QA Investigation Results

Pennsylvania Department of Health
CROSSROADS PHYSICAL THERAPY AND REHABILITATION INC.
Health Inspection Results

CROSSROADS PHYSICAL THERAPY AND REHABILITATION INC.
Health Inspection Results For:

There are 8 surveys for this facility. Please select a date to view the survey results.

Surveys don't appear on this website until at least 41 days have elapsed since the exit date of the survey.

Initial Comments:

Based on the findings of an onsite unannounced Medicare recertification survey completed on 9/10/2020, Crossroads Physical Therapy and Rehabilitation Inc. was found to have the following standard level deficiencies that were determined to be in substantial compliance with the following requirements of 42 CFR, Part 485.727, Subpart H, Conditions of Participation for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services - Emergency Preparedness.

Plan of Correction:

485.727(a)(1)-(2) STANDARD
Plan Based on All Hazards Risk Assessment
Name - Component - 00
§403.748(a)(1)-(2), §416.54(a)(1)-(2), §418.113(a)(1)-(2), §441.184(a)(1)-(2), §460.84(a)(1)-(2), §482.15(a)(1)-(2), §483.73(a)(1)-(2), §483.475(a)(1)-(2), §484.102(a)(1)-(2), §485.68(a)(1)-(2), §485.542(a)(1)-(2), §485.625(a)(1)-(2), §485.727(a)(1)-(2), §485.920(a)(1)-(2), §486.360(a)(1)-(2), §491.12(a)(1)-(2), §494.62(a)(1)-(2)

[(a) Emergency Plan. The [facility] must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:]

(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.*

(2) Include strategies for addressing emergency events identified by the risk assessment.

* [For Hospices at §418.113(a):] Emergency Plan. The Hospice must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:
(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.
(2) Include strategies for addressing emergency events identified by the risk assessment, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice's ability to provide care.

*[For LTC facilities at §483.73(a):] Emergency Plan. The LTC facility must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must do the following:
(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing residents.
(2) Include strategies for addressing emergency events identified by the risk assessment.

*[For ICF/IIDs at §483.475(a):] Emergency Plan. The ICF/IID must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:

(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing clients.
(2) Include strategies for addressing emergency events identified by the risk assessment.

Observations:

Based on review of facility documentation, and staff (EMP) interviews, the facility failed to develop, establish, review and maintain a comprehensive emergency preparedness program based on a facility-based and community-based risk assessment, utilizing an all-hazards approach.

Findings included:

Review of the agency "DISASTER PLAN" on 9/8/2020 at approximately 11:30 AM revealed, Policies " XXI. DISASTER PLAN, DISASTER PLAN AND INFECTION CONTROL, EMERGENCY FIRE AND DISASTER PLAN and PRN STAFF DISASTER TRAINING AND DRILL. "

A review of the facility documentation provided on 9/8/2020 at approximately 11:50 AM failed to provide evidence of documentation that the facilities emergency preparedness program was a facility-based and community-based risk assessment utilizing an all-hazards approach.

During interviews with (EMP1) and (EMP3) on 9/8/2020 at approximately 11:50 AM and 12:50 PM. The agency did have a Disaster Plan where policy reviews, disaster exercises and training were conducted by the agency. Although the agency staff was not aware of the Federal, State, and local emergency preparedness requirements. The surveyor reviewed the Emergency Preparedness requirements for OPT agencies with both employees. A review of a copy of the "State Operations Manual Appendix Z Emergency Preparedness for all Provider and Certified Supplier Types Interpretive Guidance Table of Contents" was also conducted with both employees.

An exit interview was conducted on 9/8/2020 at approximately 3:00 PM with the administrator and office manager that confirmed the above findings.

Plan of Correction:

Department of Health Plan of Correction Document – CrossRoads Physical Therapy and Rehab, INC
1. Emergency Preparedness Plan will be accomplished for CrossRoads Physical Therapy and Rehab, INC as part of review process dated 9/10/2020.
2. The other individuals potentially effected by the plan of care will include all staff members of CrossRoads Physical Therapy and Rehab, INC, local emergency response teams, FEMA officials, local police, fire departments, local hospitals and medical professionals who could be utilized in the emergency preparedness plan.
3. Internal clinic audits will be implemented to assure yearly review of emergency contact list, staff training, and volunteer/prn staff training yearly with established protocols in the policy and procedure manual of the operations. QI/QA coordinator will implement training procedures for initial education of the emergency preparedness training with the entire staff on October 27,2020 at the monthly staff meeting. Peer review and yearly policy and procedure reviews will occur quarterly and in January of each year, respectively. Update on plan will occur at Board of Directors Meeting in January of each year.
4. Monitoring of corrective action will be done in yearly Board of Directors meetings with yearly training of full-time staff and prn staff. A separate meeting with PRN staff and volunteers occurs each January to update this prn staff and volunteers to the clinic as a regular requirement of their emergency preparedness and disaster training program to include infection control, emergency procedures, and HR file update. Director of QI/QA performs quarterly peer and clinic audits using designated audit tools to ensure all policies and documentation are meeting the standards of practice for the state of PA (Appendix Z – state operations manual for emergency preparedness).
a. Director of QI/QA to perform quarterly training and audits
b. Operations manager to check and review QI/QA reports quarterly
c. Facility directors to review quarterly audits and educate staff
d. Administrator / CEO – will supervise all QI/QA reports quarterly and report changes to staff and board of Directors annually.
5. Correction action plan submitted to PA Dept of Health by 10/2/2020. Staff will be educated on approved plan of correction on monthly staff meeting dated 10/27/2020 pending state approval by Administrator / CEO of CrossRoads Physical Therapy and Rehab, INC with the assistance of QI/QA coordinator of CrossRoads Physical Therapy and Rehab, INC.

EMERGENCY PREPAREDNESS POLICY

Established January 22, 2018
Revised September 29, 2020

I. PURPOSE: To establish a policy for Emergency Preparedness Plan.

II. POLICY: Crossroads will follow the enclosed guidelines for any naturally occurring, facility-based, or community-based emergency.

III. RESPONSIBILITY: All Crossroads Management, Staff, and PRN/Volunteer Staff

IV. PROCEDURE:
A. Staff will familiarize themselves with the enclosed emergency preparedness guidelines.
B. Staff will, in the event of an emergency situation, notify the CEO, Facility Director, or OOM of the occurring or impending emergent situation.
C. Staff will follow the enclosed procedures for the specific emergent situation, as it occurs.
D. Local emergency departments will be notified of the Emergency Preparedness Program.
E. Staff signature sheets will serve as evidence that they have reviewed all documentation herein with regard to Emergency Preparedness.
F. Additional information can be found in the Disaster P&P Manual.

*Attached document, Emergency Preparedness Plan, will be updated every two (2) years or sooner, as needed. The Emergency Contact List will be reviewed yearly, updated and shared with the Board of Directors at annual meetings.

CrossRoads Physical Therapy and Rehabilitation, INC – Emergency Preparedness Manual

TABLE OF CONTENTS

Section 1: Summary .............................................................................
Section 2: Responsibilities in All Emergencies/Hazards .................................
Section 3: Fire Plan .................................................................................

Section 4: Tropical Storm, Hurricane or Tornado............................................
Section 5: Security Alert / Lock Down ..........................................................

Section 6: Combative Patient, Visitor, Associate...........................................

Section 7: Utility Outages.........................................................................
Section 8: Severe Hot or Cold Weather ......................................................
Section 9: Winter Storm ...........................................................................
Section 10: Bomb Threat ...........................................................................

Section 11: Hazardous Materials/ Bioterrorism ..............................................
Section 12: Pandemic Influenza ..................................................................
Section 13: Earthquake..............................................................................

Section 14: Evacuation Guidelines .............................................................
Section 15: Resuming Operations/Recovery .................................................
Section 16: Training..................................................................................

Section 17: Attachments

A: Facility Emergency Call List. .................................................
B: Non-Associate Emergency Call List ..........................................
C: Transportation Resources ........................................................
D: Associate Acknowledgement...................................................

SECTION 1: SUMMARY

The Emergency Action Plan does not answer every question or address/solve every problem that will be encountered in an emergency. The plan is a guide to describe how associates will prepare for, respond to, make decisions during, and recover from an emergency. It is important to realize that each emergency situation is going to be different. In any emergency, it is essential to think and act rapidly while using sound judgment and common sense. It is in everyone's best interest to be prepared should an emergency occur.

The Emergency Action Plan ("plan") serves as a guide for all associates to efficiently and effectively respond to any internal or external emergencies. The plan is designed to address extraordinary circumstances that may threaten the health, safety or property of CrossRoads Physical Therapy and Rehab, INC patients, associates and visitors. The plan provides a systematic and organized approach to access resources and assign duties and responsibilities during an emergency. The plan is intended to be flexible and quickly adaptable to maintain a safe environment within the rehabilitation clinic. CrossRoads Physical Therapy and Rehab, INC adopts the principles of the National Incident Command System and Incident Command System, used in most fire, Emergency Medical Services (EMS) and Police organizations.

All associates are required to be familiar with this plan and have an understanding of his or her role and function in an emergency situation -- BEFORE THE EMERGENCY OCCURS. Every associate plays a vital role in ensuring the success of this plan. The purpose of the plan is to:

- Provide guidelines in case of an internal or external emergency in an effort to minimize risk of injury to patients, associates and visitors.
- Delineate functions, duties and responsibilities during an emergency in order to maintain a safe environment for patients, associates and visitors.
- Distinguish between an internal disaster (i.e. fire, explosion, security) and an external disaster (i.e. severe weather, natural disaster, and chemical spill).
- Comply with Federal and Pennsylvania State regulatory requirements that mandate CrossRoads Physical Therapy and Rehab, INC to:
o Develop an emergency and disaster plan that includes procedures to be followed before, during and after an emergency or disaster
o Train all associates, staff, volunteers in emergency procedures at the time of hire and review the procedures annually with all associates
o Conduct unannounced drills.
- Fire drill will be conducted in one quarter of the year.
- Emergency or disaster drills will be performed in the other three (3) quarters of the year. This will include the practices of sheltering-in-place and evacuating patients; each will be practiced at least once annually.

CrossRoads Physical Therapy and Rehab, INC has developed written plans and procedures to meet potential internal and external emergencies including:

 Fire (CODE RED)

 Tropical Storm, Hurricane, Tornado, Earthquake, (CODE YELLOW)

 Security Alert/ Lockdown ( CODE GREY)

 Combative patient or visitor (CODE PURPLE)

 Loss of utilities (prolonged)

 Severe Hot or Cold Weather (prolonged)

 Winter storm, Blizzard, or Ice Storm

 Bomb threat ( CODE BLACK)

 Hazardous Materials/ Bioterrorism (CODE ORANGE)

 Pandemic influenza

 Evacuation

 Infection Control

 Resuming Operations/Recovery

 Training

SECTION 2: RESPONSIBILITIES IN ALL EMERGENCIES/HAZARDS
The following are generic descriptions of individual responsibilities during an internal or external emergency. It is important to realize that each emergency situation will be different. This list is not intended to be all inclusive.

Managing Partner/Member- Responsible with the approval of the other Members for the implementation, overall direction and coordination of the plan, coordinates with local and state emergency response organizations, serves as a liaison and communicates with other Members and directors.

ADMINISTRATION

 HUMAN RESOURCES- Maintains up to date phone lists and calls off-duty associates to fill needs. Assists in arranging transportation for associates, if necessary. Also secures associate files.
 REHAB DEPARTMENT - Provides support as directed by the Administrator or designee.
 ALL OTHER ASSOCIATES (Employed and Volunteer)- IN THE EVENT OF AN EMERGENCY, ALL ASSOCIATES MAY BE ASSIGNED A TASK REGARDLESS OF THEIR (ESSENTIAL/NON-ESSENTIAL) STATUS

All Press releases will be coordinated through the office of the Managing Member.

SECTION 3: FIRE PLAN -potenial risk = high

ANNOUNCEMENT:

- Announce "CODE RED"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "fire."
- Make the "all clear" announcement when authorized by the Clinic Director/designee on site or the Fire Department Incident Commander.

GENERAL INFORMATION:

- All associates will receive education during General Orientation and at least annually about
fire plan.
- Fire drill will be conducted in one quarter of the year.
- Fire drills will be unannounced.
- Fire bells will be tested regularly.
- Patients should not be brought in from outside of the building.
- All fire drills will be documented as to time, date, location and effectiveness.
- The "R-A-C-E" response sequence is posted.
- Elevators should not be used when the alarm bells are sounding.
- Associates should not cross area of the fire to report to their designated area.

FIRE PROCEDURES:

- Detection and Response
o Fire may be detected by sight, smell, heat/smoke detector or sprinkler function.
o The associate that locates the fire should immediately implement the "R-A-C-E" procedure:

 RESCUE any patients in immediate danger.
 ALARM go to nearest pull station and pull the fire alarm. Proceed to nearest phone and follow public address direction.
 CONFINE the fire by closing patient room doors.
 EVACUATE Begin assisting with the evacuation of patients away from the fire area as directed by the Clinic Director/designee.
 EXTINGUISH utilize fire extinguishers as the situation permits and ONLY if it does not place the associate at safety risk.
To use a fire extinguisher, remember: "PASS": PULL - AIM - SQUEEZE – SWEEP
- If someone's clothes are on fire: Stop, drop, cover the face, and roll.

ASSOCIATE RESPONSIBILITIES
Clinic Director/ designee is responsible for assuming the overall direction and control of the emergency operations of the rehab clinic.
- At the sound of the fire alarm, the Clinic Director/designee becomes the individual responsible for coordinating the clinic response of the associate(s). An Incident Command Center will be established unless it is deemed unsafe to do so. The Clinic Director/designee will relinquish responsibility when Fire Department Personnel respond.
o The Office Manager will notify "911".
o "911" will also be automatically notified by the alarm system monitoring company.
o The Clinic Director/designee will notify Maintenance associates.
o The Clinic Director/designee will designate an individual to monitor the fire personnel.
o The Clinic Director/designee will provide decision-making related to evacuation.
o Refer to the Evacuation Guidelines.

ASSOCIATE DUTIES - FIRE AREA
- Remove patients from the immediate fire area and place behind fire doors. Prepare for evacuation as directed by Clinic Director/designee.
- Close all doors and windows.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Check each patient treatment room to account for and rescue any patients, associates, and visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Transfer patient medical records to a safe area.

ASSOCIATE DUTIES - NON- FIRE AREA
- Check each patient treatment room to account for any associates, patients or visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Make sure all patients are accounted for.
- Transfer medical records to a safe area.
- Wait in safe, designated area for further instructions.

ASSOCIATES
- Secure immediate work area by closing all windows and office doors.
- Available associates are to report to the Office Manager's area and wait for further direction.
- Shut off all operating equipment.
- Secure immediate work area.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Fire Department Incident Commander
- Patients should be moved away from the fire area to the nearest secured area/hallway behind fire doors by an associate responding to that area.
- Patients' condition and the level of fire and/or smoke danger will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated.
- Refer to the Evacuation Guidelines.

SECTION 4: TROPICAL STORM, HURRICANE OR TORNADO -potenial risk = low

A Tropical Storm is an organized system of strong thunderstorms with a defined surface circulation and maximum sustained winds of 39-73 miles per hour. A tropical storm becomes a hurricane when winds reach 74 miles-per-hour. The tropical storm and hurricane season is typically June 1 - November 30.

- Tropical Storm Watch - issued when tropical storm conditions, including winds from 39-73 miles per hour, conditions are favorable or have created a risk.
- Tropical Storm Warning - issued when tropical storm conditions are either occurring or are imminent based on radar.
- Hurricane Watch - issued for a specified area for which a hurricane or hurricane related hazard is favorable and has created a risk.
- Hurricane Warning - issued when hurricane conditions are expected in a specified area
- Tornado Watçh - issued when tornados are possible in the area.
- Tornado Warning - issued when a tornado has been sighted or indicated by weather radar.
- Severe Storm Watch – issued when conditions are favorable or have created a risk of a thunderstorm capable of high winds.
- Severe Storm Warning – issued when a thunderstorm capable of high winds has been sighted or is indicated by radar.

ANNOUNCEMENT FOR TROPICAL STORM, HURRICANE OR TORNADO

.
- Announce "CODE YELLOW"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "tornado or hurricane".
- Make the "all clear" announcement when authorized by the Clinic Director/designee.

