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PALM GARDENS CENTER FOR NURSING ANDREHABILITATIONComprehensive EmergencyManagement PlanPart II2020PALM GARDENS CENTER FOR NURSING AND REHABILITATION615 AVENUE C, BROOKLYN, NY 11218718-633-3300

InstructionsPalm Gardens adapted The NYSDOH Comprehensive Emergency Management (CEMP)Template as a tool to help develop and maintain CEMPs. For 2020, Infectious disease Hazardincident has been updated to include guidance and formatted to provide a form to comply withthe new requirements of Chapter 114 of the Laws of 2020 for the development of a PandemicEmergency Plan (PEP). This plan is designed to help Palm Gardens easily identify the informationneeded to effectively plan for, respond to, and recover from natural and human-made disasters.All content in this template were reviewed and tailored to meet the needs of Palm Gardens.This Comprehensive Emergency Management Plan (CEMP)-Infectious disease/PandemicEmergency Plan has been approved for implementation by Palm Gardens Administration.New York State Department of HealthCEMP (Part II) - Page 2

Emergency ContactsThe following table lists contact information for public safety and public health representatives forquick reference during an emergency.Table 1: Emergency Contact InformationOrganizationPhone Number(s)Local Fire DepartmentEngine 240- 718-965-8240Engine 281- 718-999-2000Local Police Department66th precinct 718-851-5611Emergency Medical ServicesRCA-718-273-3555Fire Marshal718-999-2000Local Office of Emergency Management718-422-4800NYSDOH Regional Office (Business Hours)1518-402-0289NYSDOH Duty Officer (Business Hours)866-881-2809New York State Watch Center (Warning Point)(Non-Business Hours)518-292-2200During normal business hours (non-holiday weekdays from 8:00 am – 5:00 pm), contact the NYSDOH Regional Office for your regionor the NYSDOH Duty Officer. Outside of normal business hours (e.g., evenings, weekends, or holidays), contact the New York StateWatch Center (Warning Point).1New York State Department of HealthCEMP (Part II) - Page 3

Record of ChangesTable 2: Record of ChangesVersion#1.0ImplementedByRevisionDateDavid Simha, AdministratorSeptember 15, 2020David Simha, AdministratorSeptember 21,2020New York State Department of HealthCEMP (Part II) - Page 4Description of ChangeInitiation

Record of External DistributionTable 3: Record of External DistributionDateRecipient NameNew York State Department of HealthCEMP (Part II) - Page 5Recipient OrganizationFormatNumber ofCopies

Table of ContentsINSTRUCTIONS2EMERGENCY CONTACTS3APPROVAL AND IMPLEMENTATIONERROR! BOOKMARK NOT DEFINED.RECORD OF CHANGES4RECORD OF EXTERNAL DISTRIBUTION519BACKGROUND1.1 Introduction1.2 Purpose1.3 Scope1.4 Situation1.4.1 Risk Assessment1.4.2 Mitigation Overview1.5 Planning Assumptions9101011111212213CONCEPT OF OPERATIONS2.1 Notification and Activation2.1.1 Hazard Identification2.1.2 Activation2.1.3 Staff Notification2.1.4 External Notification2.2 Mobilization2.2.1 Incident Management Team2.2.2 Command Center2.3 Response2.3.1 Assessment2.3.2 Protective Actions2.3.3 Staffing2.4 Recovery2.4.1 Recovery Services2.4.2 Demobilization2.4.3 Infrastructure Restoration2.4.4 Resumption of Full Services2.4.5 Resource Inventory and 3INFORMATION MANAGEMENT22Critical Facility Records223.1New York State Department of HealthCEMP (Part II) - Page 6

3.2 Resident Tracking and Information-Sharing3.2.1 Tracking Evacuated Residents3.3 Staff Tracking and Accountability3.3.1 Tracking Facility Personnel3.3.2 Staff Accountability3.3.3 Non-Facility Personnel222223232323424COMMUNICATIONS4.1 Facility Communications4.1.1 Communications Review and Approval4.2 Internal Communications4.2.1 Staff Communication4.2.2 Staff Reception Area4.2.3 Resident Communication4.3 External Communications4.3.1 Corporate/Parent Organization4.3.2 Authorized Family and Guardians4.3.3 Media and General Public5ADMINISTRATION, FINANCE, LOGISTICS24242525252526Error! Bookmark not defined.2626275.1 Administration5.1.1 Preparedness5.2 Finance5.2.1 Preparedness5.2.2 Incident Response5.3 Logistics5.3.1 Preparedness5.3.2 Incident Response27272727272828286PLAN DEVELOPMENT AND MAINTENANCE297AUTHORITIES AND REFERENCES30ANNEX A:PROTECTIVE ACTIONS32ANNEX B:RESOURCE MANAGEMENT341.2.3.4.PreparednessResource Distribution and ReplenishmentResource SharingEmergency StaffingANNEX C:1.2.EMERGENCY POWER SYSTEMSCapabilitiesResilience and VulnerabilitiesNew York State Department of HealthCEMP (Part II) - Page 734343535373737

