Preparing for a Hurricane
Hospitals and other health care facilities in the path of Hurricane Florence are currently preparing for the storm. In South Carolina a reported 177 health care facilities, including 19 hospitals, are being evacuated. Inland hospitals can expect an influx of patients from facilities that have been forced to evacuate. There may also see individuals injured during and/or immediately after the storm. Typical injuries after a hurricane might include crush injuries, thermal stress, electrical burns, musculoskeletal injuries and injuries from contaminated water.
Now is the time for hospitals expecting evacuated patients and/or individuals otherwise impacted by Hurricane Florence to review emergency response plans with staff, specifically addressing how patient surges will be managed. Now is also a good time to review HIPAA compliance with staff. The HIPAA Privacy Rule is not suspended during a public health or other emergency although certain provisions may be waived by the Secretary of Health and Human Services. Covered entities and business associates are reminded that they must have contingency plans that include or address the following elements:
- Data backup plan
- Disaster recovery plan
- Emergency operation plan
- Testing and revision procedures
- Application and data criticality analysis
Even without a waiver, the HIPAA Privacy Rule always allows patient information to be shared for the following purposes and under the following conditions.
- Public Health Activities
- Disclosures to Family, Friends, and Others Involved in an Individual’s Care and for Notification
- Imminent Danger
For most disclosures, remember that a reasonable effort must be made to limit the information disclosed to that which is the “minimum necessary” to accomplish the purpose. (Minimum necessary requirements do not apply to disclosures to health care providers for treatment purposes.)
Included with today’s notice are several example policies related to preparation and response to natural disasters as well as HIPAA requirement considerations during disaster relief efforts.
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