TROPICAL STORM, HURRICANE, OR TORNADO PROCEDURES

- Monitor the weather closely.
- Listen to the NOAA weather radio and/or local radio station for
instructions.
- Once a WARNING has been issued, follow the instructions below:
o When authorized by the Clinic Director/designee, make the "CODE YELLOW ALERT" announcement 3 times.
o Keep everyone inside the building.
o All associates must secure their work area.
o Everyone must stay away from all windows and outside doors.

ASSOCIATE RESPONSIBILITIES.

- Move ALL patients to the inside walls.
- Close windows, blinds, and pull privacy curtains. Any articles which may act as projectiles should be secured.
- Provide each patient a pillow to help protect his or her head.
- Wait for further instruction from the Emergency Services Incident Commander or designee.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Emergency Services Incident Commander (if applicable).
- Patients should be moved to the nearest secured area within the building until deemed necessary to move offsite.
- Patients' condition and the nature and location of the severe weather emergency will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated by the Clinic Director/designee.
- Refer to the Evacuation Guidelines
- Resources:

o http: / / www.fema.gov/areyouready/thunderstorms.shtm
o http: / / www.hazardscaucus.org/hurricanes_factsheet0909.pdf
o http: / /www.nssl.noaa.gov/edu/ safety/tornadoguide.html
o https: / /www.FloodSmart.gov (FEMA)
o https:// www.redcross.org/local/michigan (American Red Cross Locator Site)
o https://www.accuweather.com/en/us/novi-mi/48375/weather-warnings/338750

SECTION 5: SECURITY ALERT/LOCK DOWN -potential risk = low

LOCK DOWN
It is the utmost responsibility that CrossRoads Physical Therapy and Rehab, INC provide a safe and secure environment in which to live and work. This responsibility applies to any and all issues that may arise to jeopardize that environment which include criminal intent or action, fugitive/prisoner escape, unlawful assembly and disorderly/unethical/inappropriate conduct. The purpose of a Code Grey event is to take any and all measures deemed relevant to prevent a dangerous situation and/or an individual from causing harm and to further prevent the individual from gaining access to the clinic.

- Upon notification of an escaped prisoner or fugitive being in the local area, associates will be notified by the Clinic Director/designee.
- Upon notification, the Office Manager will announce Code Gray three times. Further instructions will follow depending on the incident. Such as:
o Armed intruder: Turn out lights, maintain silence, do not respond to alarms without assuring the area is safe and cautiously respond to noise.
o Rabid animal: Attempt to confine animal and get patients to safety.
o Escaped convict: proceed with lock down
- The Managing Member will be notified of lock down.
- Office Manager will immediately lock all doors.
- Associates receiving permission to leave during a Code Gray event may request an escort if available. Associates leaving during a Code Gray do so at their own risk.
- Upon conclusion of a lock down, an announcement for "all clear code gray" will be announced 3 times. Doors will be unlocked.

SECTION 6. COMBATIVE PATIENT, VISITOR, ASSOCIATE – risk level = medium
CrossRoads Physical Therapy and Rehab, INC strives to ensure a safe and secure environment for all associates, patients and visitors. To that end, the purpose of a Code Purple event is to address workplace violence, in any mannerism, including any act or attempted act of physical aggression, verbal abuse or harm by an individual. Aggression can range from threats and verbal abuse to physical assault or injury.

- In case of the need for assistance due to patient, visitor, and/or associate safety issues including workplace violence, the associates who encounter the situation will immediately notify the Managing Member or other available Members and request their assistance.
- If there is an emergent need for help to manage the situation, associate responsible party will announce Code Purple 3 times and the area in which to report.
- Associates should respond to the Code Purple location, assess the situation, and make the determination if additional outside emergency support is warranted. If warranted, an emergency service request should be placed; contact 911.
- Associates are not to attempt to restrain any intruder or visitor.
- Protection of the patients, visitors, and associates is to be achieved by using a calm, rational approach.
- Associates will move the patients in immediate danger to a safe location first.
- Patients will be relocated to a private room until the situation is over.
- If an injury to a patient, visitor, or an associate occurs, treatment will be initiated if needed, and the appropriate incident report will be completed.
- In a workplace violence situation:
o Stay calm
o Call or have someone make the 911 call and explain to the dispatcher the situation
o Listen attentively
o Maintain eye contact
o Be courteous and patient
o Maintain a quiet tone of voice
o Avoid arguing or making comments that might intensify hostility
o Avoid doing anything that will cause the assailant to take action
o Don't risk harm to yourself or others
SECTION 7: UTILITY OUTAGES – risk level = low

ELECTRICAL POWER FAILURE

- The emergency generator will be automatically activated within 10 seconds of a power outage.

WATER INTERRUPTION

- A water interruption will impact clinic services.
- When a water problem is identified, the Clinic Manager/designee should be immediately notified for a decision to cancel patient appointments and reschedule.
- For drinking water, emergency water will be distributed.
- For non-drinking water (cleaning and toilets, etc.), water is available from the hot water tanks.

SECTION 8: SEVERE HOT OR COLD WEATHER-risk level = low

Under normal circumstances, CrossRoads Physical Therapy and Rehab, INC heating and air conditioning system ("HVAC") will maintain a comfortable environment. The following steps should be taken when/if the HVAC system becomes inoperative for a prolonged period of time.

- Notify the building landlord by cell phone.
- Landlord personnel will assess the problem and notify the HVAC system repair contractor.
- If the HVAC contractor indicates a prolonged amount of time to repair the system, the Clinic Director/designee will make the decision to keep the clinic open or to close the clinic.
- If a patient appears to be in any danger of weather related stress, the attending Physician and/or "911" will be immediately notified.
- Patients' condition and the nature, location, and expected duration of the emergency will determine the fastest and safest method of evacuation.

SECTION 9: WINTER STORM – risk level = medium
- In the event of an impending winter storm, the Clinic Director/designee should turn on the NOAA weather radio for up-to-date weather information.
- Special attention should be given to winter storm warnings:
Winter Storm Watch - a winter storm is expected in our area within days.
Winter Storm Warning - a winter storm is occurring or will soon occur in the area within hours.
Blizzard Warning - sustained winds or frequent wind gusts up to 35 miles per hour or greater and considerable amounts of falling or blowing snow (reducing visibility to less than a quarter mile) are expected to prevail for a period of three hours or longer.
- Winter storms may produce snow, ice, sleet, strong winds, freezing rain, heavy snow and/or extreme cold.
- In the event of a blizzard, the "plan" will be activated by the Clinic Director/designee.
- The consequences of a winter storm include, but are not limited to;
o Associates not able to report to work
o Disruption of utilities and communications
o Freezing pipes
o Delay/disruption in delivery of supplies
o Structural damage to the buildings
o Delayed response capability of Emergency Medical Services

- Resources:
o www. weather .com
o www.weatherunderground.com

SECTION 10: BOMB THREAT- risk level = low
It is impossible to know if a bomb threat is real or a hoax. Therefore, it is imperative to treat all bomb threats seriously. Every effort should be made to minimize disturbance of patients and staff while attempting to locate and remove the bomb. It is important to try to remain calm and try to keep the patients calm while addressing the threat.

GENERAL PROCEDURE
- Keep the caller on the line as long as possible.
- Never place the caller on "hold".
- Ask the caller to repeat the message.
- If the phone has a display, copy the number and/or the letters on the display.

AFTER THE CALLER HANGS UP
- Notify the Clinic Director/designee immediately.
- Notify"911".
- Complete the attached "Bomb Threat Documentation Form".

ANNOUNCEMENT

- Announce "CODE BLACK".
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "bomb."
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Bomb Squad Incident Commander.

EVACUATION INFORMATION

- Patients should be evacuated immediately from the clinic and clinic building.
- As you evacuate, look for suspicious packages/objects/other items that do not belong there. Do not touch or remove any suspicious item.
- Keep all evacuees and associates together until Emergency Services personnel arrive. Do not re-enter the building or return patients to the clinic until authorized by the Emergency Services Incident Commander.

BOMB THREAT DOCUMENTATION FORM

Date: ______________ Person Receiving Call: _________________

Time: Telephone # call was received on: ______________

Caller's exact words: __________________________________________________

Questions to ask (if possible):

- When is the bomb going to explode? ______________________________

- Where is the bomb right now? _________________

- What kind of bomb is it? _____________________________________

- What does the bomb look like? _________________________________

- Why did you place the bomb? ________________________________

Try to determine the following: (Circle appropriate information)

- Caller's Identity: Male/Female Adult/Juvenile Age

- Voice: Loud Soft High Pitch Deep Raspy Pleasant

- Intoxicated/other _______________

- Accent: Local Not Local Foreign Region

- Speech: Fast Slow Distinct Distorted Stutter Nasal

- Language: Excellent Good Fair Poor Foul Other:________

- Manner: Calm Angry Rational Irrational Coherent Incoherent Deliberate Emotional Righteous Laughing

- Background Noises: Office Machines Factory Machines Bedlam Trains Animals Traffic Music Other__________

Additional Information: _______________________________________________________
__________________________________________________________________________

SECTION 11: HAZARDOUS MATERIAL/BIOTERRORISM EVENT -risk level = low

Hazardous Materials ("HAZMAT") is any substance that poses a risk to health, safety and property when released, spilled, or spread in sufficient quantities. These substances can be chemical, biological, or radiological. A HAZMAT event could occur inside the clinic building, in the vicinity of the clinic building, or in a wider geographical area. Most Bio-terrorism agents that would likely be used are in the form of bacteria, viruses, and toxins. Many of these agents break down quickly in sunlight and the environment while other, like anthrax, are long lived.

- Examples of a HAZMAT incident include, but are not limited to:
o Chemical spill
o Airborne hazard
o Bio-terrorism (including biological weapons or chemical weapons)
o Weapons of mass destruction
- In the event of an internal HAZMAT emergency occurring within the clinic or elsewhere within the building where the clinic is located, the services of the Fire Department, Police Department, Emergency Medical Services and the Blair County Division of Emergency Services should be utilized.
- When outside help is required, one of the agencies listed above should be contacted. See attached list of resources.
- In the event of a community-wide HAZMAT/ Bio-terrorism incident:
o Announce "CODE ORANGE"
o Repeat the announcement 3 times.
o Speak clearly and slowly.
o Never shout the words that would alarm patients.
o Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
o Initiate a facility lock-down. Close and lock all exterior doors to prevent movement in or out of the facility to minimize the risk of unnecessary contamination.
o Move all patients to a safe, central location within the building.
o Close all windows, blinds and patient room doors.
o Turn off heat/air conditioner in clinic.
o Maintenance will turn-off the facility HVAC system.
o Monitor radio broadcasts for updates. Public Health officials may not be able to provide information right away.
- If a bio-terrorism event is suspected, local emergency response systems will be activated. Guidance will be provided by Blair County Division of Emergency Services, Blair County Health Department, Bioterrorism Emergency Notification, and the Federal Centers for Disease Control.

- Evacuation can be authorized by the Clinic Director/designee, or the Emergency Services Incident Commander (if applicable).
o Patients should be moved to the nearest safe and secured area within the
building until deemed safe and necessary to evacuate off site.
o Patients' condition and the nature, location, and expected duration of the
emergency will determine the fastest and safest method of evacuation.

- If exposure to a biological agent occurs:
o Remove clothes and personal items and bag them. Follow official instructions for disposal of contaminated items.
o Wash yourself with soap and water and put on clean clothes.
o Contaminated persons may be asked to stay away from others or be quarantined.
- If a biological exposure is treatable, patients and associates will receive further instructions.

SECTION 12: PANDEMIC INFLUENZA- risk level = medium

A pandemic is a global outbreak of a serious disease that exceeds the "normal" levels of mortality and infection levels for a typical disease. A flu pandemic occurs when a new Influenza virus emerges for which people have little or no immunity and for which there is no vaccine. The disease spreads easily person to person, causes serious Illness, and can sweep across the country and around the world in a very short time. The length of the emergency could be as long as 6-8 weeks or more.

- The greatest challenge will be the maintenance of adequate staffing levels. It should be assumed that the associate population will be infected at the same rate that the patient population will be. In the clinic there must be the presence of two associates at all times when patients are being treated. If this requirement cannot be met, then the clinic must suspend services until able to be in compliance.
- Training includes infection control precautions, standard and droplet infection control precautions, respiratory hygiene, and cough etiquette.
- Educational awareness measures may include, but are not limited to, the following:
o Utilizing good hygiene by following recommended infection control protocols.
o Minimizing exposure by avoiding public gatherings, public places, and areas considered high risk.
o Updating vaccinations, including seasonal flu and pneumonia.
o Encouraging overall good physical health including eating right, drinking plenty of fluids, and getting enough exercise and sleep.
o Maintaining a positive attitude.
o Remaining home when sick.
- Strict adherence to infection control policies and procedures is critical.
- Post signs for cough etiquette.
- Determine when to restrict intake of new patients.
- Contact local and State Health Departments for vaccines and anti-viral medications.
- Implement contingency staffing plans as needed.

Resources:

flu/weekly! fluactivity.htm
http:/ /www.miemss.org/ alert
www.pandemicflu.gov
www.hhs.gov/ pandemicflu/ plan!
www.cdc, gov / flu/professionals/diagnosis
www.hhs gov/pandemicflu/plan
www.cdc. gov/flu/groups.htrn
www.cdc.gov/ flu/roups.htm
www.hhs.gov/pandemicflu/planjsup4,html
www.cdc.gov/flu/professionals/infectioncontrol/index. htm
www.cdc.gov/flulweekly/fluactivitvhrm

SECTION 13: EARTHQUAKE – risk level = low

An earthquake is a sudden, rapid movement/shaking of the earth caused by the abrupt easing of strains built up along geologic faults that have accumulated over a long time. Earthquakes strike suddenly, without warning. Earthquakes can occur at any time of the year and at any time of the day or night. Earthquakes are not totally predictable.

- Earth shaking does not harm you; building collapse and resulting fires do. Injuries and deaths are increased by human panic, so it is imperative to remain calm.
- Minimize your movements during an earthquake to a few steps to a nearby safe place. Chances of injury increase with movement.
- Stay calm and try to calm and reassure others. Think before taking action.
- If you are INSIDE when you feel an earthquake:
o Stay inside until the shaking stops. Move next to an inside wall or get under a desk or sturdy table and hold on to it.
o Remember to DROP, COVER, AND HOLD.
 Drop and cover under a desk or sturdy table.
 Hold on to the desk or table. If it moves, move with it, do not run, and stay in place.
o Stay away from windows, bookcases, refrigerators, heavy mirrors, and hanging objects that could fall.
o Do not go outside until the shaking stops.

- If you are OUTSIDE when you feel an earthquake:
o Get into an open area away from trees, signs, buildings, walls, electrical wires, and poles.
o Do not go inside any building.

- The first 72 hours after an earthquake are critical. Electricity, gas, water and telephones may not be working. In addition, public safety services such as police, fire and ambulance services will be extremely busy. We must be prepared to be self-sufficient for possibly 72-hours following an earthquake.
- Check for injuries. Check yourself first, then others. Give first aid as necessary.
- Call 911 to report life threatening emergencies.
- Set-up an area to care for injured and assign associates to provide care.
- Remain calm and reassure others.
- Do not move the seriously injured except away from danger or potential further injury.
- Stay away from damaged areas after patients have been moved.
- Avoid broken glass.
- Check gas, water, and electric lines. If damaged, shut off service.
- Replace all telephone receivers and use for emergency calls only.
- Tune to the emergency broadcast station on radio.
- The electricity may go out.
- The fire alarm and/or the sprinkler system may activate from the quake. Check for fire and take appropriate action.
- Refrain from flushing toilets. Sewer lines may be broken.
- Check shelves for objects ready to fall.
- Do not light flames, operate electric switches, or use the telephone, if there is a possibility of a gas leak.
- Expect and be prepared for aftershocks.

EVACUATION

- An evacuation can be authorized by the Clinic Director/designee member, or the Emergency Services Incident Commander.
- Patients should be moved to the nearest safe and secured area while evacuation procedures are implemented.
- The patients' condition and the nature and location of the building damage will determine the fastest and safest method of evacuation.
- Refer to the Evacuation Guidelines
- RESOURCES
hitp://earthguake.usgs.gov

SECTION 14: EVACUATION GUIDELINES

- During an internal or external emergency, it may be necessary to evacuate an area or perhaps the entire building to ensure the safety and well-being of patients, visitors and associates.
- The order to evacuate will be given by the Clinic Director/ designee or the Emergency Services Incident Commander.