ANNEX D:TRAINING AND . Participation Records3.2. After Action Reports3839393939ANNEX E: INFECTIOUS DISEASE PANDEMIC EMERGENCY PLAN (PEP)40New York State Department of HealthCEMP (Part II) - Page 8

1 Background1.1 IntroductionTo protect the well-being of residents, staff, and visitors, the following all-hazards ComprehensiveEmergency Management Plan (CEMP) has been developed. It includes considerations necessaryto satisfy the requirements for a Pandemic Emergency Plan (PEP). Appendix K of the CEMP hasbeen adjusted to meet the needs of the PEP and will also provide Palm Gardens a form to post forthe public on the Palm Gardens website and to provide immediately upon request. The CEMP isinformed by the conduct of facility-based and community-based risk assessments and pre-disastercollaboration with Maimonides Medical Center, Ditmas Park Nursing Home, and local emergencymanagement agency].This CEMP is a living document that will be reviewed annually, at a minimum, under Section 7:Plan Development and Maintenance.The impact of the next pandemic could have an overwhelming effect on the health andwell-being of the residents and all employees, not just in Palm Gardens but the whole populationin general. Planning and preparation before the next pandemic are critical towards an effectiveresponse.World Health Organization has identified three areas for a pandemic to occur: A novel virus subtype must emerge to which the general population will have no or littleimmunity. The new virus must be able to replicate in human and cause serious illness. The new virus must be efficiently transmitted from one human to another.On March 11, 2020 the Novel Coronavirus Disease, COVID-19, was declared a pandemic by theWorld Health Organization. On March 13, 2020, a national emergency was announced in theUnited States concerning the COVID-19 outbreak.Characteristic of pandemic include:a)Simultaneous impacts territory-wideb)An overwhelming burden of ill persons requiring hospitalization or outpatient medical care;c)Likely shortages and delays in the availability of vaccines and antiviral drugs;d)Disruption of community infrastructures including transportation, commerce, utilities, and publicsafety;e)The global spread of infection, and;New York State Department of HealthCEMP (Part II) - Page 9

1.2PurposeThe purpose of this plan is to describe Palm Gardens approach to mitigating the effects of preparing for,responding to, and recovering from natural disasters, man-made incidents, and/or facility emergencies.Figure 1: Four Phases of Emergency ManagementPrevention ofanticipatedemergenciesor minimizingtheir ring in theshort,intermediate, andlong-term from anemergency1.3Preparation toaddress anemergencyRespondingefficiently andsafely to anemergencyScopeThe scope of this plan extends to any event that disrupts or has the potential to disruptsignificantly, the provision of expected standards of care and continuity of operations, regardlessof the cause of the incident (i.e., human-made or natural disaster).The plan provides Palm Gardens with a framework for the emergency preparedness program andutilizes an all-hazards approach to develop capabilities and capacities to address anticipatedevents.This plan is a supplement to the PALM GARDENS Emergency Management Plan.New York State Department of HealthCEMP (Part II) - Page 10

1.4 Situation1.4.1 Risk Assessment2Palm Gardens conducts an annual risk assessment to identify which natural, and human-madehazards pose the most significant risk to the facility (i.e., human and economic losses based onthe vulnerability of people, buildings, and infrastructure).Palm Gardens conducted a facility-specific risk assessment on 09/11/20 and determined thefollowing hazards may affect the facility’s ability to maintain operations before, during, and afteran incident: Winter Storm/Blizzard Extreme Temperatures Fire Infectious Disease IT/Communication FailureThis risk information serves as the foundation for the plan—including associated policies,procedures, and preparedness activities.2The Hazard Vulnerability Analysis (HVA) is the industry standard for assessing risk to healthcare Palm Gardens. Palm Gardens mayrely on a community-based risk assessment developed by public health agencies, emergency management agencies, and HealthEmergency Preparedness Coalition or in conjunction with conducting its own facility-based assessment. If this approach is used,Palm Gardens are expected to have a copy of the community-based risk assessment and to work with the entity that developed it toensure that the facility’s emergency plan is in alignment.New York State Department of HealthCEMP (Part II) - Page 11

