lives, maintain dignity, and ensure that even in the worst of times, residents receive the care and compassion they deserve.

Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146