ANNOUNCEMENT

- Announce "ATTENTION ALL STAFF, PATIENTS, AND VISITORS. PLEASE BEGIN PREPARATIONS TO EVACUATE THE BUILDING IMMEDIATELY."
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the words that will alarm patients.
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
- Repeat the announcement 3 times.
- Speak clearly and slowly.

TYPES OF EVACUATION / SHELTERING

- Evacuation-In-Place / Horizontal - Patients are moved to another safe location on the same floor within the building.
- Evacuation-In-Place / Vertical - Patients are moved to other floor levels within the building.
- Total Evacuation - Patients are removed from the building and moved to another offsite location.

ORDER OF EVACUATION

- Patients closest to the danger area.
- Ambulatory patients - Assemble in a group, wrap them with coats or blankets (if necessary), and walk them to safety.
- Wheelchair Patients - Assemble in a group, wrap them with coats or blankets (if necessary), and transport them to safety.

EQUIPMENT

- If evacuation of these items does not pose an unnecessary risk, take Medical Records to the designated safe area.
- Evacuation Sites: Depending on the nature, type, location, and expected duration of the emergency, both in building and out of building evacuation sites are available.
- Evacuation could necessitate using all modes of available transportation. Transportation will be coordinated by the Office Manager. Refer to attached for a list of transportation resources.
- All families will be notified of the evacuation as soon as possible. They will be informed of the reason for the evacuation, designated evacuation sites, and asked whether or not they can assist in the process in any way.
- If the evacuation is going to be long term or permanent, associates will:
o Assist in making transportation arrangements.
o Arrange for the transfer of medical records.

SECTION 15: RESUMING OPERATIONS

RECOVERY

- Following a major emergency, CrossRoads Physical Therapy and Rehab, INC will establish a "recovery team" that will prioritize steps to resume operations. The team will:

o Meet daily
o Keep detailed records including written documentation and/or audio and/or video and/or photographs of the incident
o Document damage from the hazard
o Document associate injury or illness from the hazard
o Conduct an investigation and coordinate with Local and State authorities.
o Coordinate with the insurance company.
- The Managing Member, in consultation with the other Members, will contact clinic's insurance broker.
- The recovery team will be directed by the Managing Member and consist of representatives appointed by the Managing Member
- The goal of the recovery team is to ensure the ongoing care, safety, and welfare of patients, associates and visitors.
- The recovery team will maintain ongoing communication with patients, associates, and their families. Assignments will be made for follow-up communication with:
o Local and State regulatory agencies
o CrossRoads Physical Therapy and Rehab, INC insurance carrier
o Vendors
- The recovery team will arrange for the protection of undamaged sections of the clinic and physically secure the premises.
- The recovery team will supervise clean-up operations including but not limited to:
o Restoration of utilities
o Removal of smoke, water, debris, etc.
o Separation of damaged and undamaged property. (Damaged property should be kept until the insurance adjuster approves removal.)
o Restoration of equipment and property
o Document recovery
o Maintaining appropriate sanitation and infection control procedures
o Security of the clinic.
- A list of vendors that offer recovery assistance will be provided per need.
- Depending upon the type, severity, and duration of the emergency, outside assistance will be available. (See attached list of resources).
- The recovery team will observe patients and associates for signs of stress and mental health issues. Counseling will be made available as necessary.
- The recovery team will maintain a chronological record of events for post emergency review.
- The recovery team will schedule a Post Emergency Meeting to discuss the emergency, lessons learned, and make recommendations to improve the clinic's emergency preparedness, response and recovery operations. Updates will be made to the "plan".

SECTION 16: TRAINING

- The Managing Members are jointly responsible for reviewing, updating, and implementing the Emergency Plan.
- The goal of Emergency Operations Plan training is to:
o Test and evaluate the clinic's Emergency Plan
o Clarify associates' roles and responsibilities
o Provide associates opportunities to practice their emergency roles and responsibilities
o Improve organizational coordination and communication
o Improve the "plan"
- Satisfy regulatory requirements.
- The purpose of "the plan" training is to:
o Reduce associate anxiety
o Improve performance, teamwork and decision making
o Reveal expectations about what is expected of co-workers
o Save lives.
- Training sessions will be scheduled on a regular basis and will include, but are not limited to, the following topics:
o Clinic response to a fire
o Evacuation using shelter-in-place
o Facility evacuation
o Emergency communications
o Facility response to a loss of utilities
o Responses after a traumatic event
- Training exercises will be both scheduled and unannounced.
- Types of training exercises include, but are not limited to:
o Table top- informal discussions of simulated emergencies and responses to specific situations in a low stress environment that does not disrupt patients.
o Drills - an exercise that focuses on a single, specific aspect of the "plan". In a drill, associates do not just talk about their actions, they actually perform them. Drills allow CrossRoads Physical Therapy and Rehab, INC to focus improvement efforts on a specific aspect of the "plan".
o Full-Scale Exercise - Tests many different aspects of the Emergency Operations Plan by simulating an emergency as realistically as possible. Provides the best feedback about what works and what does not work in the Emergency Operations Plan.
- All training exercises involve the following components:
o Designing the exercise
o Conducting the exercise
o Evaluating the exercise
o Improving the Emergency Operations Plan based on recommendations from the evaluation of the training exercise.
- Following a traumatic event, patients and associates should be monitored for the following traumatic responses:
o Anxiety - a reaction to a vague or unknown threat. Symptoms may include feelings of apprehension, nervousness, or fear often accompanied by physical symptoms.
o Fear - a reaction to a recognized threat.
o Panic disorder - sudden intense feeling of apprehension accompanied by physical symptoms.
o Post-Traumatic Stress Disorder - anxiety disorder that some people experience after seeing or living a dangerous event that includes extreme fear or horror.
o Depression - a mental state characterized by an inability to concentrate, insomnia, feelings of dejection and guilt, lack of hope and absence of cheerfulness.
- Patients and associates exhibiting any of the above traumatic responses should be referred to a Physician or mental health professional.

Attachment A
CrossRoads Physical Therapy and Rehab, INC Emergency Call List

Title/Name Department Business Phone Cell Phone
Chief Executive Officer
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Executive Team:
Managing Member
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Medical Director
Dr. Jason Henninger, DO Medical Director 814-684-2100 814-932-6263
Regional Office Manager
Sallie Fleming Executive Administration 814-696-3400 814-631-3901

Chief Financial Officer
Tim Parnell MSPT, ATC, EMT, CEO Accounting
Extension 814-696-3400 814-931-0012
Clinic Managers:
Aaron Kovach, DPT Duncansville Clinic 814-696-3400 814-215-9531
Seth Davis, DPT Martinsburg Clinic 814-793-3428 440-309-6654

Clinic Designee:
Krystal Disney, PTA – Director of QI/QA Duncansville Clinic 814-696-3400 814-931-3978

Director of Human Resources
Lisa Parnell Human Resources
Extension 814-696-3400 814-931-7895

Attachment B
Non- Associate Emergency Call List

Company Name Phone number Service
911 911 Police, fire, and ambulance response
Altoona Water Authority 814-949-2222 Water Supplier
American Red Cross 800-733-2767 Disaster assistance
Bioterrorism Emergency Notification 215-685-6740 Threat or Actual Bioterrorist Attack
Blair Co Sherriff's Dept. 814-693-3100
PA State Police 814-696-6100
Blair Co Health Dept. 814-695-7543 Homeland Security
Blair Co Facilities Management/Building Safety Dispatch 814-940-5900 Secondary point of contact for Homeland Security (OCHSD)
Bovard 814-941-4328 Heating and Cooling
Conemaugh at Nason 814-224-2141 Hospital/Emergency
Emergency Operations Center (EOC) 814-940-5900
Emergency Preparedness Coordinator of State 717-651-2001

Healthcare Coalition 717-561-5255 Regional
Emergency Preparedness and Response
MDHHS Communicable Disease/Immunizations 517-335-8165
Penelec 888-544-4877 Electricity Supplier
Peoples 800-764-0111 Gas Utility Supplier
UPMC Altoona 814-889-2011 Hospital/Emergency

Attachment C
Transportation resources

Company Name Vehicle type Phone Number Wheelchair
Accessible
Altoona Metro Transit Bus 814-944-4074 Yes
AMED Authority Ambulance 814-943-8993 Yes
AMTRAK Train 800-872-7245 Yes
AMTRAN Bus 814-944-4074 Yes
Blair Senior Services Van 814-695-3500 Yes
Hollidaysburg Ambulance Ambulance 814-695-3711 Yes
Hollidaysburg American Legion Ambulance Service Ambulance 814-695-1421 Yes
Lyft Taxi 855-865-9553 Limited Availability
MedVan Van 888-633-9995 Yes
Stat Medevac Air Carrier 814-941-6478 Yes
Uber Taxi 800-353-8237 Limited Availability

Attachment D

Associate Acknowledgement

I have received and read a copy of CrossRoads Physical Therapy and Rehab, INC Emergency Preparedness Plan. I understand that the statements contained in this plan are intended to serve general information purposes concerning CrossRoads Physical Therapy and Rehab, INC and its existing policies, procedures, and practices in the event of an emergency situation.
Since the information, policies, procedures, and practices described herein are necessarily subject to change, I acknowledge that revisions to the Emergency Action Plan may occur. All such changes will be communicated through official notices, and I understand that revised information may supersede, modify, or eliminate existing policies, procedures and practices.
I have received the Emergency Preparedness Plan and I understand that it is my responsibility to read and comply with the policies, procedures, and practices contained within this plan and any revisions made to it.

Associate Name (Printed) ________________________________
Signature _____________________________________________
Date _________________________________________________
Witness Signature ___________________________________

485.727(b) STANDARD
Development of EP Policies and Procedures
Name - Component - 00
§403.748(b), §416.54(b), §418.113(b), §441.184(b), §460.84(b), §482.15(b), §483.73(b), §483.475(b), §484.102(b), §485.68(b), §485.542(b), §485.625(b), §485.727(b), §485.920(b), §486.360(b), §491.12(b), §494.62(b).

(b) Policies and procedures. [Facilities] must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least every 2 years.

*[For LTC facilities at §483.73(b):] Policies and procedures. The LTC facility must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least annually.

*Additional Requirements for PACE and ESRD Facilities:

*[For PACE at §460.84(b):] Policies and procedures. The PACE organization must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must address management of medical and nonmedical emergencies, including, but not limited to: Fire; equipment, power, or water failure; care-related emergencies; and natural disasters likely to threaten the health or safety of the participants, staff, or the public. The policies and procedures must be reviewed and updated at least every 2 years.

*[For ESRD Facilities at §494.62(b):] Policies and procedures. The dialysis facility must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least every 2 years. These emergencies include, but are not limited to, fire, equipment or power failures, care-related emergencies, water supply interruption, and natural disasters likely to occur in the facility's geographic area.

Observations:

Based on a review of the facility's Emergency Preparedness Plan (EPP) and staff (EMP) interview, the facility failed to develop and implement Emergency Preparedness policies and procedures based on a community risk assessment and communication plan by the effective date of November 15, 2017.

Findings Included:

Review of the agency "DISASTER PLAN" on 9/8/2020 at approximately 11:30 AM revealed, Policies " XXI. DISASTER PLAN, DISASTER PLAN AND INFECTION CONTROL, EMERGENCY FIRE AND DISASTER PLAN and PRN STAFF DISASTER TRAINING AND DRILL. "

A review of the facility documentation provided on 9/8/2020 at approximately 11:50 AM failed to provide evidence of documentation that the facilities emergency preparedness program was based on a community risk assessment and communication plan.

During interviews with (EMP1) and (EMP3) on 9/8/2020 at approximately 11:50 AM and 12:50 PM. The agency did have a Disaster Plan where policy reviews, disaster exercises and training were conducted by the agency. Although the agency staff was not aware of the Federal, State, and local emergency preparedness requirements. The surveyor reviewed the Emergency Preparedness requirements for OPT agencies with both employees. A review of a copy of the "State Operations Manual Appendix Z Emergency Preparedness for all Provider and Certified Supplier Types Interpretive Guidance Table of Contents" was also conducted with both employees.

An exit interview was conducted on 9/8/2020 at approximately 3:00 PM with the administrator and office manager that confirmed the above findings.

Plan of Correction:

485.727(b)(4) STANDARD
Policies/Procedures-Volunteers and Staffing
Name - Component - 00
§403.748(b)(6), §416.54(b)(5), §418.113(b)(4), §441.184(b)(6), §460.84(b)(7), §482.15(b)(6), §483.73(b)(6), §483.475(b)(6), §484.102(b)(5), §485.68(b)(4), §485.542(b)(6), §485.625(b)(6), §485.727(b)(4), §485.920(b)(5), §491.12(b)(4), §494.62(b)(5).

[(b) Policies and procedures. The [facilities] must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least every 2 years [annually for LTC facilities]. At a minimum, the policies and procedures must address the following:]

(6) [or (4), (5), or (7) as noted above] The use of volunteers in an emergency or other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.

*[For RNHCIs at §403.748(b):] Policies and procedures. (6) The use of volunteers in an emergency and other emergency staffing strategies to address surge needs during an emergency.

*[For Hospice at §418.113(b):] Policies and procedures. (4) The use of hospice employees in an emergency and other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.

Observations:

Based on a review of agency documentation, policy and procedures and staff (EMP) interview, the facility failed to develop emergency preparedness policy and procedure that included the use of volunteers in an emergency or other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.

Findings Included:

Review of the agency "DISASTER PLAN" on 9/8/2020 at approximately 11:30 AM revealed, Policies "XXI. DISASTER PLAN, DISASTER PLAN AND INFECTION CONTROL, EMERGENCY FIRE AND DISASTER PLAN and PRN STAFF DISASTER TRAINING AND DRILL."

A review of the facility documentation provided on 9/8/2020 at approximately 11:50 AM revealed, the agency failed to provide documentation that contain evidence of policy and procedures that included the other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals. Facility failed to provide documentation to confirm facility had met this standard.

During interviews with (EMP1) and (EMP3) on 9/8/2020 at approximately 11:50 AM and 12:50 PM. The agency did have a Disaster Plan where policy reviews, disaster exercises and training were conducted by the agency. Although the agency staff was not aware of the Federal, State, and local emergency preparedness requirements. The surveyor reviewed the Emergency Preparedness requirements for OPT agencies with both employees. A review of a copy of the "State Operations Manual Appendix Z Emergency Preparedness for all Provider and Certified Supplier Types Interpretive Guidance Table of Contents" was also conducted with both employees.

An exit interview was conducted on 9/8/2020 at approximately 3:00 PM with the administrator and office manager that confirmed the above findings.

Plan of Correction:

485.727(c) STANDARD
Development of Communication Plan
Name - Component - 00
§403.748(c), §416.54(c), §418.113(c), §441.184(c), §460.84(c), §482.15(c), §483.73(c), §483.475(c), §484.102(c), §485.68(c), §485.542(c), §485.625(c), §485.727(c), §485.920(c), §486.360(c), §491.12(c), §494.62(c).

(c) The [facility] must develop and maintain an emergency preparedness communication plan that complies with Federal, State and local laws and must be reviewed and updated at least every 2 years [annually for LTC facilities].

Observations:

Based on a review of agency documentation, email correspondence, and staff interview, the facility failed to develop and maintain an emergency preparedness communication plan that complies with Federal, State and local laws.

Findings Included:

Review of the agency "DISASTER PLAN" on 9/8/2020 at approximately 11:30 AM revealed, Policies "XXI. DISASTER PLAN, DISASTER PLAN AND INFECTION CONTROL, EMERGENCY FIRE AND DISASTER PLAN and PRN STAFF DISASTER TRAINING AND DRILL."

A review of the facility documentation provided on 9/8/2020 at approximately 11:50 AM revealed, the agency failed to provide evidence of documentation that the facility failed to develope an emergency preparedness communication plan that complies with Federal, State and local laws.

During interviews with (EMP1) and (EMP3) on 9/8/2020 at approximately 11:50 AM and 12:50 PM. The agency did have a Disaster Plan where policy reviews, disaster exercises and training were conducted by the agency. Although the agency staff was not aware of the Federal, State, and local emergency preparedness requirements. The surveyor reviewed the Emergency Preparedness requirements for OPT agencies with both employees. A review of a copy of the "State Operations Manual Appendix Z Emergency Preparedness for all Provider and Certified Supplier Types Interpretive Guidance Table of Contents" was also conducted with both employees.