1.4.2 Mitigation OverviewThe primary focus of Palm Gardens' pre-disaster mitigation efforts is to identify the level ofvulnerability to various hazards and mitigate those vulnerabilities to ensure continuity of servicedelivery and business operations despite potential or actual hazardous conditions.To minimize impacts to service delivery and business operations during an emergency, PalmGardens has completed the following mitigation activities: Development and maintenance of a CEMP;Procurement of emergency supplies and resources;Establishment and maintenance of mutual aid and vendor agreements to providesupplementary emergency assistance;Regular instruction to staff on plans, policies, and procedures; andValidation of plans, policies, and procedures through exercises.3For more information about the Palm Gardens fire prevention efforts (e.g., drills), safetyinspections, and equipment testing, please refer to the Preventive Maintenance binder, which islocated in the Maintenance office1.5 Planning AssumptionsThe following planning assumptions guide this plan: 3Emergencies and disasters can occur without notice, any day, and on any shift.Emergencies and disasters may be facility-specific, local, regional, or state-wide.Local and state authorities may declare an emergency.Palm Gardens may receive requests from other facilities for resource support (supplies,equipment, staffing, or to serve as a receiving facility).Palm Gardens' security may be compromised during an emergency.The emergency may exceed Palm Gardens capabilities, and external emergencyresources may be unavailable. The facility is expected to be able to function without aninflux of outside supplies or assistance for 72 hours.Power systems (including emergency generators) could fail.During an emergency, it may be difficult for some staff to get to the facility, or alternately,they may need to stay in the facility for a prolonged period.Refer to the “Training and Exercises” section of this plan for additional information about pre-incident trainings and exercises.New York State Department of HealthCEMP (Part II) - Page 12

2 Concept of Operations2.1Notification and Activation2.1.1 Hazard IdentificationPalm Gardens may receive a warning about an impending natural disaster (e.g., hurricaneforecast) or human-made threat (e.g., law enforcement report), which will be used to determineinitial response activities and the movement of personnel, equipment, and supplies. For no-noticeincidents (e.g., active shooter, tornado), Palm Gardens will not receive an advance warning aboutthe disaster. They will need to determine response activities based on the impact of the disaster.The Incident Commander may designate a staff member to monitor evolving conditions, typicallythrough television news, reports from government authorities, and weather forecasts.All staff has a responsibility to report potential or actual hazards or threats to their directsupervisor.2.1.2 ActivationUpon notification of hazard or threat—from staff, residents, or external organizations—the seniormost on-site facility official will determine whether to activate the plan based on one or more ofthe triggers below: The provision of usual standards of care and continuity of operations is threatened andcould potentially cause harm.Palm Gardens has determined to implement a protective action.Palm Gardens is serving as a receiving facility.There is an increase in residents and staff showing signs and symptoms related to aninfectious disease.Palm Gardens is testing the plan during internal and external exercises (e.g., fire drills).If one or more activation criteria are met, and the plan is activated, the senior-most on-sitefacility official—or the most appropriate official based on the incident—will assume the role of“Incident Commander” and operations proceed as outlined in this document.2.1.3 Staff NotificationOnce a hazard or threat report has been made, an initial notification message will be disseminatedto staff under the facility’s communication plan.Department Heads or their designees will contact on-duty personnel to provide additionalinstructions and solicit relevant incident information from personnel (e.g., the status of residents,the status of equipment).New York State Department of HealthCEMP (Part II) - Page 13

Once on-duty personnel has been notified, Department Heads or designee will notify off-dutypersonnel if necessary and provide additional guidance/instruction (e.g., request to report to thefacility).Department personnel is to follow instructions from Department Heads, keep lines ofcommunication open, and provide status updates promptly.2.1.4 External NotificationDepending on the type and severity of the incident, Palm Gardens may also notify external parties(e.g., local office of emergency management, resource vendors, relatives, and responsibleparties) utilizing local notification procedures to request assistance (e.g., guidance, information,resources) or to provide situational awareness.The NYSDOH Regional Office is a mandatory notification recipient regardless of hazard type,while other notifications may be hazard-specific. Table 4: Notification by Hazard Type provides acomprehensive list of compulsories and recommended external notification recipients based onhazard type.New York State Department of HealthCEMP (Part II) - Page 14

