Emergency Preparedness for Opioid Treatment Providers (OTPs)
Supersedes OASAS Local Service Bulletin 2019-05
Date Issued: May 17, 2024
Recipient
- All Outpatient Opioid Treatment Programs
- Local Governmental Units (LGUs)
Purpose
The purpose of this Local Services Bulletin is to ensure Office of Addiction Services and Supports (OASAS) providers who administer outpatient opioid treatment services develop emergency preparedness plans that are coordinated with local behavioral health partners and emergency preparedness agencies and organizations, and that all OASAS-certified outpatient opioid treatment programs utilize the New York State Central Registry.
During OASAS-declared emergencies, opioid treatment programs (OTPs) must remain open during their regular medicating hours at a minimum. Premature or early closures will only occur after consultation with and approval from the NY State Opioid Treatment Authority (SOTA). OTPs may temporarily provide flexible take-home schedules of medication for their clinically appropriate active patients [consistent with 14 NYCRR Part 822.16 (c) (3)], to avoid strain on clinic resources. During OASAS-declared emergencies, OTPs must provide courtesy medication without charge.
Background
The New York State Office of Addiction Services and Supports (OASAS) certifies more than 100 outpatient opioid treatment programs that serve over 40,000 individuals on any given day throughout the State. Each of these programs is responsible for developing, maintaining, and updating a Comprehensive Emergency Management Plan (Plan) to prepare for, respond to, and/or recover from an internal or external emergency that may present an immediate danger to personnel, patients, programs, and/or property.
The objectives of each Plan are to:
- identify, assess and prioritize vulnerabilities to emergencies or disasters and the resources available to prevent or mitigate, respond to, and recover from;
- outline short, medium and long-range measures to improve the capability to respond to and recover from an emergency or disaster;
- provide for the efficient utilization of all available resources during an emergency or disaster; and
- ensure the continuity of operations in times of emergency or disaster situations.
While no Plan can cover every conceivable emergency or disaster situation and related response activity, the concepts and components outlined in this Local Services Bulletin (LSB) have a broad range of applicability to a wide variety of emergencies or disaster situations. This LSB will ensure that OASAS and its network of providers will have sound Plans, and the capability to continue operations in times of emergencies or disaster situations.
Notification and Ongoing Communication with OASAS Staff, Other Providers and Counties
OASAS providers are responsible for distributing updated agency-specific emergency management contact information to its respective Regional Office representatives and the SOTA on a quarterly basis. OASAS Regional Office personnel are responsible for initiating contact with its network of providers to ensure they are aware of the nature of large-scale incidents (e.g., major fire/flood, radioactive or chemical contamination, disease outbreak, sustained blizzard conditions, major natural gas pipeline eruptions, terrorist attack, or extended utility outage).
OASAS OTPs are responsible for notifying both Regional Office staff and the State Opioid Treatment Authority (SOTA) of small-scale, site-specific emergencies (e.g., power outages and downed power lines, etc.). Providers are reminded that the local County Emergency Management Office is the first line of defense, and providers should be communicating with their County Office of Emergency Management to ensure that they are aware of evacuation plans and other aspects of the county’s emergency response. The Department of Homeland Security and Emergency Services Office of Emergency Management has all county emergency management websites (with contact information) available online at: http://www.dhses.ny.gov/oem/contact/map.cfm.
Regional Office personnel and the State Opioid Treatment Authority should maintain ongoing contact throughout the response phase to ensure that OASAS OTPs can continue to protect the health and safety of those individuals in their programs.
Overview of Emergency Management in New York State
When an emergency or disaster is beyond a local jurisdiction’s capability, towns and cities (except the city of New York) will request help through their respective county government. Village governments will request assistance through their town government. Counties and the City of New York will request State assistance through the State Office of Emergency Management (SOEM). If it is necessary, at the direction of the Governor, New York State will request help from the federal government.
Direction and control of State risk reduction, response and recovery actions is exercised by the New York State Disaster Preparedness Commission (DPC) and is coordinated by the SOEM. SOEM coordinates state response and recovery activities under provisions of State Executive Law Article 2-B and the State Comprehensive Emergency Management Plan. OASAS is committed to ensuring that our provider network can appropriately interface with the local and county response agencies in times of emergencies. Furthermore, OASAS strives to also ensure that it is prepared to respond to an emergency as part of the collective state disaster response.