An exit interview was conducted on 9/8/2020 at approximately 3:00 PM with the administrator and office manager that confirmed the above findings.

Plan of Correction:

Addendum to policy 10/27/2020: In the event of an emergency, CEO/facility director/or office manager will activate the plan by calling 911 via land line or cell phone to alert authorities of the emergency.

Department of Health Plan of Correction Document – CrossRoads Physical Therapy and Rehab, INC
1. Emergency Preparedness Plan will be accomplished for CrossRoads Physical Therapy and Rehab, INC as part of review process dated 9/10/2020.
2. The other individuals potentially effected by the plan of care will include all staff members of CrossRoads Physical Therapy and Rehab, INC, local emergency response teams, FEMA officials, local police, fire departments, local hospitals and medical professionals who could be utilized in the emergency preparedness plan.
3. Internal clinic audits will be implemented to assure yearly review of emergency contact list, staff training, and volunteer/prn staff training yearly with established protocols in the policy and procedure manual of the operations. QI/QA coordinator will implement training procedures for initial education of the emergency preparedness training with the entire staff on October 27,2020 at the monthly staff meeting. Peer review and yearly policy and procedure reviews will occur quarterly and in January of each year, respectively. Update on plan will occur at Board of Directors Meeting in January of each year.
4. Monitoring of corrective action will be done in yearly Board of Directors meetings with yearly training of full-time staff and prn staff. A separate meeting with PRN staff and volunteers occurs each January to update this prn staff and volunteers to the clinic as a regular requirement of their emergency preparedness and disaster training program to include infection control, emergency procedures, and HR file update. Director of QI/QA performs quarterly peer and clinic audits using designated audit tools to ensure all policies and documentation are meeting the standards of practice for the state of PA (Appendix Z – state operations manual for emergency preparedness).
a. Director of QI/QA to perform quarterly training and audits
b. Operations manager to check and review QI/QA reports quarterly
c. Facility directors to review quarterly audits and educate staff
d. Administrator / CEO – will supervise all QI/QA reports quarterly and report changes to staff and board of Directors annually.
5. Correction action plan submitted to PA Dept of Health by 10/2/2020. Staff will be educated on approved plan of correction on monthly staff meeting dated 10/27/2020 pending state approval by Administrator / CEO of CrossRoads Physical Therapy and Rehab, INC with the assistance of QI/QA coordinator of CrossRoads Physical Therapy and Rehab, INC.

EMERGENCY PREPAREDNESS POLICY

Established January 22, 2018
Revised September 29, 2020

I. PURPOSE: To establish a policy for Emergency Preparedness Plan.

II. POLICY: Crossroads will follow the enclosed guidelines for any naturally occurring, facility-based, or community-based emergency.

III. RESPONSIBILITY: All Crossroads Management, Staff, and PRN/Volunteer Staff

IV. PROCEDURE:
A. Staff will familiarize themselves with the enclosed emergency preparedness guidelines.
B. Staff will, in the event of an emergency situation, notify the CEO, Facility Director, or OOM of the occurring or impending emergent situation.
C. Staff will follow the enclosed procedures for the specific emergent situation, as it occurs.
D. Local emergency departments will be notified of the Emergency Preparedness Program.
E. Staff signature sheets will serve as evidence that they have reviewed all documentation herein with regard to Emergency Preparedness.
F. Additional information can be found in the Disaster P&P Manual.
G. In the event of an emergency, CEO/facility director/or office manager will activate the plan by calling 911 via land line or cell phone to alert authorities of the emergency.

*Attached document, Emergency Preparedness Plan, will be updated every two (2) years or sooner, as needed. The Emergency Contact List will be reviewed yearly, updated and shared with the Board of Directors at annual meetings.

CrossRoads Physical Therapy and Rehabilitation, INC – Emergency Preparedness Manual

TABLE OF CONTENTS

Section 1: Summary .............................................................................
Section 2: Responsibilities in All Emergencies/Hazards .................................
Section 3: Fire Plan .................................................................................

Section 4: Tropical Storm, Hurricane or Tornado............................................
Section 5: Security Alert / Lock Down ..........................................................

Section 6: Combative Patient, Visitor, Associate...........................................

Section 7: Utility Outages.........................................................................
Section 8: Severe Hot or Cold Weather ......................................................
Section 9: Winter Storm ...........................................................................
Section 10: Bomb Threat ...........................................................................

Section 11: Hazardous Materials/ Bioterrorism ..............................................
Section 12: Pandemic Influenza ..................................................................
Section 13: Earthquake..............................................................................

Section 14: Evacuation Guidelines .............................................................
Section 15: Resuming Operations/Recovery .................................................
Section 16: Training..................................................................................

Section 17: Attachments

A: Facility Emergency Call List. .................................................
B: Non-Associate Emergency Call List ..........................................
C: Transportation Resources ........................................................
D: Associate Acknowledgement...................................................

SECTION 1: SUMMARY

The Emergency Action Plan does not answer every question or address/solve every problem that will be encountered in an emergency. The plan is a guide to describe how associates will prepare for, respond to, make decisions during, and recover from an emergency. It is important to realize that each emergency situation is going to be different. In any emergency, it is essential to think and act rapidly while using sound judgment and common sense. It is in everyone's best interest to be prepared should an emergency occur.

The Emergency Action Plan ("plan") serves as a guide for all associates to efficiently and effectively respond to any internal or external emergencies. The plan is designed to address extraordinary circumstances that may threaten the health, safety or property of CrossRoads Physical Therapy and Rehab, INC patients, associates and visitors. The plan provides a systematic and organized approach to access resources and assign duties and responsibilities during an emergency. The plan is intended to be flexible and quickly adaptable to maintain a safe environment within the rehabilitation clinic. CrossRoads Physical Therapy and Rehab, INC adopts the principles of the National Incident Command System and Incident Command System, used in most fire, Emergency Medical Services (EMS) and Police organizations.

All associates are required to be familiar with this plan and have an understanding of his or her role and function in an emergency situation -- BEFORE THE EMERGENCY OCCURS. Every associate plays a vital role in ensuring the success of this plan. The purpose of the plan is to:

- Provide guidelines in case of an internal or external emergency in an effort to minimize risk of injury to patients, associates and visitors.
- Delineate functions, duties and responsibilities during an emergency in order to maintain a safe environment for patients, associates and visitors.
- Distinguish between an internal disaster (i.e. fire, explosion, security) and an external disaster (i.e. severe weather, natural disaster, and chemical spill).
- Comply with Federal and Pennsylvania State regulatory requirements that mandate CrossRoads Physical Therapy and Rehab, INC to:
o Develop an emergency and disaster plan that includes procedures to be followed before, during and after an emergency or disaster
o Train all associates, staff, volunteers in emergency procedures at the time of hire and review the procedures annually with all associates
o Conduct unannounced drills.
- Fire drill will be conducted in one quarter of the year.
- Emergency or disaster drills will be performed in the other three (3) quarters of the year. This will include the practices of sheltering-in-place and evacuating patients; each will be practiced at least once annually.

CrossRoads Physical Therapy and Rehab, INC has developed written plans and procedures to meet potential internal and external emergencies including:

 Fire (CODE RED)

 Tropical Storm, Hurricane, Tornado, Earthquake, (CODE YELLOW)

 Security Alert/ Lockdown ( CODE GREY)

 Combative patient or visitor (CODE PURPLE)

 Loss of utilities (prolonged)

 Severe Hot or Cold Weather (prolonged)

 Winter storm, Blizzard, or Ice Storm

 Bomb threat ( CODE BLACK)

 Hazardous Materials/ Bioterrorism (CODE ORANGE)

 Pandemic influenza

 Evacuation

 Infection Control

 Resuming Operations/Recovery

 Training

SECTION 2: RESPONSIBILITIES IN ALL EMERGENCIES/HAZARDS
The following are generic descriptions of individual responsibilities during an internal or external emergency. It is important to realize that each emergency situation will be different. This list is not intended to be all inclusive.

Managing Partner/Member- Responsible with the approval of the other Members for the implementation, overall direction and coordination of the plan, coordinates with local and state emergency response organizations, serves as a liaison and communicates with other Members and directors.

ADMINISTRATION

 HUMAN RESOURCES- Maintains up to date phone lists and calls off-duty associates to fill needs. Assists in arranging transportation for associates, if necessary. Also secures associate files.
 REHAB DEPARTMENT - Provides support as directed by the Administrator or designee.
 ALL OTHER ASSOCIATES (Employed and Volunteer)- IN THE EVENT OF AN EMERGENCY, ALL ASSOCIATES MAY BE ASSIGNED A TASK REGARDLESS OF THEIR (ESSENTIAL/NON-ESSENTIAL) STATUS

All Press releases will be coordinated through the office of the Managing Member.

SECTION 3: FIRE PLAN -potenial risk = high

ANNOUNCEMENT:

- Announce "CODE RED"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "fire."
- Make the "all clear" announcement when authorized by the Clinic Director/designee on site or the Fire Department Incident Commander.

GENERAL INFORMATION:

- All associates will receive education during General Orientation and at least annually about
fire plan.
- Fire drill will be conducted in one quarter of the year.
- Fire drills will be unannounced.
- Fire bells will be tested regularly.
- Patients should not be brought in from outside of the building.
- All fire drills will be documented as to time, date, location and effectiveness.
- The "R-A-C-E" response sequence is posted.
- Elevators should not be used when the alarm bells are sounding.
- Associates should not cross area of the fire to report to their designated area.

FIRE PROCEDURES:

- Detection and Response
o Fire may be detected by sight, smell, heat/smoke detector or sprinkler function.
o The associate that locates the fire should immediately implement the "R-A-C-E" procedure:

 RESCUE any patients in immediate danger.
 ALARM go to nearest pull station and pull the fire alarm. Proceed to nearest phone and follow public address direction.
 CONFINE the fire by closing patient room doors.
 EVACUATE Begin assisting with the evacuation of patients away from the fire area as directed by the Clinic Director/designee.
 EXTINGUISH utilize fire extinguishers as the situation permits and ONLY if it does not place the associate at safety risk.
To use a fire extinguisher, remember: "PASS": PULL - AIM - SQUEEZE – SWEEP
- If someone's clothes are on fire: Stop, drop, cover the face, and roll.

ASSOCIATE RESPONSIBILITIES
Clinic Director/ designee is responsible for assuming the overall direction and control of the emergency operations of the rehab clinic.
- At the sound of the fire alarm, the Clinic Director/designee becomes the individual responsible for coordinating the clinic response of the associate(s). An Incident Command Center will be established unless it is deemed unsafe to do so. The Clinic Director/designee will relinquish responsibility when Fire Department Personnel respond.
o The Office Manager will notify "911".
o "911" will also be automatically notified by the alarm system monitoring company.
o The Clinic Director/designee will notify Maintenance associates.
o The Clinic Director/designee will designate an individual to monitor the fire personnel.
o The Clinic Director/designee will provide decision-making related to evacuation.
o Refer to the Evacuation Guidelines.

ASSOCIATE DUTIES - FIRE AREA
- Remove patients from the immediate fire area and place behind fire doors. Prepare for evacuation as directed by Clinic Director/designee.
- Close all doors and windows.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Check each patient treatment room to account for and rescue any patients, associates, and visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Transfer patient medical records to a safe area.

ASSOCIATE DUTIES - NON- FIRE AREA
- Check each patient treatment room to account for any associates, patients or visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Make sure all patients are accounted for.
- Transfer medical records to a safe area.
- Wait in safe, designated area for further instructions.

ASSOCIATES
- Secure immediate work area by closing all windows and office doors.
- Available associates are to report to the Office Manager's area and wait for further direction.
- Shut off all operating equipment.
- Secure immediate work area.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Fire Department Incident Commander
- Patients should be moved away from the fire area to the nearest secured area/hallway behind fire doors by an associate responding to that area.
- Patients' condition and the level of fire and/or smoke danger will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated.
- Refer to the Evacuation Guidelines.

SECTION 4: TROPICAL STORM, HURRICANE OR TORNADO -potenial risk = low

A Tropical Storm is an organized system of strong thunderstorms with a defined surface circulation and maximum sustained winds of 39-73 miles per hour. A tropical storm becomes a hurricane when winds reach 74 miles-per-hour. The tropical storm and hurricane season is typically June 1 - November 30.

- Tropical Storm Watch - issued when tropical storm conditions, including winds from 39-73 miles per hour, conditions are favorable or have created a risk.
- Tropical Storm Warning - issued when tropical storm conditions are either occurring or are imminent based on radar.
- Hurricane Watch - issued for a specified area for which a hurricane or hurricane related hazard is favorable and has created a risk.
- Hurricane Warning - issued when hurricane conditions are expected in a specified area
- Tornado Watçh - issued when tornados are possible in the area.
- Tornado Warning - issued when a tornado has been sighted or indicated by weather radar.
- Severe Storm Watch – issued when conditions are favorable or have created a risk of a thunderstorm capable of high winds.
- Severe Storm Warning – issued when a thunderstorm capable of high winds has been sighted or is indicated by radar.

ANNOUNCEMENT FOR TROPICAL STORM, HURRICANE OR TORNADO

.
- Announce "CODE YELLOW"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "tornado or hurricane".
- Make the "all clear" announcement when authorized by the Clinic Director/designee.

TROPICAL STORM, HURRICANE, OR TORNADO PROCEDURES

- Monitor the weather closely.
- Listen to the NOAA weather radio and/or local radio station for
instructions.
- Once a WARNING has been issued, follow the instructions below:
o When authorized by the Clinic Director/designee, make the "CODE YELLOW ALERT" announcement 3 times.
o Keep everyone inside the building.
o All associates must secure their work area.
o Everyone must stay away from all windows and outside doors.

ASSOCIATE RESPONSIBILITIES.

- Move ALL patients to the inside walls.
- Close windows, blinds, and pull privacy curtains. Any articles which may act as projectiles should be secured.
- Provide each patient a pillow to help protect his or her head.
- Wait for further instruction from the Emergency Services Incident Commander or designee.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Emergency Services Incident Commander (if applicable).
- Patients should be moved to the nearest secured area within the building until deemed necessary to move offsite.
- Patients' condition and the nature and location of the severe weather emergency will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated by the Clinic Director/designee.
- Refer to the Evacuation Guidelines
- Resources:

o http: / / www.fema.gov/areyouready/thunderstorms.shtm
o http: / / www.hazardscaucus.org/hurricanes_factsheet0909.pdf
o http: / /www.nssl.noaa.gov/edu/ safety/tornadoguide.html
o https: / /www.FloodSmart.gov (FEMA)
o https:// www.redcross.org/local/michigan (American Red Cross Locator Site)
o https://www.accuweather.com/en/us/novi-mi/48375/weather-warnings/338750

SECTION 5: SECURITY ALERT/LOCK DOWN -potential risk = low

LOCK DOWN
It is the utmost responsibility that CrossRoads Physical Therapy and Rehab, INC provide a safe and secure environment in which to live and work. This responsibility applies to any and all issues that may arise to jeopardize that environment which include criminal intent or action, fugitive/prisoner escape, unlawful assembly and disorderly/unethical/inappropriate conduct. The purpose of a Code Grey event is to take any and all measures deemed relevant to prevent a dangerous situation and/or an individual from causing harm and to further prevent the individual from gaining access to the clinic.

- Upon notification of an escaped prisoner or fugitive being in the local area, associates will be notified by the Clinic Director/designee.
- Upon notification, the Office Manager will announce Code Gray three times. Further instructions will follow depending on the incident. Such as:
o Armed intruder: Turn out lights, maintain silence, do not respond to alarms without assuring the area is safe and cautiously respond to noise.
o Rabid animal: Attempt to confine animal and get patients to safety.
o Escaped convict: proceed with lock down
- The Managing Member will be notified of lock down.
- Office Manager will immediately lock all doors.
- Associates receiving permission to leave during a Code Gray event may request an escort if available. Associates leaving during a Code Gray do so at their own risk.
- Upon conclusion of a lock down, an announcement for "all clear code gray" will be announced 3 times. Doors will be unlocked.

SECTION 6. COMBATIVE PATIENT, VISITOR, ASSOCIATE – risk level = medium
CrossRoads Physical Therapy and Rehab, INC strives to ensure a safe and secure environment for all associates, patients and visitors. To that end, the purpose of a Code Purple event is to address workplace violence, in any mannerism, including any act or attempted act of physical aggression, verbal abuse or harm by an individual. Aggression can range from threats and verbal abuse to physical assault or injury.