EarthquakeExtreme ColdExtreme HeatFireFloodCBRNE5Infectious Disease /PandemcLandslideMMMMMMMMMFacility SeniorLeaderMMMN/AMMMMMMMLocal EmergencyManagementRRRRRRRRRRLocal LawEnforcementMRRRRRRRRLocal Fire/EMSRRRRRRRRLocal HealthDepartmentMRRRMRROff Duty StaffRRRRRRRelatives andResponsiblePartiesMRRRRResource VendorsRRRRAuthority HavingJurisdictionRRRRegionalHealthcare FacilityEvacuation CenterRRRNotification RecipientWildfireWater DisruptionMTornadoDam FailureMPower OutageCoastal StormMIT/Comms FailureBlizzard/Ice StormNYSDOH RegionalOffice6M MandatoryR RecommendedExample HazardActive Threat4Table 4: Notification by Hazard TypeM MMMMMM RR4“Active threat” is defined as an individual or group of individuals actively engaged in killing or attempting to kill people in a populatedarea. Example attack methods may include bombs, firearms, and fire as a weapon.5“CBRNE” refers to “Chemical, Biological, Radiological, Nuclear, or Explosive”6To notify NYSDOH of an emergency during business hours (non-holiday weekdays from 8:00 am – 5:00 pm), the IncidentCommander will contact the NYSDOH Regional Office 518-402-0289]. Outside of normal business hours (e.g., evenings, weekends,or holidays), the Incident Commander will contact the New York State Watch Center (Warning Point) at 518-292-2200. The WatchCommand will return the call and will ask for the type of emergency and the type of facility (e.g. hospital, nursing home, adult home)involved. The Watch Command will then route the call to the Administrator on Duty, who will assist the facility with response to thesituation.New York State Department of HealthCEMP (Part II) - Page 15

2.2 Mobilization2.2.1 Incident Management TeamUpon plan activation, the Incident Commander will activate some or all positions of the IncidentManagement Team, which is comprised of pre-designated personnel who are trained andassigned to plan and execute response and recovery operations.Incident Management Team activation is designed to be flexible and scalable, depending on thetype, scope, and complexity of the incident. As a result, the Incident Commander will decide toactivate the entire team or privileged positions based on the extent of the emergency.Table 5 outlines suggested facility positions to fill each of the Incident Management Teampositions. The most appropriate individual, given the event/incident, may fill different roles asneeded.Table 5: Incident Management Team - Facility Position CrosswalkIncident PositionFacility Position TitleDescriptionIncidentCommanderAdministrator, Director of NursingLeads the response and activates andmanages other Incident ManagementTeam positions.PublicInformationOfficerAssistant Administrator,Admissions Director, SocialServices DirectorProvides information and updates tovisitors, relatives, and responsibleparties, media, and externalorganizations.Safety OfficerMaintenance Director, EmergencyResponse CoordinatorEnsures the safety of staff, residents,and visitors; monitors and addresseshazardous conditions; empowered tohalt any activity that poses an immediatethreat to health and safety.OperationsSection ChiefInfection Control Practitioners,Registered Nurses, LicensedNursesManages tactical operations executed bystaff (e.g., continuity of resident services,Administration of first aid).PlanningSection ChiefDirector of Staff Development,Director of Nursing, AssistantDirector of Nursing]Collects and evaluates information tosupport decision-making and maintainsincident documentation, includingstaffing plans.New York State Department of HealthCEMP (Part II) - Page 16

Incident PositionFacility Position TitleDescriptionLogisticsSection ChiefAssistant Administrator,Admissions Director, ProcurementManager, Transportation Director]Locates, distributes, and storesresources arranges transportation, andmakes alternate shelter arrangementswith receiving Palm Gardens.Finance/AdminSection ChiefBusiness Office Manager, HumanResource Director]Monitors cost related to the incidentwhile providing accounting, procurement,time recording, and cost analyses.If the primary designee for an Incident Management Team position is unavailable, Table 6identifies primary, secondary, and tertiary facility personnel that will staff Incident ManagementTeam positions.While assignments are dependent upon the requirements of the incident, available resources,and available personnel, this table provides initial options for succession planning, including shiftchanges.Table 6: Orders of SuccessionIncident PositionPrimarySuccessor 1Incident CommanderAdministratorDirector of NursingPublic Information OfficerSocial WorkerAdmission DirectorSafety OfficerEnvironmentalDirectorRehab DirectorOperations Section ChiefAdministratorPlanning Section ChiefDirector of NursingSuccessor 2ADONReceptionistReceptionistADONHuman ResourceAdmissions DirectorLogistics Section ChiefEnvironmentalDirectorFinance/Admin SectionChiefBusiness officeNew York State Department of HealthCEMP (Part II) - Page 17Recreation DirectorAdministratorDirector of NursingMedicareCoordinatorReceptionist

