Emergency / Disaster Preparedness and Continuity of Operations Plan

Emergency / Disaster Preparedness and Continuity of Operations Plan

Policy Statement

The Company maintains an Emergency / Disaster Preparedness and Continuity of Operations Plan to support the safety and well-being of recipients, caregivers, and staff during emergencies or disasters that may disrupt the provision of Applied Behavior Analysis (ABA) services.

As a provider of behavior analysis services delivered primarily in-home and within community settings, the organization does not provide residential care, emergency sheltering, transportation, medical treatment, evacuation services, or emergency medical response. Parents, legal guardians, and caregivers remain responsible for emergency decision-making, supervision, transportation, evacuation, sheltering, and medical care of recipients during emergencies or disasters.

The organization will make reasonable efforts to maintain communication, continuity of care, and behavioral support services to recipients and families during emergency situations while prioritizing the safety of staff and recipients.

• the need for services,
• the organization's ability to provide services,
• staff availability, or
• access to client homes or community locations.

This policy applies to all employees, contractors, volunteers, and administrators of the Company.

Scope of Services During Emergencies

The Company provides behavior analysis services only and does not function as:

• a residential provider,
• home health agency,
• medical provider,
• emergency shelter,
• transportation provider, or
• emergency response agency.

Because most services are rendered within the home and community environment, the organization's primary role during emergencies or disasters shall be to provide families and caregivers with behavioral tools, support strategies, continuity recommendations, and environmental management guidance intended to assist recipients during periods in which structured ABA therapy services may be temporarily interrupted.

Families and caregivers shall be educated on:

• maintaining routines,
• implementing reinforcement strategies,
• reducing behavioral escalation risks,
• promoting safety,
• supporting emotional regulation, and
• managing environmental disruptions during emergency conditions.

Temporary disruption, modification, cancellation, or suspension of services may occur during emergencies due to:

• safety concerns,
• evacuation orders,
• hazardous conditions,
• staffing limitations,
• utility disruptions, or
• operational interruptions.

Structured ABA services are expected to resume as soon as emergency conditions have stabilized and operations can safely continue.

Definitions

Emergency. Any event that disrupts normal operations or poses a threat to the safety of recipients, caregivers, staff, or the community, including but not limited to:

• hurricanes,
• tropical storms,
• flooding,
• severe weather,
• fires,
• power outages,
• public health emergencies,
• hazardous material incidents,
• civil emergencies, or
• infrastructure failures.

Continuity of Operations. The ability of the organization to maintain essential administrative and clinical functions during and after an emergency.

Mitigation Activities

The organization shall implement mitigation activities intended to reduce risks associated with emergencies and disasters. These activities may include:

• Maintaining updated emergency contact information for recipients and staff.
• Maintaining smoke detectors and fire extinguishers within office locations, when applicable.
• Maintaining secure backup systems for electronic records and communication systems.
• Protecting confidential client information through password-protected systems and secure electronic storage.
• Educating staff regarding personal and family emergency preparedness planning.
• Assisting caregivers with identifying community emergency resources when clinically appropriate.
• Identifying recipients who may require additional behavioral support or continuity planning during emergencies.
• Monitoring weather alerts and emergency declarations impacting operational areas.

Preparedness Activities

Preparation activities are intended to build organizational readiness before emergencies occur. These activities include:

• Orientation and annual training regarding emergency procedures.
• Periodic review and evaluation of emergency preparedness procedures.
• Maintaining updated staff contact information.
• Maintaining operational supplies such as flashlights, portable chargers, and communication resources.
• Establishing communication procedures for office closure notifications and operational updates.
• Coordinating, when appropriate, with local emergency management resources and community agencies.

Hurricane and Severe Weather Preparedness

Due to the organization's operations within the State of Florida, the organization shall maintain hurricane and severe weather preparedness procedures.

Prior to anticipated hurricanes or tropical storms, the organization may:

• contact families regarding anticipated operational changes,
• review continuity-of-care needs,
• provide behavioral support recommendations,
• discuss anticipated service interruptions,
• instruct staff regarding temporary service suspension procedures, and
• communicate office closure information.

Community-based and in-home services may be modified, canceled, rescheduled, or suspended when hazardous conditions exist.

Emergency Response Procedures

In the event of an emergency, the Administrator, Clinical Director, or designated leadership staff shall implement emergency response procedures.

The organization may:

• assess operational status,
• determine staff availability,
• prioritize continuity-of-care communication,
• notify families regarding service disruptions,
• provide behavioral support recommendations when appropriate, and
• coordinate with local emergency resources as necessary.

The organization shall not require staff to enter unsafe environments or travel under dangerous conditions.

Service Suspension and Modification

Services may be temporarily modified, canceled, rescheduled, or suspended under the following circumstances:

• state or local emergency declarations,
• mandatory evacuation orders,
• unsafe travel conditions,
• severe weather warnings,
• utility disruptions,
• public safety concerns,
• staffing limitations, or
• inability to safely access service locations.

Clinical leadership shall determine whether services may continue based upon:

• recipient safety,
• caregiver participation,
• staff safety,
• environmental conditions,
• operational capacity, and
• payer or regulatory requirements.

Communication Procedures

The organization shall utilize available communication methods to maintain contact with staff and families during emergencies.

Primary communication methods may include:

• cellular telephones,
• email,
• text messaging,
• electronic health record messaging systems, and
• other available communication platforms.

If electronic communication systems become unavailable, staff may be instructed to report to designated office leadership for operational assignments when safe to do so.

Behavioral Support During Emergencies

When operationally feasible, behavior analysts may provide caregivers with behavioral support recommendations intended to:

• reduce stress,
• support behavioral stability,
• maintain routines when possible,
• reduce maladaptive behavior risks associated with environmental disruption, and
• support safety during emergencies.

Recommendations may include:

• visual schedules,
• reinforcement strategies,
• transition supports,
• coping strategies,
• environmental structure recommendations,
• behavior prevention strategies,
• de-escalation supports, and
• caregiver support strategies.

The organization recognizes that, during emergencies, caregivers may temporarily assume a greater role in implementing behavioral supports due to interruptions in structured therapy services.

Confidentiality and HIPAA Compliance

Reasonable safeguards shall be implemented to protect confidential client information during emergencies and disasters. The organization shall:

• maintain secure electronic systems,
• utilize password-protected devices,
• maintain backup records when feasible,
• limit disclosure of protected health information to authorized purposes, and
• comply with applicable HIPAA Privacy and Security requirements.

Information shared with emergency management authorities shall be limited to the minimum necessary information permitted by law.

Documentation Requirements

Emergency-related activities shall be documented when clinically or operationally relevant, including:

• communication attempts,
• caregiver notifications,
• service cancellations,
• service interruptions,
• continuity-of-care efforts,
• emergency operational decisions, and
• clinically relevant behavioral recommendations.

Documentation shall be maintained consistent with organizational policies and the applicable funding source’s documentation requirements, including Florida Medicaid where applicable.

Recovery Procedures

Recovery activities shall begin following stabilization of emergency conditions and may include:

• restoring office operations,
• restoring communication systems,
• resuming normal business hours,
• resuming clinical services when safe,
• assessing operational disruptions,
• reviewing staff and client needs, and
• evaluating emergency response effectiveness.

Structured ABA services shall resume as soon as emergency conditions permit safe continuation of services.

Staff Responsibilities

Clinical Staff. Clinical staff, including BCBAs, BCaBAs, and RBTs, shall:

• follow organizational emergency procedures,
• maintain communication with supervisors,
• document service disruptions as appropriate,
• prioritize safety,
• provide behavioral support recommendations when directed, and
• comply with emergency operational instructions.

Administrative Staff. Administrative staff shall:

• assist with communication efforts,
• support operational coordination,
• maintain emergency contact systems,
• assist with scheduling changes, and
• support continuity-of-operations activities.

Staff are responsible for maintaining their own personal emergency preparedness plans, transportation, and housing arrangements.

Chain of Command

In the event of an emergency, operational authority shall follow the following chain of command:

1. Administrator
2. Clinical Director
3. Operations Manager or Office Manager
4. Designated Leadership Staff

A designated leadership representative may assume operational responsibilities when primary leadership personnel are unavailable.

Annual Training and Evaluation

All staff shall receive training regarding this Emergency / Disaster Preparedness and Continuity of Operations Plan:

• upon hire or onboarding,
• annually thereafter, and
• following significant revisions to the plan.

The organization shall review and evaluate the effectiveness of the emergency preparedness plan at least annually and following actual emergency events when appropriate.

Evaluations may assess:

• communication effectiveness,
• operational continuity,
• staff preparedness,
• resource allocation,
• continuity-of-care procedures, and
• overall emergency response effectiveness.

Revisions shall be implemented as needed to improve organizational preparedness and response capabilities.