- In case of the need for assistance due to patient, visitor, and/or associate safety issues including workplace violence, the associates who encounter the situation will immediately notify the Managing Member or other available Members and request their assistance.
- If there is an emergent need for help to manage the situation, associate responsible party will announce Code Purple 3 times and the area in which to report.
- Associates should respond to the Code Purple location, assess the situation, and make the determination if additional outside emergency support is warranted. If warranted, an emergency service request should be placed; contact 911.
- Associates are not to attempt to restrain any intruder or visitor.
- Protection of the patients, visitors, and associates is to be achieved by using a calm, rational approach.
- Associates will move the patients in immediate danger to a safe location first.
- Patients will be relocated to a private room until the situation is over.
- If an injury to a patient, visitor, or an associate occurs, treatment will be initiated if needed, and the appropriate incident report will be completed.
- In a workplace violence situation:
o Stay calm
o Call or have someone make the 911 call and explain to the dispatcher the situation
o Listen attentively
o Maintain eye contact
o Be courteous and patient
o Maintain a quiet tone of voice
o Avoid arguing or making comments that might intensify hostility
o Avoid doing anything that will cause the assailant to take action
o Don't risk harm to yourself or others
SECTION 7: UTILITY OUTAGES – risk level = low

ELECTRICAL POWER FAILURE

- The emergency generator will be automatically activated within 10 seconds of a power outage.

WATER INTERRUPTION

- A water interruption will impact clinic services.
- When a water problem is identified, the Clinic Manager/designee should be immediately notified for a decision to cancel patient appointments and reschedule.
- For drinking water, emergency water will be distributed.
- For non-drinking water (cleaning and toilets, etc.), water is available from the hot water tanks.

SECTION 8: SEVERE HOT OR COLD WEATHER-risk level = low

Under normal circumstances, CrossRoads Physical Therapy and Rehab, INC heating and air conditioning system ("HVAC") will maintain a comfortable environment. The following steps should be taken when/if the HVAC system becomes inoperative for a prolonged period of time.

- Notify the building landlord by cell phone.
- Landlord personnel will assess the problem and notify the HVAC system repair contractor.
- If the HVAC contractor indicates a prolonged amount of time to repair the system, the Clinic Director/designee will make the decision to keep the clinic open or to close the clinic.
- If a patient appears to be in any danger of weather related stress, the attending Physician and/or "911" will be immediately notified.
- Patients' condition and the nature, location, and expected duration of the emergency will determine the fastest and safest method of evacuation.

SECTION 9: WINTER STORM – risk level = medium
- In the event of an impending winter storm, the Clinic Director/designee should turn on the NOAA weather radio for up-to-date weather information.
- Special attention should be given to winter storm warnings:
Winter Storm Watch - a winter storm is expected in our area within days.
Winter Storm Warning - a winter storm is occurring or will soon occur in the area within hours.
Blizzard Warning - sustained winds or frequent wind gusts up to 35 miles per hour or greater and considerable amounts of falling or blowing snow (reducing visibility to less than a quarter mile) are expected to prevail for a period of three hours or longer.
- Winter storms may produce snow, ice, sleet, strong winds, freezing rain, heavy snow and/or extreme cold.
- In the event of a blizzard, the "plan" will be activated by the Clinic Director/designee.
- The consequences of a winter storm include, but are not limited to;
o Associates not able to report to work
o Disruption of utilities and communications
o Freezing pipes
o Delay/disruption in delivery of supplies
o Structural damage to the buildings
o Delayed response capability of Emergency Medical Services

- Resources:
o www. weather .com
o www.weatherunderground.com

SECTION 10: BOMB THREAT- risk level = low
It is impossible to know if a bomb threat is real or a hoax. Therefore, it is imperative to treat all bomb threats seriously. Every effort should be made to minimize disturbance of patients and staff while attempting to locate and remove the bomb. It is important to try to remain calm and try to keep the patients calm while addressing the threat.

GENERAL PROCEDURE
- Keep the caller on the line as long as possible.
- Never place the caller on "hold".
- Ask the caller to repeat the message.
- If the phone has a display, copy the number and/or the letters on the display.

AFTER THE CALLER HANGS UP
- Notify the Clinic Director/designee immediately.
- Notify"911".
- Complete the attached "Bomb Threat Documentation Form".

ANNOUNCEMENT

- Announce "CODE BLACK".
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "bomb."
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Bomb Squad Incident Commander.

EVACUATION INFORMATION

- Patients should be evacuated immediately from the clinic and clinic building.
- As you evacuate, look for suspicious packages/objects/other items that do not belong there. Do not touch or remove any suspicious item.
- Keep all evacuees and associates together until Emergency Services personnel arrive. Do not re-enter the building or return patients to the clinic until authorized by the Emergency Services Incident Commander.

BOMB THREAT DOCUMENTATION FORM

Date: ______________ Person Receiving Call: _________________

Time: Telephone # call was received on: ______________

Caller's exact words: __________________________________________________

Questions to ask (if possible):

- When is the bomb going to explode? ______________________________

- Where is the bomb right now? _________________

- What kind of bomb is it? _____________________________________

- What does the bomb look like? _________________________________

- Why did you place the bomb? ________________________________

Try to determine the following: (Circle appropriate information)

- Caller's Identity: Male/Female Adult/Juvenile Age

- Voice: Loud Soft High Pitch Deep Raspy Pleasant

- Intoxicated/other _______________

- Accent: Local Not Local Foreign Region

- Speech: Fast Slow Distinct Distorted Stutter Nasal

- Language: Excellent Good Fair Poor Foul Other:________

- Manner: Calm Angry Rational Irrational Coherent Incoherent Deliberate Emotional Righteous Laughing

- Background Noises: Office Machines Factory Machines Bedlam Trains Animals Traffic Music Other__________

Additional Information: _______________________________________________________
__________________________________________________________________________

SECTION 11: HAZARDOUS MATERIAL/BIOTERRORISM EVENT -risk level = low

Hazardous Materials ("HAZMAT") is any substance that poses a risk to health, safety and property when released, spilled, or spread in sufficient quantities. These substances can be chemical, biological, or radiological. A HAZMAT event could occur inside the clinic building, in the vicinity of the clinic building, or in a wider geographical area. Most Bio-terrorism agents that would likely be used are in the form of bacteria, viruses, and toxins. Many of these agents break down quickly in sunlight and the environment while other, like anthrax, are long lived.

- Examples of a HAZMAT incident include, but are not limited to:
o Chemical spill
o Airborne hazard
o Bio-terrorism (including biological weapons or chemical weapons)
o Weapons of mass destruction
- In the event of an internal HAZMAT emergency occurring within the clinic or elsewhere within the building where the clinic is located, the services of the Fire Department, Police Department, Emergency Medical Services and the Blair County Division of Emergency Services should be utilized.
- When outside help is required, one of the agencies listed above should be contacted. See attached list of resources.
- In the event of a community-wide HAZMAT/ Bio-terrorism incident:
o Announce "CODE ORANGE"
o Repeat the announcement 3 times.
o Speak clearly and slowly.
o Never shout the words that would alarm patients.
o Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
o Initiate a facility lock-down. Close and lock all exterior doors to prevent movement in or out of the facility to minimize the risk of unnecessary contamination.
o Move all patients to a safe, central location within the building.
o Close all windows, blinds and patient room doors.
o Turn off heat/air conditioner in clinic.
o Maintenance will turn-off the facility HVAC system.
o Monitor radio broadcasts for updates. Public Health officials may not be able to provide information right away.
- If a bio-terrorism event is suspected, local emergency response systems will be activated. Guidance will be provided by Blair County Division of Emergency Services, Blair County Health Department, Bioterrorism Emergency Notification, and the Federal Centers for Disease Control.

- Evacuation can be authorized by the Clinic Director/designee, or the Emergency Services Incident Commander (if applicable).
o Patients should be moved to the nearest safe and secured area within the
building until deemed safe and necessary to evacuate off site.
o Patients' condition and the nature, location, and expected duration of the
emergency will determine the fastest and safest method of evacuation.

- If exposure to a biological agent occurs:
o Remove clothes and personal items and bag them. Follow official instructions for disposal of contaminated items.
o Wash yourself with soap and water and put on clean clothes.
o Contaminated persons may be asked to stay away from others or be quarantined.
- If a biological exposure is treatable, patients and associates will receive further instructions.

SECTION 12: PANDEMIC INFLUENZA- risk level = medium

A pandemic is a global outbreak of a serious disease that exceeds the "normal" levels of mortality and infection levels for a typical disease. A flu pandemic occurs when a new Influenza virus emerges for which people have little or no immunity and for which there is no vaccine. The disease spreads easily person to person, causes serious Illness, and can sweep across the country and around the world in a very short time. The length of the emergency could be as long as 6-8 weeks or more.

- The greatest challenge will be the maintenance of adequate staffing levels. It should be assumed that the associate population will be infected at the same rate that the patient population will be. In the clinic there must be the presence of two associates at all times when patients are being treated. If this requirement cannot be met, then the clinic must suspend services until able to be in compliance.
- Training includes infection control precautions, standard and droplet infection control precautions, respiratory hygiene, and cough etiquette.
- Educational awareness measures may include, but are not limited to, the following:
o Utilizing good hygiene by following recommended infection control protocols.
o Minimizing exposure by avoiding public gatherings, public places, and areas considered high risk.
o Updating vaccinations, including seasonal flu and pneumonia.
o Encouraging overall good physical health including eating right, drinking plenty of fluids, and getting enough exercise and sleep.
o Maintaining a positive attitude.
o Remaining home when sick.
- Strict adherence to infection control policies and procedures is critical.
- Post signs for cough etiquette.
- Determine when to restrict intake of new patients.
- Contact local and State Health Departments for vaccines and anti-viral medications.
- Implement contingency staffing plans as needed.

Resources:

flu/weekly! fluactivity.htm
http:/ /www.miemss.org/ alert
www.pandemicflu.gov
www.hhs.gov/ pandemicflu/ plan!
www.cdc, gov / flu/professionals/diagnosis
www.hhs gov/pandemicflu/plan
www.cdc. gov/flu/groups.htrn
www.cdc.gov/ flu/roups.htm
www.hhs.gov/pandemicflu/planjsup4,html
www.cdc.gov/flu/professionals/infectioncontrol/index. htm
www.cdc.gov/flulweekly/fluactivitvhrm

SECTION 13: EARTHQUAKE – risk level = low

An earthquake is a sudden, rapid movement/shaking of the earth caused by the abrupt easing of strains built up along geologic faults that have accumulated over a long time. Earthquakes strike suddenly, without warning. Earthquakes can occur at any time of the year and at any time of the day or night. Earthquakes are not totally predictable.

- Earth shaking does not harm you; building collapse and resulting fires do. Injuries and deaths are increased by human panic, so it is imperative to remain calm.
- Minimize your movements during an earthquake to a few steps to a nearby safe place. Chances of injury increase with movement.
- Stay calm and try to calm and reassure others. Think before taking action.
- If you are INSIDE when you feel an earthquake:
o Stay inside until the shaking stops. Move next to an inside wall or get under a desk or sturdy table and hold on to it.
o Remember to DROP, COVER, AND HOLD.
 Drop and cover under a desk or sturdy table.
 Hold on to the desk or table. If it moves, move with it, do not run, and stay in place.
o Stay away from windows, bookcases, refrigerators, heavy mirrors, and hanging objects that could fall.
o Do not go outside until the shaking stops.

- If you are OUTSIDE when you feel an earthquake:
o Get into an open area away from trees, signs, buildings, walls, electrical wires, and poles.
o Do not go inside any building.

- The first 72 hours after an earthquake are critical. Electricity, gas, water and telephones may not be working. In addition, public safety services such as police, fire and ambulance services will be extremely busy. We must be prepared to be self-sufficient for possibly 72-hours following an earthquake.
- Check for injuries. Check yourself first, then others. Give first aid as necessary.
- Call 911 to report life threatening emergencies.
- Set-up an area to care for injured and assign associates to provide care.
- Remain calm and reassure others.
- Do not move the seriously injured except away from danger or potential further injury.
- Stay away from damaged areas after patients have been moved.
- Avoid broken glass.
- Check gas, water, and electric lines. If damaged, shut off service.
- Replace all telephone receivers and use for emergency calls only.
- Tune to the emergency broadcast station on radio.
- The electricity may go out.
- The fire alarm and/or the sprinkler system may activate from the quake. Check for fire and take appropriate action.
- Refrain from flushing toilets. Sewer lines may be broken.
- Check shelves for objects ready to fall.
- Do not light flames, operate electric switches, or use the telephone, if there is a possibility of a gas leak.
- Expect and be prepared for aftershocks.

EVACUATION

- An evacuation can be authorized by the Clinic Director/designee member, or the Emergency Services Incident Commander.
- Patients should be moved to the nearest safe and secured area while evacuation procedures are implemented.
- The patients' condition and the nature and location of the building damage will determine the fastest and safest method of evacuation.
- Refer to the Evacuation Guidelines
- RESOURCES
hitp://earthguake.usgs.gov

SECTION 14: EVACUATION GUIDELINES

- During an internal or external emergency, it may be necessary to evacuate an area or perhaps the entire building to ensure the safety and well-being of patients, visitors and associates.
- The order to evacuate will be given by the Clinic Director/ designee or the Emergency Services Incident Commander.

ANNOUNCEMENT

- Announce "ATTENTION ALL STAFF, PATIENTS, AND VISITORS. PLEASE BEGIN PREPARATIONS TO EVACUATE THE BUILDING IMMEDIATELY."
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the words that will alarm patients.
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
- Repeat the announcement 3 times.
- Speak clearly and slowly.

TYPES OF EVACUATION / SHELTERING

- Evacuation-In-Place / Horizontal - Patients are moved to another safe location on the same floor within the building.
- Evacuation-In-Place / Vertical - Patients are moved to other floor levels within the building.
- Total Evacuation - Patients are removed from the building and moved to another offsite location.

ORDER OF EVACUATION

- Patients closest to the danger area.
- Ambulatory patients - Assemble in a group, wrap them with coats or blankets (if necessary), and walk them to safety.
- Wheelchair Patients - Assemble in a group, wrap them with coats or blankets (if necessary), and transport them to safety.

EQUIPMENT

- If evacuation of these items does not pose an unnecessary risk, take Medical Records to the designated safe area.
- Evacuation Sites: Depending on the nature, type, location, and expected duration of the emergency, both in building and out of building evacuation sites are available.
- Evacuation could necessitate using all modes of available transportation. Transportation will be coordinated by the Office Manager. Refer to attached for a list of transportation resources.
- All families will be notified of the evacuation as soon as possible. They will be informed of the reason for the evacuation, designated evacuation sites, and asked whether or not they can assist in the process in any way.
- If the evacuation is going to be long term or permanent, associates will:
o Assist in making transportation arrangements.
o Arrange for the transfer of medical records.

SECTION 15: RESUMING OPERATIONS

RECOVERY

- Following a major emergency, CrossRoads Physical Therapy and Rehab, INC will establish a "recovery team" that will prioritize steps to resume operations. The team will:

o Meet daily
o Keep detailed records including written documentation and/or audio and/or video and/or photographs of the incident
o Document damage from the hazard
o Document associate injury or illness from the hazard
o Conduct an investigation and coordinate with Local and State authorities.
o Coordinate with the insurance company.
- The Managing Member, in consultation with the other Members, will contact clinic's insurance broker.
- The recovery team will be directed by the Managing Member and consist of representatives appointed by the Managing Member
- The goal of the recovery team is to ensure the ongoing care, safety, and welfare of patients, associates and visitors.
- The recovery team will maintain ongoing communication with patients, associates, and their families. Assignments will be made for follow-up communication with:
o Local and State regulatory agencies
o CrossRoads Physical Therapy and Rehab, INC insurance carrier
o Vendors
- The recovery team will arrange for the protection of undamaged sections of the clinic and physically secure the premises.
- The recovery team will supervise clean-up operations including but not limited to:
o Restoration of utilities
o Removal of smoke, water, debris, etc.
o Separation of damaged and undamaged property. (Damaged property should be kept until the insurance adjuster approves removal.)
o Restoration of equipment and property
o Document recovery
o Maintaining appropriate sanitation and infection control procedures
o Security of the clinic.
- A list of vendors that offer recovery assistance will be provided per need.
- Depending upon the type, severity, and duration of the emergency, outside assistance will be available. (See attached list of resources).
- The recovery team will observe patients and associates for signs of stress and mental health issues. Counseling will be made available as necessary.
- The recovery team will maintain a chronological record of events for post emergency review.
- The recovery team will schedule a Post Emergency Meeting to discuss the emergency, lessons learned, and make recommendations to improve the clinic's emergency preparedness, response and recovery operations. Updates will be made to the "plan".