OASAS Role: Emergency Management in New York State
OASAS participates on the DPC and collaborates with SOEM, the Office of Mental Health (OMH), and DOH to:
- manage volunteer services;
- arrange for replacement of damaged/destroyed essential equipment;
- arrange for access of personnel to impacted area;
- arrange for transportation;
- prepare for the administration, safeguarding and recording of medications;
- develop legal opinions that support an emergency response (e.g., licensing, informed consent, confidentiality, providers licensed in other jurisdictions, personal, professional and organizational liability, patient records management, waiver of contracting or other procurement rules during emergencies); and
- submit funding requests from appropriate State/Federal agencies.
OASAS is the primary state agency responsible for promoting the continuity of opioid treatment programs during emergencies. OASAS provides emergency management guidance to certified substance use disorder prevention and treatment providers. These are coordinated with other State, county, and local entities such as: SOEM, OMH, DOH, Conference of Local Mental Hygiene Directors (CLMHD), Local governments (e.g., counties), professional organizations (e.g., InUnity (ASAP & Coalition for Behavioral Health), Committee of Methadone Program Administrators), and other substance use disorder prevention treatment providers.
RESPONSIBILITIES
Scope of the OTP Emergency Management Plans
Each OTP should have an emergency response plan that outlines overall provider policies and activities in three areas: risk reduction and preparedness, response, and recovery.
Risk Reduction/Preparedness/Mitigation
Focus on identifying natural, technological, or human-caused hazards (which may originate from an internal or external source), mission critical agency business processes and systems, potential continuity problems affecting the agency, and steps taken to prevent or mitigate those problems.
Note: OTPs must always keep three weeks to one month’s supply of methadone stocked as part of emergency preparedness.
Response
Involves measures to recognize and respond to an emergency, provide for a warning system, identify protective actions, and ensure that mission critical activities are carried out.
Response efforts also encompass efforts to alleviate damage, loss and hardship and other issues associated with business continuity. All OTPs should take steps to identify an alternate facility if one of its sites is rendered inoperable by an emergency or disaster. In some cases, portions of, or the entire agency facility may be uninhabitable, requiring the use of an alternate facility.
OTPs should have in place a plan that ensures necessary staff will be available during an emergency. Facilities should be stocked with batteries and equipped with generators to enable OTP functions during power shortages or outages. OTPs should always maintain and make available an up-to-date list of emergency contact numbers (such as fire, police, and nearby hospitals). No additional physician’s orders are needed to courtesy medicate patients during an emergency.
OTP plans should include provisions for emergency back-up communications with the New York State Central Registry – currently operated by Lighthouse, including but not limited to internet-enabled smart phones, laptops, computers, and tablets. Emergency Consent Forms must be prepared for patients to sign. Once patients have signed an Emergency Consent form, OTPs must check the New York State Central Registry to verify patient identification, dosage, and the status of the patient’s existing take home medication, if applicable, and medicate accordingly.
If the New York State Central Registry is not available, then the OTP should contact the patient’s home clinic for dosage and other relevant information. If neither the New York State Central Registry or the patient’s home clinic is available, the expectation is that the OTP prescribing professional exercise good clinical judgment and document accordingly when medicating. Good clinical judgement should consider that historically, patients have been honest and accurate when self-reporting their dosage during emergency events.
The emergency or disaster related to a hazard may have a severe impact on a provider, its facilities, and its system operations. Some emergencies or disasters will warrant the employees to take some sort of protective action, such as sheltering in-place or evacuating. In a widespread community disaster or emergency, employees may need to take the appropriate steps to ensure that safety and security of their families prior to returning to work.
Recovery
Recovery efforts include short and long-term strategies to restore agency business operations following an emergency or disaster and should include identifying ways to prevent/mitigate internal hazards and mitigate the effects of external hazards.
OTPs must maintain records of medication dispensed to patients, including courtesy medicated patients with secure identifying methods. If the emergency is a prolonged event, OTPs may provide more flexible take home schedules of courtesy medicated patients after consulting with their “home clinic”.
Disaster preparedness and emergency response plans should be developed to address all foreseeable hazards. Provider planning efforts should consider the business impact that a hazard may have and its ability to continue to operate and provide services. Certain planning assumptions should serve as the basis for the development and implementation of the Plan. A hazard may be of a natural, technological, or human-caused nature. This could have a negative impact on staff assignments. There may be disruptions in utility services including electric, gas, telecommunications, water, and cable. Vendors, county and local governments, and other state agencies that a provider normally deals with may also be responding to the emergency and may be experiencing some disruption in operations.