2.2.2 Command CenterThe Incident Commander will designate a space, e.g., facility conference room or other largegathering space, on the facility premises to serve as the centralized location for incidentmanagement and coordination activities, also known as the “Command Center.”The designated location for the Command Center is the Admission office and the secondary/backup area is the Administrator office unless circumstances of the emergency dictate the specificationof a different location upon activation of the CEMP, in which case staff will be notified of thechange at the time of activation.2.3 Response2.3.1 AssessmentThe Incident Commander will convene activated Incident Management Team members in theCommand Center and assign staff to assess designated areas of the facility to account forresidents and identify potential or actual risks, including the following: Number of residents injured or affected;Status of resident care and support services;Extent or impact of the problem (e.g., hazards, life safety concerns);Current and projected staffing levels (clinical, support, and supervisory/managerial);Status of facility plant, utilities, and environment of care;The projected impact on normal facility operations;Facility resident occupancy and bed availability;Need for protective action; andResource needs.2.3.2 Protective ActionsRefer to Annex A: Protective Actions for more information.2.3.3 StaffingBased on the outcomes of the assessment, the Planning Section Chief will develop a staffing planfor the operational period (e.g., the remainder of shift). The Operation Section Chief will executethe staffing plan by overseeing staff execution of response activities. The Finance/AdministrationSection Chief will manage the storage and processing of timekeeping and related documentationto track staff hours.New York State Department of HealthCEMP (Part II) - Page 18

2.4 Recovery2.4.1 Recovery ServicesRecovery services focus on the needs of residents and staff and help to restore the facility’s predisaster physical, mental, social, and economic conditions.Recovery services may include coordination with government, non-profit, and private sectororganizations to identify community resources and services (e.g., employee assistance programs,state and federal disaster assistance programs, if eligible). Pre-existing facility- and communitybased services and pre-established points of contact are provided in Table 7.Table 7: Pre-Identified Recovery ServicesServiceDescription of ServicePoint(s) of Contact[Recovery service or program][Description of service andsupport provided][Contact information and/orlink to website]On-going recovery activities, limited staff resources, as well as the incident’s physical and mentalhealth impact on staff members may delay facility staff from returning to normal job duties,responsibilities, and scheduling.Resuming pre-incident staff scheduling will require a planned transition of staff resources,accounting for the following considerations: Priority staffing of critical functions and services (e.g., resident care services,maintenance, dining services).Personal staff needs (e.g., restore private residence, care for relatives, attend memorialservices, mental/behavioral health services).Continued use or release of surge staffing if activated during the incident.2.4.2 DemobilizationAs the incident evolves, the Incident Commander will begin to develop a demobilization plan thatincludes the following elements: 7Activation of the re-entry/repatriation process if an evacuation occurred;7Deactivation of surge staffing;Replenishment of emergency resources;Refer to the NYSDOH Evacuation Plan Template for more information about repatriation.New York State Department of HealthCEMP (Part II) - Page 19

Reactivation of standard services and operations; andCompilation of documentation for recordkeeping purposes.2.4.3 Infrastructure RestorationOnce the Incident Commander has directed the transition from incident response operations todemobilization, the facility will focus on restoring normal services and operations to providecontinuity of care and preserve the safety and security of residents.Table 8 outlines entities responsible for performing infrastructure restoration activities and relatedcontracts/agreements.Table 8: Infrastructure Restoration ActivitiesContracts/AgreementsActivityResponsible EntityInternal assessment ofelectrical power.Director of MaintenanceClean-up of facility grounds(e.g., general housekeeping,removing debris, anddamaged materials).Director of MaintenanceInternal damageassessments (e.g., structural,environmental, operational).Director of MaintenanceN/AClinical systems andequipment inspection.Director of MaintenanceN/AStrengthen infrastructure forfuture disasters (ifrepair/restoration activitiesare needed).Director of MaintenanceN/ACommunication andtransparency of restorationefforts to staff and residents.Director of MaintenanceN/ARecurring inspection ofrestored structures.Director of MaintenanceN/ANew York State Department of HealthCEMP (Part II) - Page 20N/AN/A