SECTION 16: TRAINING

- The Managing Members are jointly responsible for reviewing, updating, and implementing the Emergency Plan.
- The goal of Emergency Operations Plan training is to:
o Test and evaluate the clinic's Emergency Plan
o Clarify associates' roles and responsibilities
o Provide associates opportunities to practice their emergency roles and responsibilities
o Improve organizational coordination and communication
o Improve the "plan"
- Satisfy regulatory requirements.
- The purpose of "the plan" training is to:
o Reduce associate anxiety
o Improve performance, teamwork and decision making
o Reveal expectations about what is expected of co-workers
o Save lives.
- Training sessions will be scheduled on a regular basis and will include, but are not limited to, the following topics:
o Clinic response to a fire
o Evacuation using shelter-in-place
o Facility evacuation
o Emergency communications
o Facility response to a loss of utilities
o Responses after a traumatic event
- Training exercises will be both scheduled and unannounced.
- Types of training exercises include, but are not limited to:
o Table top- informal discussions of simulated emergencies and responses to specific situations in a low stress environment that does not disrupt patients.
o Drills - an exercise that focuses on a single, specific aspect of the "plan". In a drill, associates do not just talk about their actions, they actually perform them. Drills allow CrossRoads Physical Therapy and Rehab, INC to focus improvement efforts on a specific aspect of the "plan".
o Full-Scale Exercise - Tests many different aspects of the Emergency Operations Plan by simulating an emergency as realistically as possible. Provides the best feedback about what works and what does not work in the Emergency Operations Plan.
- All training exercises involve the following components:
o Designing the exercise
o Conducting the exercise
o Evaluating the exercise
o Improving the Emergency Operations Plan based on recommendations from the evaluation of the training exercise.
- Following a traumatic event, patients and associates should be monitored for the following traumatic responses:
o Anxiety - a reaction to a vague or unknown threat. Symptoms may include feelings of apprehension, nervousness, or fear often accompanied by physical symptoms.
o Fear - a reaction to a recognized threat.
o Panic disorder - sudden intense feeling of apprehension accompanied by physical symptoms.
o Post-Traumatic Stress Disorder - anxiety disorder that some people experience after seeing or living a dangerous event that includes extreme fear or horror.
o Depression - a mental state characterized by an inability to concentrate, insomnia, feelings of dejection and guilt, lack of hope and absence of cheerfulness.
- Patients and associates exhibiting any of the above traumatic responses should be referred to a Physician or mental health professional.

Attachment A
CrossRoads Physical Therapy and Rehab, INC Emergency Call List

Title/Name Department Business Phone Cell Phone
Chief Executive Officer
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Executive Team:
Managing Member
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Medical Director
Dr. Jason Henninger, DO Medical Director 814-684-2100 814-932-6263
Regional Office Manager
Sallie Fleming Executive Administration 814-696-3400 814-631-3901

Chief Financial Officer
Tim Parnell MSPT, ATC, EMT, CEO Accounting
Extension 814-696-3400 814-931-0012
Clinic Managers:
Aaron Kovach, DPT Duncansville Clinic 814-696-3400 814-215-9531
Seth Davis, DPT Martinsburg Clinic 814-793-3428 440-309-6654

Clinic Designee:
Krystal Disney, PTA – Director of QI/QA Duncansville Clinic 814-696-3400 814-931-3978

Director of Human Resources
Lisa Parnell Human Resources
Extension 814-696-3400 814-931-7895

Attachment B
Non- Associate Emergency Call List

Company Name Phone number Service
911 911 Police, fire, and ambulance response
Altoona Water Authority 814-949-2222 Water Supplier
American Red Cross 800-733-2767 Disaster assistance
Bioterrorism Emergency Notification 215-685-6740 Threat or Actual Bioterrorist Attack
Blair Co Sherriff's Dept. 814-693-3100
PA State Police 814-696-6100
Blair Co Health Dept. 814-695-7543 Homeland Security
Blair Co Facilities Management/Building Safety Dispatch 814-940-5900 Secondary point of contact for Homeland Security (OCHSD)
Bovard 814-941-4328 Heating and Cooling
Conemaugh at Nason 814-224-2141 Hospital/Emergency
Emergency Operations Center (EOC) 814-940-5900
Emergency Preparedness Coordinator of State 717-651-2001

Healthcare Coalition 717-561-5255 Regional
Emergency Preparedness and Response
MDHHS Communicable Disease/Immunizations 517-335-8165
Penelec 888-544-4877 Electricity Supplier
Peoples 800-764-0111 Gas Utility Supplier
UPMC Altoona 814-889-2011 Hospital/Emergency

Attachment C
Transportation resources

Company Name Vehicle type Phone Number Wheelchair
Accessible
Altoona Metro Transit Bus 814-944-4074 Yes
AMED Authority Ambulance 814-943-8993 Yes
AMTRAK Train 800-872-7245 Yes
AMTRAN Bus 814-944-4074 Yes
Blair Senior Services Van 814-695-3500 Yes
Hollidaysburg Ambulance Ambulance 814-695-3711 Yes
Hollidaysburg American Legion Ambulance Service Ambulance 814-695-1421 Yes
Lyft Taxi 855-865-9553 Limited Availability
MedVan Van 888-633-9995 Yes
Stat Medevac Air Carrier 814-941-6478 Yes
Uber Taxi 800-353-8237 Limited Availability

Attachment D

Associate Acknowledgement

I have received and read a copy of CrossRoads Physical Therapy and Rehab, INC Emergency Preparedness Plan. I understand that the statements contained in this plan are intended to serve general information purposes concerning CrossRoads Physical Therapy and Rehab, INC and its existing policies, procedures, and practices in the event of an emergency situation.
Since the information, policies, procedures, and practices described herein are necessarily subject to change, I acknowledge that revisions to the Emergency Action Plan may occur. All such changes will be communicated through official notices, and I understand that revised information may supersede, modify, or eliminate existing policies, procedures and practices.
I have received the Emergency Preparedness Plan and I understand that it is my responsibility to read and comply with the policies, procedures, and practices contained within this plan and any revisions made to it.

Associate Name (Printed) ________________________________
Signature _____________________________________________
Date _________________________________________________
Witness Signature ___________________________________

485.727(c)(3) STANDARD
Primary/Alternate Means for Communication
Name - Component - 00
§403.748(c)(3), §416.54(c)(3), §418.113(c)(3), §441.184(c)(3), §460.84(c)(3), §482.15(c)(3), §483.73(c)(3), §483.475(c)(3), §484.102(c)(3), §485.68(c)(3), §485.542(c)(3), §485.625(c)(3), §485.727(c)(3), §485.920(c)(3), §486.360(c)(3), §491.12(c)(3), §494.62(c)(3).

[(c) The [facility] must develop and maintain an emergency preparedness communication plan that complies with Federal, State and local laws and must be reviewed and updated at least every 2 years [annually for LTC facilities]. The communication plan must include all of the following:

(3) Primary and alternate means for communicating with the following:
(i) [Facility] staff.
(ii) Federal, State, tribal, regional, and local emergency management agencies.

*[For ICF/IIDs at §483.475(c):] (3) Primary and alternate means for communicating with the ICF/IID's staff, Federal, State, tribal, regional, and local emergency management agencies.

Observations:

Based on a review of the agency emergency preparedness documentation, policy and procedures and staff (EMP) interview, the agency failed to develop the communication plan that included a primary and alternate means to communicate with agency staff and local/regional/state/federal emergency preparedness agencies.

Findings Included:

Review of the agency "DISASTER PLAN" on 9/8/2020 at approximately 11:30 AM revealed, Policies "XXI. DISASTER PLAN, DISASTER PLAN AND INFECTION CONTROL, EMERGENCY FIRE AND DISASTER PLAN and PRN STAFF DISASTER TRAINING AND DRILL."

A review of the facility documentation provided on 9/8/2020 at approximately 11:50 AM revealed, the agency's plan failed to include a primary and alternate means of communicating with facility staff, Federal, State, tribal, regional and local emergency management agencies.

During interviews with (EMP1) and (EMP3) on 9/8/2020 at approximately 11:50 AM and 12:50 PM. The agency did have a Disaster Plan where policy reviews, disaster exercises and training were conducted by the agency. Although the agency staff was not aware of the Federal, State, and local emergency preparedness requirements. The surveyor reviewed the Emergency Preparedness requirements for OPT agencies with both employees. A review of a copy of the "State Operations Manual Appendix Z Emergency Preparedness for all Provider and Certified Supplier Types Interpretive Guidance Table of Contents" was also conducted with both employees.

An exit interview was conducted on 9/8/2020 at approximately 3:00 PM with the administrator and office manager that confirmed the above findings.

Plan of Correction:

Addendum to policy 10/27/2020: In the event of an emergency, CEO/facility director/or office manager will activate the plan by calling 911 via land line or cell phone to alert authorities of the emergency.

Department of Health Plan of Correction Document – CrossRoads Physical Therapy and Rehab, INC
1. Emergency Preparedness Plan will be accomplished for CrossRoads Physical Therapy and Rehab, INC as part of review process dated 9/10/2020.
2. The other individuals potentially effected by the plan of care will include all staff members of CrossRoads Physical Therapy and Rehab, INC, local emergency response teams, FEMA officials, local police, fire departments, local hospitals and medical professionals who could be utilized in the emergency preparedness plan.
3. Internal clinic audits will be implemented to assure yearly review of emergency contact list, staff training, and volunteer/prn staff training yearly with established protocols in the policy and procedure manual of the operations. QI/QA coordinator will implement training procedures for initial education of the emergency preparedness training with the entire staff on October 27,2020 at the monthly staff meeting. Peer review and yearly policy and procedure reviews will occur quarterly and in January of each year, respectively. Update on plan will occur at Board of Directors Meeting in January of each year.
4. Monitoring of corrective action will be done in yearly Board of Directors meetings with yearly training of full-time staff and prn staff. A separate meeting with PRN staff and volunteers occurs each January to update this prn staff and volunteers to the clinic as a regular requirement of their emergency preparedness and disaster training program to include infection control, emergency procedures, and HR file update. Director of QI/QA performs quarterly peer and clinic audits using designated audit tools to ensure all policies and documentation are meeting the standards of practice for the state of PA (Appendix Z – state operations manual for emergency preparedness).
a. Director of QI/QA to perform quarterly training and audits
b. Operations manager to check and review QI/QA reports quarterly
c. Facility directors to review quarterly audits and educate staff
d. Administrator / CEO – will supervise all QI/QA reports quarterly and report changes to staff and board of Directors annually.
5. Correction action plan submitted to PA Dept of Health by 10/2/2020. Staff will be educated on approved plan of correction on monthly staff meeting dated 10/27/2020 pending state approval by Administrator / CEO of CrossRoads Physical Therapy and Rehab, INC with the assistance of QI/QA coordinator of CrossRoads Physical Therapy and Rehab, INC.

EMERGENCY PREPAREDNESS POLICY

Established January 22, 2018
Revised September 29, 2020

I. PURPOSE: To establish a policy for Emergency Preparedness Plan.

II. POLICY: Crossroads will follow the enclosed guidelines for any naturally occurring, facility-based, or community-based emergency.

III. RESPONSIBILITY: All Crossroads Management, Staff, and PRN/Volunteer Staff

IV. PROCEDURE:
A. Staff will familiarize themselves with the enclosed emergency preparedness guidelines.
B. Staff will, in the event of an emergency situation, notify the CEO, Facility Director, or OOM of the occurring or impending emergent situation.
C. Staff will follow the enclosed procedures for the specific emergent situation, as it occurs.
D. Local emergency departments will be notified of the Emergency Preparedness Program.
E. Staff signature sheets will serve as evidence that they have reviewed all documentation herein with regard to Emergency Preparedness.
F. Additional information can be found in the Disaster P&P Manual.
G. Addendum to policy 10/27/2020: In the event of an emergency, CEO/facility director/or office manager will activate the plan by calling 911 via land line or cell phone to alert authorities of the emergency.

*Attached document, Emergency Preparedness Plan, will be updated every two (2) years or sooner, as needed. The Emergency Contact List will be reviewed yearly, updated and shared with the Board of Directors at annual meetings.

CrossRoads Physical Therapy and Rehabilitation, INC – Emergency Preparedness Manual

TABLE OF CONTENTS

Section 1: Summary .............................................................................
Section 2: Responsibilities in All Emergencies/Hazards .................................
Section 3: Fire Plan .................................................................................

Section 4: Tropical Storm, Hurricane or Tornado............................................
Section 5: Security Alert / Lock Down ..........................................................

Section 6: Combative Patient, Visitor, Associate...........................................

Section 7: Utility Outages.........................................................................
Section 8: Severe Hot or Cold Weather ......................................................
Section 9: Winter Storm ...........................................................................
Section 10: Bomb Threat ...........................................................................

Section 11: Hazardous Materials/ Bioterrorism ..............................................
Section 12: Pandemic Influenza ..................................................................
Section 13: Earthquake..............................................................................

Section 14: Evacuation Guidelines .............................................................
Section 15: Resuming Operations/Recovery .................................................
Section 16: Training..................................................................................

Section 17: Attachments

A: Facility Emergency Call List. .................................................
B: Non-Associate Emergency Call List ..........................................
C: Transportation Resources ........................................................
D: Associate Acknowledgement...................................................

SECTION 1: SUMMARY

The Emergency Action Plan does not answer every question or address/solve every problem that will be encountered in an emergency. The plan is a guide to describe how associates will prepare for, respond to, make decisions during, and recover from an emergency. It is important to realize that each emergency situation is going to be different. In any emergency, it is essential to think and act rapidly while using sound judgment and common sense. It is in everyone's best interest to be prepared should an emergency occur.

The Emergency Action Plan ("plan") serves as a guide for all associates to efficiently and effectively respond to any internal or external emergencies. The plan is designed to address extraordinary circumstances that may threaten the health, safety or property of CrossRoads Physical Therapy and Rehab, INC patients, associates and visitors. The plan provides a systematic and organized approach to access resources and assign duties and responsibilities during an emergency. The plan is intended to be flexible and quickly adaptable to maintain a safe environment within the rehabilitation clinic. CrossRoads Physical Therapy and Rehab, INC adopts the principles of the National Incident Command System and Incident Command System, used in most fire, Emergency Medical Services (EMS) and Police organizations.

All associates are required to be familiar with this plan and have an understanding of his or her role and function in an emergency situation -- BEFORE THE EMERGENCY OCCURS. Every associate plays a vital role in ensuring the success of this plan. The purpose of the plan is to:

- Provide guidelines in case of an internal or external emergency in an effort to minimize risk of injury to patients, associates and visitors.
- Delineate functions, duties and responsibilities during an emergency in order to maintain a safe environment for patients, associates and visitors.
- Distinguish between an internal disaster (i.e. fire, explosion, security) and an external disaster (i.e. severe weather, natural disaster, and chemical spill).
- Comply with Federal and Pennsylvania State regulatory requirements that mandate CrossRoads Physical Therapy and Rehab, INC to:
o Develop an emergency and disaster plan that includes procedures to be followed before, during and after an emergency or disaster
o Train all associates, staff, volunteers in emergency procedures at the time of hire and review the procedures annually with all associates
o Conduct unannounced drills.
- Fire drill will be conducted in one quarter of the year.
- Emergency or disaster drills will be performed in the other three (3) quarters of the year. This will include the practices of sheltering-in-place and evacuating patients; each will be practiced at least once annually.

CrossRoads Physical Therapy and Rehab, INC has developed written plans and procedures to meet potential internal and external emergencies including:

 Fire (CODE RED)

 Tropical Storm, Hurricane, Tornado, Earthquake, (CODE YELLOW)

 Security Alert/ Lockdown ( CODE GREY)

 Combative patient or visitor (CODE PURPLE)

 Loss of utilities (prolonged)

 Severe Hot or Cold Weather (prolonged)

 Winter storm, Blizzard, or Ice Storm

 Bomb threat ( CODE BLACK)

 Hazardous Materials/ Bioterrorism (CODE ORANGE)

 Pandemic influenza

 Evacuation

 Infection Control

 Resuming Operations/Recovery

 Training

SECTION 2: RESPONSIBILITIES IN ALL EMERGENCIES/HAZARDS
The following are generic descriptions of individual responsibilities during an internal or external emergency. It is important to realize that each emergency situation will be different. This list is not intended to be all inclusive.