Aspects of an Effective Emergency Management Plan
Planning for emergencies is often a difficult and challenging undertaking. The Emergency Management field has developed a 10-Step Planning Process that has proven to be a successful method for developing, testing, and implementing an effective emergency management plan. Utilizing this format aids in developing plans that are consistent with existing methodologies and serves as a viable planning tool in identifying emergency preparedness before, during and after the emergency. These steps should also be followed to appropriately update any existing plans. A summary of the ten steps is as follows:
Step 1: Form a Planning Team
Providers should identify and designate an Emergency Manager who has the primary responsibility to act as a liaison between executive staff from the program and the SOTA. The Emergency Manager ensures that policies and initiatives regarding emergency preparedness are disseminated to individual departments/section leaders for implementation.
The Emergency Manager should develop an emergency planning team to guide the preparedness, response, and recovery planning efforts. As necessary, the planning team will coordinate response activities with the local emergency services, as appropriate. Planning efforts should not be conducted by one individual working autonomously from a group. The key is to utilize the expertise and support from those individuals that may be involved in the response organization. Utilizing a team approach will yield a quality Plan by incorporating the knowledge of others. The process not only provides an accurate reflection of response capabilities, but also fosters teambuilding, which will be invaluable in times of emergency.
Education and Awareness: OTP employees should be trained in what their role is in response to an emergency. In addition to training, employees should also receive awareness training in emergency response, such as how they will receive a warning, what the evacuation routes are, where the congregate area or assembly point is, and what is expected of each employee in an emergency.
Executive staff have the responsibility to ensure that all its employees have had the opportunity to receive emergency preparedness training. The training should be conducted at least annually, but preferably semi-annually.
Training should include:
- education on hazards that may impact the facility, both internal and external;
- familiarizing staff with the kind of protective measures that have been developed to respond to any emergency;
- how the employees will be warned in an emergency;
- what is expected of each employee; and the procedure for post-disaster follow-up and assessment.
Providers should reach out to their local County Office of Emergency Management or, in the case of OTPs located in the City of New York, to the NYC Office of Emergency Management, to ensure that the local emergency management network is keeping our OTPs in mind when doing preparedness training and emergency management and response.
Local Treatment and Prevention Emergency Preparedness: OASAS strongly encourages collaboration with county governments (e.g., County Mental Hygiene Directors, Conference of Local Mental Hygiene Directors, and Offices of Emergency Management), and other agencies (e.g., Coalition of Medication-Assisted Treatment Providers and Advocates) to support local emergency preparedness for substance use disorder providers.
Step 2: Hazard Analysis
At least once per year, each OASAS OTP should conduct a Hazard Vulnerability Analysis to determine the potential impacts on the facility. The analysis should include identifying both internal and external hazards. The analysis will assist in identifying where efforts would be best served in developing contingency plans and incorporating mitigation measures and activities. Examples of hazards are terrorism, fire, flood, hazardous materials accident, hazardous materials fixed site, utility failure, tornado, snowstorm (severe), hurricane, super storm rain and wind event (flooding), earthquake, ice storm, structural collapse, radiological accident, transportation accident, epidemic, indoor air quality, infestation, armed intruder, and civil unrest.
Identification and Analysis of Potential Hazards: This portion of the Plan provides for the identification of hazards that the provider must prepare for, respond to and recover from. Hazard identification should include internal hazards (e.g., fire) as well as external hazards (e.g., hurricane, chemical release). In assessing the external hazards, providers should consider obtaining advice and assistance from local response agencies as well as the appropriate state agencies. Several methodologies exist to identify hazards, ranging from the simple to the complex. It is important for each OTP to conduct a Hazard Vulnerability Analysis and to look at natural, technological and human-caused hazards. In addition to being an excellent awareness tool, the analysis should assist in identifying where efforts would be best served in developing contingency plans and incorporating mitigation measures and activities. Your local County Office of Emergency Management or, in the case of providers located in the City of New York, NYC Office of Emergency Management, can provide guidance.
Step 3: Risk Reduction
Upon completing a Hazard Vulnerability Analysis, providers should apply Risk Reduction (Prevention and Mitigation) measures to those hazards. Mitigation measures vary in application and expense, including both structural and non-structural concepts. Risk Reduction activities can range from the very expensive to a minimal expense, such as training and exercising. The key is to explore options, think broad-based and be creative.
For each hazard reduction action identified, the following information should be developed by the Emergency Management Team: a description of the action; a statement on the technical feasibility of the action; the estimated cost of the action; the expected benefits and the estimated monetary value of each benefit; and a prioritization of the actions being proposed.
Leadership should implement mitigation measures with both short-term and long-term methodologies. The short-term measures should be implemented right away. Long-term mitigation actions are generally more involved and are implemented over a longer period of time. Mitigation measures should also be considered where capital programming is under consideration or capital improvements are being made.
Examples of mitigation/risk reduction are: Incorporating physical security upgrades, including access and egress controls, perimeter security, credentialing, vehicle parking/storage polices, the use of bollards at primary exits and securing/upgrading the building air-intake system; incorporating the use of security window film to hold glass intact in the event of it being broken to help in preventing glass from becoming lethal flying projectiles; and incorporating the use of a back-up generator for use in emergencies or disasters that may have an impact on the availability or distribution of power.
Step 4: Capability Assessment
A Capability Assessment is a planning tool that is used to evaluate the effectiveness of an emergency response plan and the ability to implement it. A tabletop exercise is the choice methodology to use when conducting a capability assessment. In this exercise, key staff are presented a scenario of a simulated emergency. The exercise is designed to elicit discussion by participants as they attempt to resolve hazard-specific problems based on existing resources and procedures. Selection of the hazard should be based on actual or potential threats identified in the Hazard Vulnerability Analysis. The results of the assessment should assist in identifying both strong and weak points in current plans and should provide direct input into plan development or review. A Capability Assessment can be used to identify several key personnel and resources that are needed to ensure the ability to respond to an emergency and continue its operation.
Step 5: Testing Drills and Exercises
At least once per year, providers should conduct practical exercises to identify shortfalls, and incorporate lessons learned from the exercises. Exercises should be reality-based and test specific components of the Plan. Training and conducting exercises are important parts of testing the effectiveness of a Plan. Plans should be tested as part of the planning process and NOT during the actual emergency. A debriefing session is conducted after each internal or multi-location exercise and policies and procedures are revised accordingly. Additionally, this Plan should be reviewed annually for necessary updates and revisions.
Step 6: Community Involvement
This is comprised of individuals or organizations that will play a role in response to an emergency. Consider providing a copy of the draft plan for review and comment to those participants. This step serves as an educational piece, as well as an opportunity for incorporating more expertise.
When appropriate, providers should coordinate their plans with the other building tenants. A building-wide or standardized plan for the whole building is acceptable provided that the employers inform their respective employees of their duties and responsibilities under the plan. When multi-employer building-wide plans are not feasible, employers should coordinate their plans with the other employers within the building to assure that conflicts and confusion are avoided during times of emergencies. In multi-story buildings where more than one employer is on a single floor, it is essential that these employers coordinate their plans with each other to avoid conflicts and confusion. Because of the level of detail and coordinative planning associated with evacuations, each provider should develop an evacuation annex to the overall agency emergency management plan.
Step 7: Response
The Plan needs to bring together all the core concepts, capabilities and response mechanisms and assemble the information into a systematic format. This part of the Plan is the most crucial as it identifies the providers response to an event. A chain of command needs to be formally identified to alleviate confusion during an actual emergency. In addition, it also provides a good opportunity to identify primary and alternate staff to fill the positions and to maintain a manageable span of control.
Step 8: Planning for Recovery
Actions in this area should be developed to address questions such as: How long will it take to recover from an emergency? What programs are available to support in the recovery process? This step of the planning process should identify the short and long-term recovery steps, which should include seeking technical and financial assistance from all levels of government (local, state, and federal) in the disaster recovery process.
Step 9: Plan Approval
On an annual basis, providers must review their emergency plans to determine if they are still accurate and timely. This annual review must result in either the CEO or a member of the board of directors signing an attestation that a review was completed, and that the plan is still valid as written. This Annual Plan Attestation should be kept on file by the provider and will be reviewed by the OASAS RO as part of a recertification review, or by other OASAS bureaus as may be appropriate.
Step 10: Update the Plan
The plan must be re-evaluated at the end of an incident, regardless of its magnitude, for the purpose of review, training, and future enhancement of the Plan. A debriefing session will be conducted after each internal or multi-agency exercise and policies and procedures revised accordingly. After assessment of the incident, the plan should be updated and signed.
Source(s) of Further Information
Questions on the contents of this bulletin should be directed to OASAS Emergency Response Manager at: (646) 728-4511 or via email to [email protected].