2.4.4 Resumption of Full ServicesDepartment Managers will conduct an internal assessment of the status of resident care servicesand advise the Incident Commander and facility leadership on the prioritization and timeline ofrecovery activities.Special consideration will be given to services that may require extensive inspection due to safetyconcerns surrounding equipment/supplies and interruption of utility support and resident careservices that directly impact the resumption of services (e.g., food service, laundry).Staff, residents, and relatives/responsible parties will be notified of any services or resident careservices that are not available, and as possible, provided updates on timeframes for resumption.The Planning Section Chief will develop a phased plan for resumption of pre-incident staffscheduling to help transition the facility from surge staffing back to normal staffing levels.2.4.5 Resource Inventory and AccountabilityFull resumption of services involves a timely detailed inventory assessment and inspection of allequipment, devices, and supplies to determine the state of resources post-disaster and identifythose that need repair or replacement.All resources, especially resident care equipment, devices, and supplies, will be assessed forhealth and safety risks. Questions on resource damage or potential health and safety risks will bedirected to the original manufacturer for additional guidance.New York State Department of HealthCEMP (Part II) - Page 21

3 Information Management3.1 Critical Facility RecordsCritical facility records that require protection and/or transfer during an incident include: Residents chartEmployee FilesFinancial recordsMedication/Narcotic RecordsPalm Gardens utilizes Matrix Care (sigma care) which is an electronic medical record system.This system is backed up by a secure server. Some charts are maintained in paper and stored inthe Medical Record office. Some paper employee files and some paper financial records aremaintained and stored in the basement. Narcotic and medication records are kept in thesupervisor’s office and in the ADON office on the 3rd floor.If computer systems are interrupted or non-functional, the facility will utilize paper-basedrecordkeeping under internal facility procedures.3.2 Resident Tracking and Information-Sharing3.2.1 Tracking Evacuated ResidentsThe facility will use the New York State Evacuation of Palm Gardens in Disasters System(“eFINDS”)8 and the Resident Evacuation Critical Information and Tracking Form9 to trackevacuated residents and ensure resident care is maintained. Handheld scanner and wristbandswith barcode are located in the ADON office on the 3rd floorResident ConfidentialityPalm Gardens will ensure resident confidentiality throughout the evacuation processfollowing the Health Insurance Portability and Accountability Act Privacy Rule (PrivacyRule), as well as with any other applicable privacy laws. Under the Privacy Rule, coveredhealth care providers are permitted to disclose protected health information to publichealth authorities authorized by law to collect protected health information to controldisease, injury, or disability, as well as to public or private entities authorized by law or8eFINDS is a secure, confidential system intended to provide authorized users with real-time access to the location of residentsevacuated during an emergency event. The system is to be used to log and track residents during an urgent or non-emergentevacuation. See Appendix K of the NYSDOH Evacuation Plan Template for further information and procedures on eFINDS.99 The Resident Evacuation Critical Information and Tracking Form is a standardized form utilized to provide pertinent individualresident information to receiving Palm Gardens and provide redundant tracking during the evacuation process, including repatriation.See Appendix L of the NYSDOH Evacuation Plan Template for the complete form.10 see HIPAA privacy rule information in CEMP toolkit, Annex K) rivacy-emergency-situations.pdfNew York State Department of HealthCEMP (Part II) - Page 22

charter to assist in disaster relief efforts. The Privacy Rule also permits disclosure rivate counsel should be consulted where there are specific questions about residentconfidentiality.3.3 Staff Tracking and Accountability3.3.1 Tracking Facility PersonnelPalm Gardens will use the New York State Evacuation of Palm Gardens in Disasters System(“eFINDS”)10 and the Resident Evacuation Critical Information and Tracking Form11 to track staff.3.3.2 Staff AccountabilityStaff accountability enhances site safety by allowing the facility to track staff locations andassignments during an emergency. Staff accountability procedures will be implemented as soonas the plan is activated.Palm Gardens will utilize the hand p

PALM GARDENS CENTER FOR NURSING AND REHABILITATION 615 AVENUE C, BROOKLYN, NY 11218 718-633-3300 PALM GARDENS CENTER FOR NURSING AND . Comprehensive Emergency Management Plan Part II 2020 . New York State Department of Health CEMP (Part II) - Page 2 Instructions Palm Gardens adapted The NYSDOH Comprehensive Emergency Management (CEMP) .

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