Managing Partner/Member- Responsible with the approval of the other Members for the implementation, overall direction and coordination of the plan, coordinates with local and state emergency response organizations, serves as a liaison and communicates with other Members and directors.

ADMINISTRATION

 HUMAN RESOURCES- Maintains up to date phone lists and calls off-duty associates to fill needs. Assists in arranging transportation for associates, if necessary. Also secures associate files.
 REHAB DEPARTMENT - Provides support as directed by the Administrator or designee.
 ALL OTHER ASSOCIATES (Employed and Volunteer)- IN THE EVENT OF AN EMERGENCY, ALL ASSOCIATES MAY BE ASSIGNED A TASK REGARDLESS OF THEIR (ESSENTIAL/NON-ESSENTIAL) STATUS

All Press releases will be coordinated through the office of the Managing Member.

SECTION 3: FIRE PLAN -potenial risk = high

ANNOUNCEMENT:

- Announce "CODE RED"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "fire."
- Make the "all clear" announcement when authorized by the Clinic Director/designee on site or the Fire Department Incident Commander.

GENERAL INFORMATION:

- All associates will receive education during General Orientation and at least annually about
fire plan.
- Fire drill will be conducted in one quarter of the year.
- Fire drills will be unannounced.
- Fire bells will be tested regularly.
- Patients should not be brought in from outside of the building.
- All fire drills will be documented as to time, date, location and effectiveness.
- The "R-A-C-E" response sequence is posted.
- Elevators should not be used when the alarm bells are sounding.
- Associates should not cross area of the fire to report to their designated area.

FIRE PROCEDURES:

- Detection and Response
o Fire may be detected by sight, smell, heat/smoke detector or sprinkler function.
o The associate that locates the fire should immediately implement the "R-A-C-E" procedure:

 RESCUE any patients in immediate danger.
 ALARM go to nearest pull station and pull the fire alarm. Proceed to nearest phone and follow public address direction.
 CONFINE the fire by closing patient room doors.
 EVACUATE Begin assisting with the evacuation of patients away from the fire area as directed by the Clinic Director/designee.
 EXTINGUISH utilize fire extinguishers as the situation permits and ONLY if it does not place the associate at safety risk.
To use a fire extinguisher, remember: "PASS": PULL - AIM - SQUEEZE – SWEEP
- If someone's clothes are on fire: Stop, drop, cover the face, and roll.

ASSOCIATE RESPONSIBILITIES
Clinic Director/ designee is responsible for assuming the overall direction and control of the emergency operations of the rehab clinic.
- At the sound of the fire alarm, the Clinic Director/designee becomes the individual responsible for coordinating the clinic response of the associate(s). An Incident Command Center will be established unless it is deemed unsafe to do so. The Clinic Director/designee will relinquish responsibility when Fire Department Personnel respond.
o The Office Manager will notify "911".
o "911" will also be automatically notified by the alarm system monitoring company.
o The Clinic Director/designee will notify Maintenance associates.
o The Clinic Director/designee will designate an individual to monitor the fire personnel.
o The Clinic Director/designee will provide decision-making related to evacuation.
o Refer to the Evacuation Guidelines.

ASSOCIATE DUTIES - FIRE AREA
- Remove patients from the immediate fire area and place behind fire doors. Prepare for evacuation as directed by Clinic Director/designee.
- Close all doors and windows.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Check each patient treatment room to account for and rescue any patients, associates, and visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Transfer patient medical records to a safe area.

ASSOCIATE DUTIES - NON- FIRE AREA
- Check each patient treatment room to account for any associates, patients or visitors. Once a room is cleared, close the door with a piece of linen shut in the door above the door handle. If linen has fallen to the floor, the room will be re-inspected to assure no associate, patient or visitor has gone back into the room.
- Ensure that a clear path exists down hallways by moving all items in the hallway to one side.
- Make sure all patients are accounted for.
- Transfer medical records to a safe area.
- Wait in safe, designated area for further instructions.

ASSOCIATES
- Secure immediate work area by closing all windows and office doors.
- Available associates are to report to the Office Manager's area and wait for further direction.
- Shut off all operating equipment.
- Secure immediate work area.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Fire Department Incident Commander
- Patients should be moved away from the fire area to the nearest secured area/hallway behind fire doors by an associate responding to that area.
- Patients' condition and the level of fire and/or smoke danger will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated.
- Refer to the Evacuation Guidelines.

SECTION 4: TROPICAL STORM, HURRICANE OR TORNADO -potenial risk = low

A Tropical Storm is an organized system of strong thunderstorms with a defined surface circulation and maximum sustained winds of 39-73 miles per hour. A tropical storm becomes a hurricane when winds reach 74 miles-per-hour. The tropical storm and hurricane season is typically June 1 - November 30.

- Tropical Storm Watch - issued when tropical storm conditions, including winds from 39-73 miles per hour, conditions are favorable or have created a risk.
- Tropical Storm Warning - issued when tropical storm conditions are either occurring or are imminent based on radar.
- Hurricane Watch - issued for a specified area for which a hurricane or hurricane related hazard is favorable and has created a risk.
- Hurricane Warning - issued when hurricane conditions are expected in a specified area
- Tornado Watçh - issued when tornados are possible in the area.
- Tornado Warning - issued when a tornado has been sighted or indicated by weather radar.
- Severe Storm Watch – issued when conditions are favorable or have created a risk of a thunderstorm capable of high winds.
- Severe Storm Warning – issued when a thunderstorm capable of high winds has been sighted or is indicated by radar.

ANNOUNCEMENT FOR TROPICAL STORM, HURRICANE OR TORNADO

.
- Announce "CODE YELLOW"
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "tornado or hurricane".
- Make the "all clear" announcement when authorized by the Clinic Director/designee.

TROPICAL STORM, HURRICANE, OR TORNADO PROCEDURES

- Monitor the weather closely.
- Listen to the NOAA weather radio and/or local radio station for
instructions.
- Once a WARNING has been issued, follow the instructions below:
o When authorized by the Clinic Director/designee, make the "CODE YELLOW ALERT" announcement 3 times.
o Keep everyone inside the building.
o All associates must secure their work area.
o Everyone must stay away from all windows and outside doors.

ASSOCIATE RESPONSIBILITIES.

- Move ALL patients to the inside walls.
- Close windows, blinds, and pull privacy curtains. Any articles which may act as projectiles should be secured.
- Provide each patient a pillow to help protect his or her head.
- Wait for further instruction from the Emergency Services Incident Commander or designee.

EVACUATION
- An evacuation can be authorized by the Clinic Director/designee or the Emergency Services Incident Commander (if applicable).
- Patients should be moved to the nearest secured area within the building until deemed necessary to move offsite.
- Patients' condition and the nature and location of the severe weather emergency will determine the fastest and safest method of evacuation.
- The CrossRoads Physical Therapy and Rehab, INC Emergency Call List and Associate Call List should be activated if patients are being evacuated by the Clinic Director/designee.
- Refer to the Evacuation Guidelines
- Resources:

o http: / / www.fema.gov/areyouready/thunderstorms.shtm
o http: / / www.hazardscaucus.org/hurricanes_factsheet0909.pdf
o http: / /www.nssl.noaa.gov/edu/ safety/tornadoguide.html
o https: / /www.FloodSmart.gov (FEMA)
o https:// www.redcross.org/local/michigan (American Red Cross Locator Site)
o https://www.accuweather.com/en/us/novi-mi/48375/weather-warnings/338750

SECTION 5: SECURITY ALERT/LOCK DOWN -potential risk = low

LOCK DOWN
It is the utmost responsibility that CrossRoads Physical Therapy and Rehab, INC provide a safe and secure environment in which to live and work. This responsibility applies to any and all issues that may arise to jeopardize that environment which include criminal intent or action, fugitive/prisoner escape, unlawful assembly and disorderly/unethical/inappropriate conduct. The purpose of a Code Grey event is to take any and all measures deemed relevant to prevent a dangerous situation and/or an individual from causing harm and to further prevent the individual from gaining access to the clinic.

- Upon notification of an escaped prisoner or fugitive being in the local area, associates will be notified by the Clinic Director/designee.
- Upon notification, the Office Manager will announce Code Gray three times. Further instructions will follow depending on the incident. Such as:
o Armed intruder: Turn out lights, maintain silence, do not respond to alarms without assuring the area is safe and cautiously respond to noise.
o Rabid animal: Attempt to confine animal and get patients to safety.
o Escaped convict: proceed with lock down
- The Managing Member will be notified of lock down.
- Office Manager will immediately lock all doors.
- Associates receiving permission to leave during a Code Gray event may request an escort if available. Associates leaving during a Code Gray do so at their own risk.
- Upon conclusion of a lock down, an announcement for "all clear code gray" will be announced 3 times. Doors will be unlocked.

SECTION 6. COMBATIVE PATIENT, VISITOR, ASSOCIATE – risk level = medium
CrossRoads Physical Therapy and Rehab, INC strives to ensure a safe and secure environment for all associates, patients and visitors. To that end, the purpose of a Code Purple event is to address workplace violence, in any mannerism, including any act or attempted act of physical aggression, verbal abuse or harm by an individual. Aggression can range from threats and verbal abuse to physical assault or injury.

- In case of the need for assistance due to patient, visitor, and/or associate safety issues including workplace violence, the associates who encounter the situation will immediately notify the Managing Member or other available Members and request their assistance.
- If there is an emergent need for help to manage the situation, associate responsible party will announce Code Purple 3 times and the area in which to report.
- Associates should respond to the Code Purple location, assess the situation, and make the determination if additional outside emergency support is warranted. If warranted, an emergency service request should be placed; contact 911.
- Associates are not to attempt to restrain any intruder or visitor.
- Protection of the patients, visitors, and associates is to be achieved by using a calm, rational approach.
- Associates will move the patients in immediate danger to a safe location first.
- Patients will be relocated to a private room until the situation is over.
- If an injury to a patient, visitor, or an associate occurs, treatment will be initiated if needed, and the appropriate incident report will be completed.
- In a workplace violence situation:
o Stay calm
o Call or have someone make the 911 call and explain to the dispatcher the situation
o Listen attentively
o Maintain eye contact
o Be courteous and patient
o Maintain a quiet tone of voice
o Avoid arguing or making comments that might intensify hostility
o Avoid doing anything that will cause the assailant to take action
o Don't risk harm to yourself or others
SECTION 7: UTILITY OUTAGES – risk level = low

ELECTRICAL POWER FAILURE

- The emergency generator will be automatically activated within 10 seconds of a power outage.

WATER INTERRUPTION

- A water interruption will impact clinic services.
- When a water problem is identified, the Clinic Manager/designee should be immediately notified for a decision to cancel patient appointments and reschedule.
- For drinking water, emergency water will be distributed.
- For non-drinking water (cleaning and toilets, etc.), water is available from the hot water tanks.

SECTION 8: SEVERE HOT OR COLD WEATHER-risk level = low

Under normal circumstances, CrossRoads Physical Therapy and Rehab, INC heating and air conditioning system ("HVAC") will maintain a comfortable environment. The following steps should be taken when/if the HVAC system becomes inoperative for a prolonged period of time.

- Notify the building landlord by cell phone.
- Landlord personnel will assess the problem and notify the HVAC system repair contractor.
- If the HVAC contractor indicates a prolonged amount of time to repair the system, the Clinic Director/designee will make the decision to keep the clinic open or to close the clinic.
- If a patient appears to be in any danger of weather related stress, the attending Physician and/or "911" will be immediately notified.
- Patients' condition and the nature, location, and expected duration of the emergency will determine the fastest and safest method of evacuation.

SECTION 9: WINTER STORM – risk level = medium
- In the event of an impending winter storm, the Clinic Director/designee should turn on the NOAA weather radio for up-to-date weather information.
- Special attention should be given to winter storm warnings:
Winter Storm Watch - a winter storm is expected in our area within days.
Winter Storm Warning - a winter storm is occurring or will soon occur in the area within hours.
Blizzard Warning - sustained winds or frequent wind gusts up to 35 miles per hour or greater and considerable amounts of falling or blowing snow (reducing visibility to less than a quarter mile) are expected to prevail for a period of three hours or longer.
- Winter storms may produce snow, ice, sleet, strong winds, freezing rain, heavy snow and/or extreme cold.
- In the event of a blizzard, the "plan" will be activated by the Clinic Director/designee.
- The consequences of a winter storm include, but are not limited to;
o Associates not able to report to work
o Disruption of utilities and communications
o Freezing pipes
o Delay/disruption in delivery of supplies
o Structural damage to the buildings
o Delayed response capability of Emergency Medical Services

- Resources:
o www. weather .com
o www.weatherunderground.com

SECTION 10: BOMB THREAT- risk level = low
It is impossible to know if a bomb threat is real or a hoax. Therefore, it is imperative to treat all bomb threats seriously. Every effort should be made to minimize disturbance of patients and staff while attempting to locate and remove the bomb. It is important to try to remain calm and try to keep the patients calm while addressing the threat.

GENERAL PROCEDURE
- Keep the caller on the line as long as possible.
- Never place the caller on "hold".
- Ask the caller to repeat the message.
- If the phone has a display, copy the number and/or the letters on the display.

AFTER THE CALLER HANGS UP
- Notify the Clinic Director/designee immediately.
- Notify"911".
- Complete the attached "Bomb Threat Documentation Form".

ANNOUNCEMENT

- Announce "CODE BLACK".
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the word "bomb."
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Bomb Squad Incident Commander.

EVACUATION INFORMATION

- Patients should be evacuated immediately from the clinic and clinic building.
- As you evacuate, look for suspicious packages/objects/other items that do not belong there. Do not touch or remove any suspicious item.
- Keep all evacuees and associates together until Emergency Services personnel arrive. Do not re-enter the building or return patients to the clinic until authorized by the Emergency Services Incident Commander.

BOMB THREAT DOCUMENTATION FORM

Date: ______________ Person Receiving Call: _________________

Time: Telephone # call was received on: ______________

Caller's exact words: __________________________________________________

Questions to ask (if possible):

- When is the bomb going to explode? ______________________________

- Where is the bomb right now? _________________

- What kind of bomb is it? _____________________________________

- What does the bomb look like? _________________________________

- Why did you place the bomb? ________________________________

Try to determine the following: (Circle appropriate information)

- Caller's Identity: Male/Female Adult/Juvenile Age

- Voice: Loud Soft High Pitch Deep Raspy Pleasant

- Intoxicated/other _______________

- Accent: Local Not Local Foreign Region

- Speech: Fast Slow Distinct Distorted Stutter Nasal

- Language: Excellent Good Fair Poor Foul Other:________

- Manner: Calm Angry Rational Irrational Coherent Incoherent Deliberate Emotional Righteous Laughing

- Background Noises: Office Machines Factory Machines Bedlam Trains Animals Traffic Music Other__________

Additional Information: _______________________________________________________
__________________________________________________________________________

SECTION 11: HAZARDOUS MATERIAL/BIOTERRORISM EVENT -risk level = low

Hazardous Materials ("HAZMAT") is any substance that poses a risk to health, safety and property when released, spilled, or spread in sufficient quantities. These substances can be chemical, biological, or radiological. A HAZMAT event could occur inside the clinic building, in the vicinity of the clinic building, or in a wider geographical area. Most Bio-terrorism agents that would likely be used are in the form of bacteria, viruses, and toxins. Many of these agents break down quickly in sunlight and the environment while other, like anthrax, are long lived.

- Examples of a HAZMAT incident include, but are not limited to:
o Chemical spill
o Airborne hazard
o Bio-terrorism (including biological weapons or chemical weapons)
o Weapons of mass destruction
- In the event of an internal HAZMAT emergency occurring within the clinic or elsewhere within the building where the clinic is located, the services of the Fire Department, Police Department, Emergency Medical Services and the Blair County Division of Emergency Services should be utilized.
- When outside help is required, one of the agencies listed above should be contacted. See attached list of resources.
- In the event of a community-wide HAZMAT/ Bio-terrorism incident:
o Announce "CODE ORANGE"
o Repeat the announcement 3 times.
o Speak clearly and slowly.
o Never shout the words that would alarm patients.
o Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
o Initiate a facility lock-down. Close and lock all exterior doors to prevent movement in or out of the facility to minimize the risk of unnecessary contamination.
o Move all patients to a safe, central location within the building.
o Close all windows, blinds and patient room doors.
o Turn off heat/air conditioner in clinic.
o Maintenance will turn-off the facility HVAC system.
o Monitor radio broadcasts for updates. Public Health officials may not be able to provide information right away.
- If a bio-terrorism event is suspected, local emergency response systems will be activated. Guidance will be provided by Blair County Division of Emergency Services, Blair County Health Department, Bioterrorism Emergency Notification, and the Federal Centers for Disease Control.

