Florida News: What to Know Before Submitting Your Emergency Management Plan

The Florida Department of Health has shared a practical resource for home care agencies: a list of the most common reasons Comprehensive Emergency Management Plans (CEMPs) are returned for revision. The observations come directly from the plan review process, and they offer a useful checklist for agencies preparing to submit or update their plans. ​

The good news: Most issues are fixable before you ever hit submit. Here's what reviewers flag most often, organized by plan section. 
 
Contact Information (Section I, Questions 2–4) 
Three questions in Section I ask for contact information for key personnel: the person in charge during an emergency, agency owners, and the individuals who developed the plan. The same issue comes up across all three: Each person listed must have two separate methods of contact. One of those methods can be an email address, but a single phone number alone isn't sufficient. 
 
Plans missing only this information generally won't be marked for revision, but it's worth getting right regardless. 
 
Plan Activation (Section II, A2) 
Reviewers frequently return plans that don't clearly identify who is responsible for activating the emergency plan or how they do it. The plan should name that person and specify the notification method, whether that's a phone call, email, text, or another channel. 
 
Staff Responsibilities (Section II, A3) 
Vague language here is a common problem. Reviewers expect a clear description of each designated staff member's role when the plan is activated, both operational responsibilities and support functions. "Staff will assist as needed" isn't enough detail. 
 
Special Needs Registry Documentation (Section II, B2) 
Plans need to explain how the agency documents emergency planning discussions with patients who require continued services but aren't registered with the Special Needs Registry, including any coordination with Assisted Living Facilities (ALF) and Adult Family Care Homes (AFCH). 
 
Prioritized Patient List (Section II, C7) 
Two items are commonly missing here: a statement confirming the list will be made available to the County Health Department or local Emergency Management agency upon request, and an explanation of how the list is maintained and kept current. 
 
Continuing Care During Non-Mandatory Evacuations (Section II, D1) 
Reviewers look for documentation of how the agency will determine whether patients who choose to stay home, in an ALF, or in an AFCH need continued services during an emergency. 
 
Medication, Supplies, and Equipment (Section II, E1) 
Plans need to explain how these lists are established and maintained. It’s not enough to say that they exist; you should outline the process behind keeping them current for special needs patients. 
 
Continuity of Essential Care (Section II, E3) 
If patients relocate during an emergency — whether within or outside the agency's service area — the plan needs to describe how the agency will continue essential services or connect them with another organization that can. 
 
Employee Training (Section III, Question 2) 
The training section often lacks sufficient detail. Plans should describe the full scope of the training program, including what constitutes an emergency, when the plan takes effect, staff roles and responsibilities, patient education procedures, information on the Special Needs Registry, and guidance for staff who volunteer at Special Needs Shelters. 
 
Agreements and Understandings (Appendix A) 
This is one of the most consistent problem areas. Mutual aid agreements, MOUs, and other required documents are frequently missing, expired, unsigned, or undated, and many don't specify expiration or renewal terms. Before submitting, confirm that every agreement included is current, signed, dated, and includes renewal terms. 
 
If you have questions about your agency's CEMP, contact Director of Government Relations Allison Cramer or join our monthly Government Relations Office Hours the second Wednesday of each month (details on the HCAOA events calendar).