- Evacuation can be authorized by the Clinic Director/designee, or the Emergency Services Incident Commander (if applicable).
o Patients should be moved to the nearest safe and secured area within the
building until deemed safe and necessary to evacuate off site.
o Patients' condition and the nature, location, and expected duration of the
emergency will determine the fastest and safest method of evacuation.

- If exposure to a biological agent occurs:
o Remove clothes and personal items and bag them. Follow official instructions for disposal of contaminated items.
o Wash yourself with soap and water and put on clean clothes.
o Contaminated persons may be asked to stay away from others or be quarantined.
- If a biological exposure is treatable, patients and associates will receive further instructions.

SECTION 12: PANDEMIC INFLUENZA- risk level = medium

A pandemic is a global outbreak of a serious disease that exceeds the "normal" levels of mortality and infection levels for a typical disease. A flu pandemic occurs when a new Influenza virus emerges for which people have little or no immunity and for which there is no vaccine. The disease spreads easily person to person, causes serious Illness, and can sweep across the country and around the world in a very short time. The length of the emergency could be as long as 6-8 weeks or more.

- The greatest challenge will be the maintenance of adequate staffing levels. It should be assumed that the associate population will be infected at the same rate that the patient population will be. In the clinic there must be the presence of two associates at all times when patients are being treated. If this requirement cannot be met, then the clinic must suspend services until able to be in compliance.
- Training includes infection control precautions, standard and droplet infection control precautions, respiratory hygiene, and cough etiquette.
- Educational awareness measures may include, but are not limited to, the following:
o Utilizing good hygiene by following recommended infection control protocols.
o Minimizing exposure by avoiding public gatherings, public places, and areas considered high risk.
o Updating vaccinations, including seasonal flu and pneumonia.
o Encouraging overall good physical health including eating right, drinking plenty of fluids, and getting enough exercise and sleep.
o Maintaining a positive attitude.
o Remaining home when sick.
- Strict adherence to infection control policies and procedures is critical.
- Post signs for cough etiquette.
- Determine when to restrict intake of new patients.
- Contact local and State Health Departments for vaccines and anti-viral medications.
- Implement contingency staffing plans as needed.

Resources:

flu/weekly! fluactivity.htm
http:/ /www.miemss.org/ alert
www.pandemicflu.gov
www.hhs.gov/ pandemicflu/ plan!
www.cdc, gov / flu/professionals/diagnosis
www.hhs gov/pandemicflu/plan
www.cdc. gov/flu/groups.htrn
www.cdc.gov/ flu/roups.htm
www.hhs.gov/pandemicflu/planjsup4,html
www.cdc.gov/flu/professionals/infectioncontrol/index. htm
www.cdc.gov/flulweekly/fluactivitvhrm

SECTION 13: EARTHQUAKE – risk level = low

An earthquake is a sudden, rapid movement/shaking of the earth caused by the abrupt easing of strains built up along geologic faults that have accumulated over a long time. Earthquakes strike suddenly, without warning. Earthquakes can occur at any time of the year and at any time of the day or night. Earthquakes are not totally predictable.

- Earth shaking does not harm you; building collapse and resulting fires do. Injuries and deaths are increased by human panic, so it is imperative to remain calm.
- Minimize your movements during an earthquake to a few steps to a nearby safe place. Chances of injury increase with movement.
- Stay calm and try to calm and reassure others. Think before taking action.
- If you are INSIDE when you feel an earthquake:
o Stay inside until the shaking stops. Move next to an inside wall or get under a desk or sturdy table and hold on to it.
o Remember to DROP, COVER, AND HOLD.
 Drop and cover under a desk or sturdy table.
 Hold on to the desk or table. If it moves, move with it, do not run, and stay in place.
o Stay away from windows, bookcases, refrigerators, heavy mirrors, and hanging objects that could fall.
o Do not go outside until the shaking stops.

- If you are OUTSIDE when you feel an earthquake:
o Get into an open area away from trees, signs, buildings, walls, electrical wires, and poles.
o Do not go inside any building.

- The first 72 hours after an earthquake are critical. Electricity, gas, water and telephones may not be working. In addition, public safety services such as police, fire and ambulance services will be extremely busy. We must be prepared to be self-sufficient for possibly 72-hours following an earthquake.
- Check for injuries. Check yourself first, then others. Give first aid as necessary.
- Call 911 to report life threatening emergencies.
- Set-up an area to care for injured and assign associates to provide care.
- Remain calm and reassure others.
- Do not move the seriously injured except away from danger or potential further injury.
- Stay away from damaged areas after patients have been moved.
- Avoid broken glass.
- Check gas, water, and electric lines. If damaged, shut off service.
- Replace all telephone receivers and use for emergency calls only.
- Tune to the emergency broadcast station on radio.
- The electricity may go out.
- The fire alarm and/or the sprinkler system may activate from the quake. Check for fire and take appropriate action.
- Refrain from flushing toilets. Sewer lines may be broken.
- Check shelves for objects ready to fall.
- Do not light flames, operate electric switches, or use the telephone, if there is a possibility of a gas leak.
- Expect and be prepared for aftershocks.

EVACUATION

- An evacuation can be authorized by the Clinic Director/designee member, or the Emergency Services Incident Commander.
- Patients should be moved to the nearest safe and secured area while evacuation procedures are implemented.
- The patients' condition and the nature and location of the building damage will determine the fastest and safest method of evacuation.
- Refer to the Evacuation Guidelines
- RESOURCES
hitp://earthguake.usgs.gov

SECTION 14: EVACUATION GUIDELINES

- During an internal or external emergency, it may be necessary to evacuate an area or perhaps the entire building to ensure the safety and well-being of patients, visitors and associates.
- The order to evacuate will be given by the Clinic Director/ designee or the Emergency Services Incident Commander.

ANNOUNCEMENT

- Announce "ATTENTION ALL STAFF, PATIENTS, AND VISITORS. PLEASE BEGIN PREPARATIONS TO EVACUATE THE BUILDING IMMEDIATELY."
- Repeat the announcement 3 times.
- Speak clearly and slowly.
- Never shout the words that will alarm patients.
- Make the "all clear" announcement when authorized by the Clinic Director/designee or the Fire Department Incident Commander.
- Repeat the announcement 3 times.
- Speak clearly and slowly.

TYPES OF EVACUATION / SHELTERING

- Evacuation-In-Place / Horizontal - Patients are moved to another safe location on the same floor within the building.
- Evacuation-In-Place / Vertical - Patients are moved to other floor levels within the building.
- Total Evacuation - Patients are removed from the building and moved to another offsite location.

ORDER OF EVACUATION

- Patients closest to the danger area.
- Ambulatory patients - Assemble in a group, wrap them with coats or blankets (if necessary), and walk them to safety.
- Wheelchair Patients - Assemble in a group, wrap them with coats or blankets (if necessary), and transport them to safety.

EQUIPMENT

- If evacuation of these items does not pose an unnecessary risk, take Medical Records to the designated safe area.
- Evacuation Sites: Depending on the nature, type, location, and expected duration of the emergency, both in building and out of building evacuation sites are available.
- Evacuation could necessitate using all modes of available transportation. Transportation will be coordinated by the Office Manager. Refer to attached for a list of transportation resources.
- All families will be notified of the evacuation as soon as possible. They will be informed of the reason for the evacuation, designated evacuation sites, and asked whether or not they can assist in the process in any way.
- If the evacuation is going to be long term or permanent, associates will:
o Assist in making transportation arrangements.
o Arrange for the transfer of medical records.

SECTION 15: RESUMING OPERATIONS

RECOVERY

- Following a major emergency, CrossRoads Physical Therapy and Rehab, INC will establish a "recovery team" that will prioritize steps to resume operations. The team will:

o Meet daily
o Keep detailed records including written documentation and/or audio and/or video and/or photographs of the incident
o Document damage from the hazard
o Document associate injury or illness from the hazard
o Conduct an investigation and coordinate with Local and State authorities.
o Coordinate with the insurance company.
- The Managing Member, in consultation with the other Members, will contact clinic's insurance broker.
- The recovery team will be directed by the Managing Member and consist of representatives appointed by the Managing Member
- The goal of the recovery team is to ensure the ongoing care, safety, and welfare of patients, associates and visitors.
- The recovery team will maintain ongoing communication with patients, associates, and their families. Assignments will be made for follow-up communication with:
o Local and State regulatory agencies
o CrossRoads Physical Therapy and Rehab, INC insurance carrier
o Vendors
- The recovery team will arrange for the protection of undamaged sections of the clinic and physically secure the premises.
- The recovery team will supervise clean-up operations including but not limited to:
o Restoration of utilities
o Removal of smoke, water, debris, etc.
o Separation of damaged and undamaged property. (Damaged property should be kept until the insurance adjuster approves removal.)
o Restoration of equipment and property
o Document recovery
o Maintaining appropriate sanitation and infection control procedures
o Security of the clinic.
- A list of vendors that offer recovery assistance will be provided per need.
- Depending upon the type, severity, and duration of the emergency, outside assistance will be available. (See attached list of resources).
- The recovery team will observe patients and associates for signs of stress and mental health issues. Counseling will be made available as necessary.
- The recovery team will maintain a chronological record of events for post emergency review.
- The recovery team will schedule a Post Emergency Meeting to discuss the emergency, lessons learned, and make recommendations to improve the clinic's emergency preparedness, response and recovery operations. Updates will be made to the "plan".

SECTION 16: TRAINING

- The Managing Members are jointly responsible for reviewing, updating, and implementing the Emergency Plan.
- The goal of Emergency Operations Plan training is to:
o Test and evaluate the clinic's Emergency Plan
o Clarify associates' roles and responsibilities
o Provide associates opportunities to practice their emergency roles and responsibilities
o Improve organizational coordination and communication
o Improve the "plan"
- Satisfy regulatory requirements.
- The purpose of "the plan" training is to:
o Reduce associate anxiety
o Improve performance, teamwork and decision making
o Reveal expectations about what is expected of co-workers
o Save lives.
- Training sessions will be scheduled on a regular basis and will include, but are not limited to, the following topics:
o Clinic response to a fire
o Evacuation using shelter-in-place
o Facility evacuation
o Emergency communications
o Facility response to a loss of utilities
o Responses after a traumatic event
- Training exercises will be both scheduled and unannounced.
- Types of training exercises include, but are not limited to:
o Table top- informal discussions of simulated emergencies and responses to specific situations in a low stress environment that does not disrupt patients.
o Drills - an exercise that focuses on a single, specific aspect of the "plan". In a drill, associates do not just talk about their actions, they actually perform them. Drills allow CrossRoads Physical Therapy and Rehab, INC to focus improvement efforts on a specific aspect of the "plan".
o Full-Scale Exercise - Tests many different aspects of the Emergency Operations Plan by simulating an emergency as realistically as possible. Provides the best feedback about what works and what does not work in the Emergency Operations Plan.
- All training exercises involve the following components:
o Designing the exercise
o Conducting the exercise
o Evaluating the exercise
o Improving the Emergency Operations Plan based on recommendations from the evaluation of the training exercise.
- Following a traumatic event, patients and associates should be monitored for the following traumatic responses:
o Anxiety - a reaction to a vague or unknown threat. Symptoms may include feelings of apprehension, nervousness, or fear often accompanied by physical symptoms.
o Fear - a reaction to a recognized threat.
o Panic disorder - sudden intense feeling of apprehension accompanied by physical symptoms.
o Post-Traumatic Stress Disorder - anxiety disorder that some people experience after seeing or living a dangerous event that includes extreme fear or horror.
o Depression - a mental state characterized by an inability to concentrate, insomnia, feelings of dejection and guilt, lack of hope and absence of cheerfulness.
- Patients and associates exhibiting any of the above traumatic responses should be referred to a Physician or mental health professional.

Attachment A
CrossRoads Physical Therapy and Rehab, INC Emergency Call List

Title/Name Department Business Phone Cell Phone
Chief Executive Officer
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Executive Team:
Managing Member
Tim Parnell MSPT, ATC, EMT, CEO Executive Administration 814-696-3400 814-931-0012
Medical Director
Dr. Jason Henninger, DO Medical Director 814-684-2100 814-932-6263
Regional Office Manager
Sallie Fleming Executive Administration 814-696-3400 814-631-3901

Chief Financial Officer
Tim Parnell MSPT, ATC, EMT, CEO Accounting
Extension 814-696-3400 814-931-0012
Clinic Managers:
Aaron Kovach, DPT Duncansville Clinic 814-696-3400 814-215-9531
Seth Davis, DPT Martinsburg Clinic 814-793-3428 440-309-6654

Clinic Designee:
Krystal Disney, PTA – Director of QI/QA Duncansville Clinic 814-696-3400 814-931-3978

Director of Human Resources
Lisa Parnell Human Resources
Extension 814-696-3400 814-931-7895

Attachment B
Non- Associate Emergency Call List

Company Name Phone number Service
911 911 Police, fire, and ambulance response
Altoona Water Authority 814-949-2222 Water Supplier
American Red Cross 800-733-2767 Disaster assistance
Bioterrorism Emergency Notification 215-685-6740 Threat or Actual Bioterrorist Attack
Blair Co Sherriff's Dept. 814-693-3100
PA State Police 814-696-6100
Blair Co Health Dept. 814-695-7543 Homeland Security
Blair Co Facilities Management/Building Safety Dispatch 814-940-5900 Secondary point of contact for Homeland Security (OCHSD)
Bovard 814-941-4328 Heating and Cooling
Conemaugh at Nason 814-224-2141 Hospital/Emergency
Emergency Operations Center (EOC) 814-940-5900
Emergency Preparedness Coordinator of State 717-651-2001

Healthcare Coalition 717-561-5255 Regional
Emergency Preparedness and Response
MDHHS Communicable Disease/Immunizations 517-335-8165
Penelec 888-544-4877 Electricity Supplier
Peoples 800-764-0111 Gas Utility Supplier
UPMC Altoona 814-889-2011 Hospital/Emergency

Attachment C
Transportation resources

Company Name Vehicle type Phone Number Wheelchair
Accessible
Altoona Metro Transit Bus 814-944-4074 Yes
AMED Authority Ambulance 814-943-8993 Yes
AMTRAK Train 800-872-7245 Yes
AMTRAN Bus 814-944-4074 Yes
Blair Senior Services Van 814-695-3500 Yes
Hollidaysburg Ambulance Ambulance 814-695-3711 Yes
Hollidaysburg American Legion Ambulance Service Ambulance 814-695-1421 Yes
Lyft Taxi 855-865-9553 Limited Availability
MedVan Van 888-633-9995 Yes
Stat Medevac Air Carrier 814-941-6478 Yes
Uber Taxi 800-353-8237 Limited Availability

Attachment D

Associate Acknowledgement

I have received and read a copy of CrossRoads Physical Therapy and Rehab, INC Emergency Preparedness Plan. I understand that the statements contained in this plan are intended to serve general information purposes concerning CrossRoads Physical Therapy and Rehab, INC and its existing policies, procedures, and practices in the event of an emergency situation.
Since the information, policies, procedures, and practices described herein are necessarily subject to change, I acknowledge that revisions to the Emergency Action Plan may occur. All such changes will be communicated through official notices, and I understand that revised information may supersede, modify, or eliminate existing policies, procedures and practices.
I have received the Emergency Preparedness Plan and I understand that it is my responsibility to read and comply with the policies, procedures, and practices contained within this plan and any revisions made to it.

Associate Name (Printed) ________________________________
Signature _____________________________________________
Date _________________________________________________
Witness Signature ___________________________________

Initial Comments:

Based on the findings of an onsite unannounced Medicare recertification survey completed 9/10/2020, Crossroads Physical Therapy and Rehabilitation Inc. was found to be in compliance with the requirements of 42 CFR, Part 485, Subpart H, Conditions of Participation for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services.

Plan of Correction: