All Hazards Response Plan The CenterPoint All Hazards Response Plan is approved under authority delegated to the Chief Administrative Officer. _____________________________________________ Ronda Outlaw, LCSW, CAO August 1, 2015 Date Executive Team Approval 6/29/15 Table of Contents Introduction 3 Important Contacts 6 Essential Function Plans Communications Physical Location Management & Information Services Customer Services Crisis Provider Services Pharmaceuticals Utilization Management Transportation Accounts Payable/Billing & Claims CenterPoint Employee Payroll Emergency Cash 9 12 15 18 21 24 26 28 30 32 34 APPENDICES 36 37 38 41 50 Appendix 1 All Hazards Information Appendix 2 Procedure on Succession Plan Appendix 3 FEMA Budget Guidelines Appendix 4 All Hazards Response Volunteer Assurance of Confidentiality Agreement 2 Introduction The CenterPoint Human Services (CenterPoint) All Hazards Response Plan (Plan) contains information and procedures for preparedness and response to natural and man-made disasters. The Plan is intended as a guide for continuation of CenterPoint Essential Functions and the mobilization of mental health, intellectual/developmental disabilities and substance abuse services if a disaster requires such services. During a disaster, counties, municipalities or divisions of the State of North Carolina could call upon CenterPoint or service providers in its network for assistance. The Plan should be executed in conjunction with the CenterPoint Emergency Action Plan. It is important to note that procedures outlined within the Emergency Action Plan are to be followed when an emergency procedure requires response or evacuation from CenterPoint buildings. CenterPoint essential functions are operational functions that must continue in the event of any natural or man-made disaster. Each essential function has an "Order of Restoration Plan" to follow during a disaster event. Essential functions are identified as: 1. Communications 2. Physical Location 3. Management & Information Services 4. Customer Services 5. Crisis Provider Services 6. Pharmaceuticals 7. Utilization Management 8. Transportation 9. Accounts Payable/Billing & Claims 10. CenterPoint Employee Payroll 11. Emergency Cash Individual plans for each essential function are outlined on the following pages. Additionally, the Appendices section of this plan contains other documents that support the continuance of CenterPoint’s essential functions and disaster response. As the agency responsible for managing mental health, intellectual/developmental disabilities and substance abuse services in Forsyth, Stokes, Davie and Rockingham Counties in North Carolina, We have 24-7 customer services that will link callers to appropriate services, including crisis services; however, we do not provide services. CenterPoint must maintain the ability to manage services in the event of a disaster. 3 The Plan is reviewed and updated annually. CenterPoint’s Disaster Response Coordinator is responsible for the Plan and works in conjunction with Disaster Response Team Leads, Successors and the agency’s Human Services Health & Safety Coordinator to assure proper response. The Plan fulfills the Devolution of Operations Plan, which addresses a key component of the Continuity of Operations Plan (COOP) identified in Federal Preparedness Circular (FPC) 65, Federal Executive Branch Continuity of Operations (COOP), dated June 15, 2004. In compliance, the Plan meets the following objectives: 1. Prioritizes essential functions and determines the resources needed to facilitate their immediate, seamless transfer to a devolution site; 2. Includes a roster of the organization’s Point of Contacts at the designated devolution site with overall responsibility for the fully equipped and trained personnel who will perform essential functions and activities when the devolution option of COOP activates; 3. Identifies the likely activation conditions (triggers) that would initiate or activate the Devolution of Operations Plan; 4. Specifies how and when direction and control of agency operations will transfer to the devolution of operations site(s); 5. Lists necessary resources (people, equipment, and materials) to perform essential functions at the devolution site; 6. Establishes reliable processes and procedures to acquire the resources necessary to continue essential functions and sustain operations for extended periods; and 7. Establishes capabilities to restore or reconstitute agency authorities to their pre-event status upon termination of devolution. 4 5 Important Contacts The CenterPoint Plan depends heavily on communicating with internal Hazards Response Team Leads, crisis service providers, State employees and various emergency response personnel across the communities of Forsyth, Stokes, Davie and Rockingham Counties. Below is a list of important contacts should a disaster response be necessary. CenterPoint Human Services Lead Hazards Response Team Member: Betty P. Taylor, Esq. CEO/Area Director Office: 336-714-9118 Cell: 336-817-0815 Disaster Response Coordinator: Leona Williams, Community Operations Manager Office: 336-714-9131 Cell: 336-403-4434 Health & Safety Coordinator: Dave Burchette, Facilities Manager Office: -336-714-9189 Cell: 336-462-6295 NC Division of Mental Health/Developmental Disabilities/Substance Abuse Services Disaster Preparedness and Response Coordinator Kate Abell Office: 919-715-2780 Cell: 919-426-1855 Fax: 919-733-1221 Local Management Entity/Managed Care Organization (LME/MCO) Disaster Response Coordinators Contiguous to CenterPoint’s catchment area: Partners Behavioral Health: Dr. Mike Forrester CCO 704-884-2652, Cardinal Innovations Health Care: Jennifer Love-Pennell, 704-939-7861, Cell 704-7836592 Sandhills Center: Phil Hewett, 919-673-7226, Cell-910-690-7013 Forsyth County Emergency Management: Leigha D. Cordell 336-767-6161 Forsyth County COAD: Ken Hoglund, Chair Activated by Forsyth County Emergency Management if needed. Health Department: Yolanda Galloway 336-703-3433 Social Services: Gayle Swain 336-703-3400 Law Enforcement Forsyth County Sheriff: 336-748-4100 6 Winston-Salem Police: 336-773-7700 Kernersville Police: 336-996-2390 Fire and Rescue EMS: 336-703-2750 Winston-Salem Fire: 336-773-7900 Forsyth County Fire: 336-703-2550 Stokes County Emergency Management: Gregg Collins: 336-593-5409 x 5 Emergency Response Coordinator: Jessica Watkins: 336-593-2400 x 2447 Health Department: Wanda East: 336-593-2400 x 1201 Social Services: Stacey Elms: 336-593-2861 x 2434 Law Enforcement Stokes County Sheriff: 336-593-8787 King Police: 336-983-0886 Walnut Cove Police: 336-591-7121 Fire and Rescue EMS: 336-593-2423 Fire Marshall: 336-593-2083 King Fire: 336-983-3030 Davie County Emergency Management: Jerry Myers, 336-753-6163 Cell 336-909-1164 Luann Angell, 336-753-6750 Cell 336-940-8151 Health Department: Suzanne Wright, 336-753-6751 Cell 336-477-5074 Social Services: Tracie Murphy 336-753-6251 Cell 336-341-5414 Law Enforcement Davie County Sheriff: 336-751-6238 Mocksville Police: 336-751-6231 Fire and Rescue EMS: 336-753-6163 Fire Marshall: 336-753-6163 Fire & Rescue Association: 336-753-6170 Rockingham County Emergency Services: Johnny Bowles, 336-634-3017 Health Department: Charlotte Martin, 336-342-8241 Social Services: Felissa Ferrell, 336-342-1394 X 7126 7 Law Enforcement Rockingham County Sheriff: 336-634-3232 Eden Police Department: 336-623-9755 Madison Police Department: 336-548-6097 Mayodan Police Department: 336-548-6038 Reidsville Police Department: 336-349-1010 Stoneville Police Department: 336-573-9393 Fire and Rescue Fire Marshall: 336-634-3017 Local Hospitals Novant Health / Forsyth Medical Center, Winston-Salem, NC: 336-718-5000 Novant Health / Kernersville Medical Center, Kernersville, NC: 336-564-4000 Wake Forest Baptist Health Forsyth County Hospital, Winston-Salem, NC: 336-716-2011 Pioneer Community Hospital, Danbury, NC: 336-593-2831 Wake Forest Baptist Health Davie Medical Center, Mocksville, NC: 336-751-8100 Cone Health / Annie Penn Hospital, Reidsville, NC: 336-951-4000 Morehead Memorial Hospital, Eden, NC: 336-689-9711 Novant Health Medial Park Hospital, Winston Salem, NC: 336-349-3434 Veterans Administration VA Outpatient Clinic (Winston-Salem, NC): Tom Magin 336-768-3296 American Red Cross (NW Chapter) Jeff McPherson 336-245-5751 American Red Cross (Rockingham County) Mandy Shields 336-349-3434 Community Organizations Active in Disaster (COAD) Ken Hoglund 336-724-2866 Media TV STATIONS: WXII: 336-721-9944 Fox WGHP: 336-878-1894 WFMY: 336-379-9369 News 14 Carolina: 336-856-9497 RADIO STATIONS: WBFJ: 336-777-1893 WSJS: 336-777-3900 107.5 KZL: 336-274-8042 WFDD 88.5: 336-758-8850 8 Communications RESPONSE LEAD: Betty Taylor, Chef Executive Officer Office: 336-714-9118 Cell: 336-817-0815 If unavailable then please call CenterPoint Customer Services at 1-888-581-9988 SUCCESSOR: Penny Casto, Consumer & Community Affairs Manager Office: 336-714-3545 Cell: 336-306-2533 OVERVIEW: In the event of a disaster, it is necessary to reach a wide variety of audiences with appropriate types of communication. To provide a guideline for communications in the event of a disaster, types of communication, audiences and communication procedures are identified in this area of the All Hazards Plan. Coordination with other agencies during a disaster response is paramount. The "Important Contacts" section of this plan will be utilized in order to communicate with needed response and support agencies. CenterPoint will coordinate responses with the local Departments of Emergency Management, the American Red Cross and the NC Division of MH/DD/SA Disaster Response Team when necessary. Forms of Communication during a Disaster The following types of communication should be considered during any response to a disaster. It may be necessary to utilize multiple types of communication to assure proper communication is being achieved. Land Phones can be utilized when power is present in a disaster event and there are no apparent electrical hazards present, which would prevent their use (4045 University Parkway, Winston Salem has generator back up). Land phones should not be used in the event of thunderstorms due to the threat of lightning. Voicemail Messages can be utilized to communicate an effective and consistent message. In the event of a disaster, which requires information on closing of offices or restricted sites, a pre-recorded voicemail on CenterPoint's main line or employee cell phones can serve as a means of communicating information. To record a new message on CenterPoint’s main line and, follow these steps: (ask ? to CFT) Main Greeting: Melody Moore, Director of Customer Services Office: 336-778-3522 9 Cell: 336-403-7995 Offsite: 336-714-9376 Cell Phones are usually a very consistent means of communicating during most disasters. They are safe to use when electrical hazards are present, but cannot be charged if power is unavailable. CenterPoint Building 4045 has generator capability and will be the primary location to recharge phones. If power outages are wide spread and Building 4045 is not available, the Facilities Manager will identify the closest location with power. Alternatively, cell phones may be charged in automobiles. E-mail can be utilized to communicate a message in a very quick and efficient manner to a large number of stakeholders. If power and computer operations are available, e-mail lists stored within the Communication List can be an effective way to target individuals. To utilize CenterPoint e-mail from a remote location the following steps may be taken. 1. Log on to Outlook mail via URL: https://webmail.cphs.org/owa 2. For "User Name" enter: cphs\your three initials - example: cphs\mdc 3. For "Password" enter your existing password used at work to access account Websites maintained by CenterPoint and provider agencies can be utilized by posting messages on the sites homepages. This means of communication depends upon staff availability, time, and power and computer operations. TV/Radio outlets can be used in the event of a mass disaster during which information must be communicated to the public. A TV/Radio contact list is included in the Important Contacts section of this plan. Identified Audiences: Employees, Providers, Clients/Enrollees In the event that a disaster response message must be communicated, it is critical that the right audience gets the right message. In the event of a disaster, Disaster Response Team members may be privy to sensitive information that should not be communicated to certain audiences. The CEO/Area Director, who serves as the Lead Disaster Response Team member, is the designated communication lead and decides what messages are to be communicated to which audiences in conjunction with the Disaster Response Coordinator. The CEO/Area Director also designates and approves persons who are allowed to communicate needed messages. News/Media It is of paramount importance that all media inquiries be directed to the Disaster Response Coordinator for proper follow up. The Disaster Response Coordinator will work with the CEO/Area Director or individuals appointed by the CEO/Area Director to handle inquiries from the media. All other persons shall refrain from discussing the situation with outsiders, especially the media. In the event that neither the Disaster 10 Response Coordinator nor CEO/Area Director is available, Disaster Response Team Leads are permitted to speak with the media if necessary. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 11 Physical Location RESPONSE LEAD: Cathy Wilson, Deputy Chief Financial Officer/Acting Chief Financial Officer Office: 336-714-9160 Cell: 336-462-6296 SUCCESSOR: Dave Burchette, Facilities Manager Office: 336-714-9189 Cell: 336-462-6295 OVERVIEW: CenterPoint currently operates three physical locations within the city limits of Winston-Salem: 4045 University Parkway, 4035 University Parkway and 4025 University Parkway. If a disaster were to disable a CenterPoint operated site, it would be necessary to establish a Command Center from which essential functions could operate. Any of the existing CenterPoint locations could serve as a Command Center if another is damaged or destroyed by a disaster. If all three physical locations were destroyed, CenterPoint would work with the Red Cross to designate an alternative location as a Command Center. A physical location may also need to be established for crisis provider services (see that section of the plan) in the event that a triage setting is required. If a disaster occurs during normal business hours when CenterPoint’s physical locations are open, emergency operations procedures will be followed to evacuate the disaster area and to determine the relocation of essential functions. In the event that disaster strikes a physical location after normal business hours, the Response Lead or Successor of this section will travel to the disaster location to determine relocation needs and begin the Order of Restoration Plan. Setting up a Triage Location Forsyth County CenterPoint has access to three physical locations within the Winston-Salem City limits – 4045, 4035 and 4025 University Parkway. If needed, a triage would most appropriately be placed at the 4045 University Parkway location. Additional locations can be identified by calling American Red Cross (NW Chapter): 336-724-2551, and/or by calling Forsyth County Emergency Management: 336-7676161. Stokes County CenterPoint has access to a physical location in Stokes County at Autumn Square, Suite 200, 3169 NC Highway 8 South, Walnut Cove, 27052. Locations can be identified by calling American Red Cross (NW Chapter): 336-7240511; Salvation Army: 336-722-8721; and/or by calling Stokes County Emergency Management – 336-593-2724. 12 Davie County CenterPoint has access to a physical location in Davie County at 172 Clements Street, Mocksville, NC 27028. Additional locations can be identified by calling American Red Cross (NW Chapter): 336-724-0511; Salvation Army: 336-722-8721; and/or by calling Davie County Emergency Management: 336-761-0879. Rockingham County Additional locations can be identified by calling American Red Cross (Rockingham County Chapter): 336-349-3434; Salvation Army: 336-722-8721; and/or by calling Rockingham County Emergency Services – 336-634-3000. Supporting a Triage Location In the event that CenterPoint is called upon to support an existing triage location, the triage is likely to have been established by the local American Red Cross, or a county emergency response department. If CenterPoint is called upon for support, the Disaster Response Coordinator will contact the crisis response providers that are listed within the Crisis Provider Services section of this plan to relay the call for support at the triage location. Relocation Goals Day One: 1. Identify essential functions impacted by disaster, which need to be relocated. 2. Secure a new location with the help of a commercial property realtor or the American Red Cross as appropriate. 3. Begin moving essential functions to the new location and begin operation. Day Two: 1. If needed, complete the relocation of essential functions. 2. Take a full assessment of operational functions in their new location and adjust as needed. Day Three: 1. Based on the disaster's impact, create a timeline for the length of time operational functions could be located at the support site. 2. Identify ongoing needs to support the continuation of each function. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Steps: 1. Determine the need to relocate and identify where relocation would best support those in need. 2. If needed, visit the disaster site. 13 3. Communicate the message of relocation to Disaster Response Leads, as appropriate. 4. Communicate the message to essential functions department employees to prepare for relocation. 5. Communicate the message of relocation to all employees, and other stakeholders. 6. Secure all physical and tangible materials that need to be transported. 7. Relocate essential functions. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 14 Management & Information Services RESPONSE LEAD: Debbie Lanning, Chief Information Officer Office: 336-714-9339 Cell: 336-671-9308 SUCCESSOR: Robert Couch, Business Process Manager Office: 336-714-9391 Cell: 336-409-8114 SUCCESSOR: Anthony Perkins, Business Operations Manager Office: 336 714-9307 Cell: 336745-1207 OVERVIEW: The MIS Information Management Program Description (IMPD) outlines how CenterPoint, as the Local Management Entity / Managed Care Organization (LME/MCO) would recover/support massive or minor management information systems if they were impacted by a disaster. The IMPD applies to mainframe, phone system, email, server systems and databases, that contain PHI or that are critical to the everyday operation of the LME/MCO. At the onset of an emergency or disaster, an immediate evaluation will be conducted to determine the severity of the actual or threatened disruption and whether the IMPD will be implemented (including determining the need to implement the Customer Services emergency response procedures; contacting the LME/MCO’s disaster recovery vendor, Dynamic Quest; and/or contacting the LME/MCO’s recovery site located in Charlotte, NC and CenterPoint’s Wellness Centers to provide virtual server services that would facilitate the disaster recovery process). The IMPD outlines how the LME/MCO would access CenterPoint data including electronic PHI in the event that the 4045 University Parkway location was deemed totally incapacitated. The LME/MCO has developed a variety of responses to address an emergency or disaster depending upon the nature and scope of the event. The following are contingency scenarios: In case of a disruption to the telecommunication infrastructure, all telephone calls will be routed to the recovery site located in Charlotte, NC. In the event of a single system failure, every effort would be made to quickly restore that system with operations remaining in place. In the event of limited vandalism, an assessment would be made as to how quickly affected systems could be restored before deciding whether to remain in place. 15 In the event of a fire or natural disaster that destroyed the building and server room the Lead will quickly activate the Plan and move our operations to the alternate warm site. The local authorities or the property owner of the building could determine reactions to a limited building fire or disaster. If forced out of the building for an extended period by an emergency or disaster but our IT equipment remained intact, the LME/MCO will exercise the option of quickly moving the intact equipment to an alternate location as determined by the “Facilities Emergency Mode Plan.” Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. The Plan would be activated in the event that the building at 4045 University Parkway, Republic Square, was destroyed by disaster. In the event of a contained fire (server room) or vandalism (to the server room), all efforts would be made to re-build the resources in the current server room at Republic Square as quickly as possible. The MIS Support Manager would be responsible for developing and implementing the Plan. All MIS staff would work together as a team to quickly bring the IT resources back online again. Recovery Site(s) The LME/MCO will use a combination of recovery sites in the event of a disaster at the Republic Square. Windows servers and databases will be recovered at a virtual server room located at Peak 10, Charlotte, NC. The redundant server room and workstation lab located at 725 N Highland Avenue will be utilized. Procedures for Restoring Windows Severs The LME/MCO is prepared to recover its critical Windows servers if they were impacted by a disaster at the Republic Square location. The (7) current critical Windows servers are the "SQL1 server," the"MS2 e-mail" server, the”DC1” server, the ”FS2” server, the“GP1” server, the “SFTS1” server, and the “PAS1” server. The LME/MCO contracts with vendor Dynamic Quest, to provide virtual server services that would facilitate our disaster recovery process. Dynamic Quest utilizes two virtualization servers called BDRs. One BDR is located in the LME/MCO’s server room, constantly monitors critical servers and takes hourly incremental snapshots of server data. After business hours, this BDR replicates all data to the second BDR located at the Peak 10 facility in Charlotte, NC. The BDR synchronization methodology allows Dynamic Quest to rapidly erect a functioning clone of any of the critical servers at either the LME/MCO site or the Charlotte Peak 10 site. In the event of disaster at the Republic Square facility, the LME/MCO will take the following actions to regain access to critical servers: 16 Contact Dynamic Quest personnel and ask that they spin up virtual versions of necessary servers at the Peak 10 complex. Contact North Carolina State IT personnel and request that DNS records be altered to point CPHS.org bound traffic to the IP address of the Peak 10 complex. The above manipulations will be transparent to the LME/MCO’s users. Users will be enabled to establish remote connections to critical computing resources using the normal protocols. Normal business operations will resume once the redundant site and the North Carolina State IT personnel alter the IP address. Procedure to Recover Workstations for Use with All Servers/Virtual Servers All critical staff will utilize CenterPoint laptops with internet access that allows remote connection to critical computing resources. Critical staff will work from home connecting to virtual computing resources using normal connection protocols. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 17 Customer Services RESPONSE LEAD: Burch Johnson, Chief Operations Officer Office: 336-714-9138 Cell: 336-403-5344 SUCCESSOR: Melody Moore, Customer Services Director Office: 336-778-3522 Cell: 336-403-7995 Offsite: 336-714-9376 OVERVIEW: The Customer Services Recovery Plan outlines how CenterPoint would continue to operate its Screening, Triage and Referral services in the event of a temporary, long-term emergency or disaster. The plan applies to the CenterPoint Customer Services Department, its employees and the infrastructure that supports it. Conditions for Activating the Plan: The building at 4045 University Parkway is incapacitated necessitating re-location of the Customer Services staff to another location. NOTE: Currently, designated employees as indicated on the Customer Service Organizational Chart have equipment in their homes that would allow them to continue the Customer Services function from their homes. If additional staff is needed, calls will be routed to individual staff until our primary building is operational or until we find an alternative primary site. CenterPoint cell phones and mobile wireless cards are available for backup phone access and internet access. Occurrence of a major internal phone equipment failure, which cannot be recovered within a reasonable amount of time. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. The Network IS and Customer Services Managers would be responsible for developing and implementing a Disaster Recovery Plan for the Customer Services Department. In the event of an actual emergency or disaster, the IS staff and Customer Services staff would work together quickly to enact the plan. 18 Recovery - CenterPoint Customer Services staff could use any location with direct-dial telephone service in the event of an emergency that required Customer Services support. Additionally, some staff could work from home. The In Contact system has the ability to route calls to any 10-digit phone number. The system is also capable of routing the calls to clinicians who work independently from CenterPoint’s external phone service. Therefore, the Customer Services department should be able to operate during any outage. Both AlphaMCS (the MIS system) and In-Contact can be accessed via internet connection. Procedures for Customer Services Department during an Emergency - In the event of a disaster that would incapacitate all three- buildings at Republic Square – 4045, 4035 and 4025 University Parkway, Winston-Salem -- the Customer Services department would operate as follows: Customer Services Staff would immediately use MIFI cards and Laptops to direct the phone traffic so that all calls are routed to the “overflow” call vendor Western Regional Partners. The calls are routed to the Western Regional Partners during the time it takes to get “at-home” agents mobilized and ready to receive calls. All staff equipped to provide Customer Services functions in their homes would be mobilized. At this point, calls would be routed back to the Customer Services Call Center staff rather than to the Western Regional Partners. Additionally, other staff could accept calls at any location with direct dial telephone service until a suitable, alternate location could be acquired. CPHS cell phones, laptops, and MIFI cards would be available for backup phone access and internet access so that on-site staff could maintain Customer Services functions. Efforts would be made to quickly repair the Republic Square location or find alternate space to house CenterPoint operations. If necessary, a new phone system would be procured, this could take 6-8 weeks from initiation. If the primary ACD system (In-Contact) fails during this period, the backup ACD system (Prairie Fyre, Oasis) would be utilized. If Republic Square and back-up systems should fail or are damaged in a natural disaster, CenterPoint could route all phone traffic to the Western Regional Partners and Customer Services staff would utilize cellphones and paper process to maintain functions, i.e. follow up on calls initially answered by Western Regional Partners In addition, CenterPoint’s call “overflow” vendor (Western Regional Partners) would be notified of the agency’s difficulties and they would “staff up” to provide extra coverage for our calls. 19 Customer Services staff should have hard copies of all manuals and other tools they use during phone calls and should be prepared to take them to the redundant Customers Services location. Maintenance Schedule - The Customer Services Disaster Recovery Plan will be tested and documented at a minimum of one time yearly. IN ALL CASES, Protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 20 Crisis Provider Services RESPONSE LEAD: (Shared) Melody Moore, Customer Services Director Office: 336-778-3522 Cell: 336-403-7995 Offsite: 336-714-9376 Leslie Gerard, Network Management Director Office: 336-714-9361 Cell: 336-341-5986 SUCCESSOR: Leona Williams, Community Operations Manager Office: 336-714-9131 Cell: 336-403-4434 OVERVIEW: If a disaster impacts enrollee services, it is the express responsibility of the impacted service provider or outside emergency responder to notify CenterPoint's Disaster Response Coordinator so that appropriate action can be taken in conjunction with identified Crisis Providers. In the event of a disaster, it will be determined how to offer support through CenterPoint's Customer Services line and/or Mobile Crisis and Crisis Provider Services. Customer Services personnel can also determine if a person in need is already in the public service system and has a clinical home service provider who serves as a "First Responder." All CenterPoint providers may be called upon to support functions within Forsyth, Stokes, Davie and Rockingham Counties as well as to support regional response efforts as identified by state and federal departments. Each service provider should have, and is responsible for, an individual Emergency Operations Plan to enact in the event of a disaster. Each Crisis Provider is responsible for dispatching employees who have had appropriate crisis response trainings such as Incident Command System/National Incident Management System (ICS/NIMS) and behavioral health response. Crisis Providers responding to a disaster should also be prepared to offer early intervention, psychological first aid, counseling, and identify persons who may be in need of long term services. Examples of Crisis Provider responses include, but are not limited to: Local and regional response Complete relocation of enrollees Setting up and/or supporting a triage location 21 TWO MAIN TYPES OF DISASTER RESPONSE Response without outside emergency assistance: In the event a single provider experiences a disaster and needs disaster response to support enrollee services, CenterPoint may choose to handle the situation with the provider in need without outside emergency assistance. Response at request of outside assistance: CenterPoint serves as the main contact for relaying mental health, intellectual/developmental disabilities and substance abuse crisis needs. As such, county emergency management, the American Red Cross, and state and federal governmental departments may request CenterPoint response. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Response without outside emergency assistance Steps: 1. 2. 3. 4. Upon receiving request, Disaster Response Coordinator shall contact CEO/Area Director Determine what services need to be offered and where they need to be offered Contact Crisis Providers to request possible assistance Communicate the message to Essential Functions department employees to prepare to support in any needed capacity if appropriate 5. Secure all physical and tangible materials that need to be transported 6. Transport needed Function 7. Communicate the message to all employees, and other stakeholders if appropriate Response at request of outside assistance Steps: 1. Upon receiving request, Disaster Response Coordinator shall contact CEO/Area Director 2. Determine what services need to be offered, where they need to be offered and what number of people have been affected 3. Determine if request is feasible and can be supported by Crisis Response Providers 4. Contact Crisis Providers to request possible assistance via email and phone calls if needed 22 5. After messages are relayed to Crisis Response Providers and Disaster Response Team Members, the Disaster Response Coordinator will contact the requesting agency to inform them of measures taken 6. Communicate the message to all employees, and other stakeholders if appropriate IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 23 Pharmaceuticals RESPONSE LEAD: Burch Johnson, Chief Operations Officer Office: 336-714-9138 Cell: 336-403-5344 SUCCESSOR: Rose Lyles, Pharmacy Project Coordinator Office: 336-714-9196 Cell: 336-692-6426 OVERVIEW: CenterPoint operates two Patient Assistance programs that offer free pharmaceuticals to indigent enrollees. The program is housed at 4045 University Parkway and functions in conjunction with the Forsyth County pharmacy. The other site is located in Wentworth and is in the same building as CenterPoint’s “safety net” provider in Rockingham County. There is no pharmacy at this site but a dispensary is maintained for the medications received through the patient assistance programs of pharmaceutical companies as well as sample medications. In the event a disaster affects either location (as referenced above) or Patient Assistance Program operations are impacted, it may be necessary to identify an alternate location where staff can work to continue to conduct all Patient Assistant Program duties. Relocating the Patient Assistance Program – Forsyth County staff can relocate to CenterPoint's main office location at 4045 University Parkway and meet with clients there. This location allows staff access to phones, computers, and Internet and client databases without any interruptions. The clients can use the local bus transportation to get to the location. In Rockingham County, the program would relocate to the site where the provider agency relocates or to an office in the Rockingham County Government Center which is adjacent to the current location. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Steps: 1. 2. 3. 4. Determine if Patient Assistance Programs need to be relocated. If programs need to be relocated, location needs to be determined. Communicate the message to Disaster Response Team members. Communicate the message to Essential Functions department employees to prepare to support in any needed capacity as appropriate. 24 5. Communicate the message to all employees, and other stakeholders. 6. Secure all physical and tangible materials that need to be transported. 7. Transport Essential Function. IN ALL CASES, protect healthcare information during any disaster event; steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 25 Utilization Management RESPONSE LEAD: Burch Johnson, Chief Operations Officer Office: 336-714-9138 Cell: 336-403-5344 SUCCESSOR: Leigh Ann Warren, Utilization Management Director Office: 336-714-9143 Cell: 336-608-9072 OVERVIEW: The Utilization Management Recovery Plan outlines how CenterPoint would continue to operate all utilization management functions in the event of a temporary or long-term emergency or disaster. The plan applies to the CenterPoint Utilization Management (UM) Department, its employees and the infrastructure that supports it. Conditions for Activating the Plan The building at 4045 University Parkway was incapacitated and UM staff needed to relocate. There was a major internal phone and/or internet failure and could not recover in a reasonable amount of time. In general, any of CenterPoint’s three locations can serve as a Command Center if the other is damaged or destroyed by a disaster. These locations are 4045 University Parkway, 4035 University Parkway and 4025 University Parkway in Winston-Salem. If all physical locations are destroyed by a disaster, then a designated location to be determined will serve as a Command Center. In the event that a disaster happens during normal business hours when physical locations are open, Emergency Operations procedures will be followed to evacuate the disaster area and relocation of essential functions will be determined immediately. In the event that a disaster strikes a Physical Location after normal business hours, it is the responsibility of the CEO/Area Director, who serves as the Lead Emergency Response Team member, to travel to disaster location to determine relocation needs and begin the Order of Restoration Plan. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible Steps: 1. If needed, visit disaster site. 2. Determine need to relocate. 26 3. 4. 5. 6. 7. Communicate the message of relocation to Disaster Response Team members. Communicate the message to UM department employees to prepare them for relocation. Communicate the message of relocation to all employees and other stakeholders. Secure all physical and tangible materials that need to be transported. Transport UM department employees if needed. RELOCATING THE UM DEPARTMENT In the event that a disaster disables the use of the Utilization Management Department at 4045 University Parkway, it is necessary to identify an alternate location where staff can work to continue to conduct all utilization management functions. Both Alpha MCS (MIS system) and In-Contact (telephone system) are web based and can be securely accessed via any internet connection. In case of disaster, two staff members currently work from home and can continue their work from those sites. Other staff can relocate to any other operable CenterPoint location. This will allow staff access to phones, computers and the Internet. If not all alternate, locations are available, UM staff would access Alpha MCS and In-Contact from CenterPoint approved equipment to conduct utilization management functions. In addition, CPHS cell phones, laptops and MIFI cards are available for backup phone access and internet access as needed. In the unlikely event that Internet access is unavailable, UM would utilize a cell phone and paper process to maintain functions. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 27 Transportation RESPONSE LEAD: Dave Burchette, Facilities Manager Office: 336-714-9189 Cell: 336-462-6295 SUCCESSOR: Bruce Smith, Maintenance Mechanic Office: 336-778-3668 Cell: 336-462-6227 OVERVIEW: The Transportation Disaster Recovery Plan details the use of fleet vehicles to support CenterPoint operations during emergencies. Additionally, the plan describes how transportation assets are sourced to support the transportation needs of enrollees from the special needs population during an emergency that requires evacuation. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Employee Transportation Depending on the scale and nature of the emergency, fleet vehicles may be directly assigned to a particular program rather than the current reservation system. Assignment will be on a priority basis to be determined by Leadership to assure the greatest needs are served. Fleet vehicles may be used to transport staff, records and/or equipment to relocate essential operations and to support field operations in the community. In the event of inclement weather, personnel assigned fleet vehicles with 4-wheel drive may be tasked to assist in transporting mission-essential staff to and from work. Steps: 1. 2. 3. 4. 5. Inventory fleet vehicles for necessary safety equipment and restock as required. Gas up fleet vehicles. Directly assign fleet vehicles to programs as directed. Issue gas cards as required. Transport Essential Function. 28 Enrollee/Mass Transportation In the event of a declared emergency evacuation order, Forsyth, Stokes, Davie and Rockingham Counties have procedures in their respective Emergency Operations Plans to facilitate the evacuation of special needs populations using such means as Transit Authority vehicles and school buses. Identified transportation needs should be forwarded to the appropriate county’s Emergency Operations Center for coordination. The contact numbers for the respective counties’ Emergency Operations Centers can be found in the Important Contacts section of this plan. Additional transportation efforts may be coordinated with the following: American Red Cross (NW Chapter): 336-245-5151 Community Organizations Active in Disaster (COAD): 336-245-5151 Salvation Army: 336-722-8721 Rockingham County: 336-349-3434 Winston-Salem Transit Authority 100 W 5th Street Winston-Salem, NC 27101 Phone: 336-727-2000 Piedmont Area Regional Transportation Located off Regional Road south of the I-40/ PTIA Airport exit Phone: 336-883-7278 / After Hours: 336-813-2287 IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 29 Accounts Payable/Billing & Claims RESPONSE LEAD: Cathy Wilson, Deputy Chief Financial Officer/Acting Chief Financial Officer Office: 336-714-9160 Cell: 336-462-6296 SUCCESSOR: Kathy Tuttle, Director Office: 336-714-9336 Cell: 336-829-1585 OVERVIEW: The critical Functions that need to continue in the event of a disaster that prevents access to Alpha MCS and the internet at CenterPoint’s 4045 University Location, for more than 3 days (72 hours) are: AlphaMCS for Claims and Eligibility processing Great Plains to process claims payment and pay vendors. NCTracks for claims and eligibility Emdeon for TPL verifications. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Steps: 1. Chief Financial Officer will contact the designated disaster recovery billing staff to authorize disaster response. 2. The Billing staff will have internet capability, which will allow access to the network backup servers and web based applications at designated off-site location to process critical functions. 3. The offsite computer will have installed a file transfer program with authorized mailboxes for NCTracks, which will allow CenterPoint to submit 837 billings and 834 eligibility files. All procedures for critical functions are secured on the J drive of the network server and a backup hardcopy will be stored off-site. 4. All user passwords necessary for the critical functions will be stored off-site. 5. The Billing Department will be able to access the internet to handle process claims and eligibility critical functions. The most frequently visited websites are: https://login.alphamcs.com/alphamcs/AlphaMCS.aspx https://www.nctracks.nc.gov/content/public?version=portal-jwap-trunk-1006515243-production&why=Root https://office.com.emdeon.com/secure/scripts/inq.dll? 30 6. The disaster response staff will assure that all critical processes are continued at the offsite location until CenterPoint’s business is restored. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 31 CenterPoint Employee Payroll RESPONSE LEAD: Cathy Wilson, Deputy Chief Financial Officer/Acting Chief Financial Officer Office: 336-714-9160 Cell: 336-462-6296 SUCCESSOR: Accounting Manager Office: 336-714-9333 Cell: 336-714-9332 OVERVIEW: In the event that a disaster disables the use of CenterPoint’s 4045 University Location, it is necessary to provide access to Great Plains from off-site to appropriate payroll staff. Access to Great Plains is critical to processing a new payroll adhering to the bi-weekly schedule. The disaster may call for repeating the prior payroll until documentation can be received to update leave and deduction records. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Steps: 1. Chief Financial Officer will contact the appropriate payroll staff to authorize disaster response. 2. If necessary, emergency transportation will be used to transport payroll staff. 3. Payroll staff will be required to import new data from Greenshades to process payroll through Great Plains. 4. The new data will be uploaded to Wells Fargo using the online connection for direct deposit, as usual. This can be done from any PC. 5. If new data is not available, the previous payroll will be used. 6. Using a previous payroll will require changing the dates through Note Pad and resaving the document with a current date or the Wells Fargo connection will reject the file. 7. If prior data is used, a manual update will be required to remove any former employees paid out on last payroll. 8. Upon resolution of the disaster, the appropriate payroll staff will need to reconcile the amount paid to employees with their timesheets to assure accurate W2 information. 9. Direct deposit detail will be furnished to employees as soon as possible after disaster recovery is complete. 10. Employees will be required to notify Payroll promptly if there are adjustments that need to be made. 32 11. Adjustments to employee compensation will need to be made on the next payroll based on submitted timesheets or Status Reports from HR. 12. No manual checks will be issued for amounts under $100.00. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 33 Emergency Cash RESPONSE LEAD: Cathy Wilson, Deputy Chief Financial Officer/Acting Chief Financial Officer Office: 336-714-9160 Cell: 336-462-6296 SUCCESSOR: Chad Swicegood, Accountant II – Cash Management Office: 336-714-9326 Cell: 336-239-0390 OVERVIEW: In the event that a disaster disables the use of CenterPoint’s 4045 University Location, it is necessary that authorized staff have internet or phone service in order to process transactions to cover agency cash obligations. Only designated staff is privy to account number and password knowledge. As a precaution, CenterPoint banking account numbers and passwords are not printed in this plan, as only designated staff is allowed to access banking information. Order of Restoration Plan An Order of Restoration Plan can only be enacted under the direction and approval of the CEO/Area Director. In the event that action is necessary and the CEO/Area Director is unable to provide the necessary approval, the identified lead of each essential function is responsible. Steps: 1. Chief Financial Officer will contact cash management staff to authorize response. 2. Cash management staff will coordinate with payroll staff and payables staff in order to make sure money is available to cover obligations. 3. Except for severe disruptions to electricity and/or telecommunications, authorized staff will use Internet from remote location in order to transfer money, make emergency ACH payments, etc. 4. In cases of severe disruptions to electricity within the area, authorized staff will use a cell or land line telephone that requires no power in order to initiate transfers, etc. 5. In the worst-case scenario, if catastrophic damage occurs to telecommunications infrastructure within the area, authorized staff will seek closest opened branch, etc. 6. Cash management staff will keep records of all transactions and record when Great Plains is available. IN ALL CASES, protect healthcare information. During any disaster event, steps must be taken to secure and protect enrollees’ information in compliance with all HIPAA laws. Maintaining security of protected health information (PHI) during an on-location disaster can be 34 challenging if computers and other filing objects are disturbed or destroyed. However, securing the area where the protected information is located is possible. If a disaster event takes place requiring that PHI be transported to a triage or crisis provider location, anyone transporting the information should abide by all HIPAA laws related to PHI transport, exceptions being the American Red Cross (ARC) they are not bound by HIPAA Laws. 35 All Hazards Response Plan Appendices Appendix 1 Disaster Information (What outside agencies utilize) Appendix 2 LME Procedure on Succession Planning Appendix 3 FEMA Budget Guidelines Appendix 4 Disaster Response Volunteer Assurance of Confidentiality Agreement pg. 37 pg. 38 pg. 41 pg. 50 36 Appendix 1 Disaster Information Public Mental Health, Developmental Disabilities & Substance Abuse Services in Disaster Response (Forsyth, Stokes, Davie & Rockingham Counties) FOLLOW THESE STEPS: Call CenterPoint Disaster Response Coordinator Leona Williams at 336-403-4434 to relay disaster response information. It will then be determined how to offer support through CenterPoint's Customer Services line and/or Mobile Crisis and Crisis Provider Services. Notify all disaster response personnel to refer persons in need to CenterPoint's Customer Services number: 1-888-581-9988. When calling the toll-free number, a professional will evaluate the urgency of need and offer an appointment in accordance with the following schedule: Routine (care needed within 14 days), Urgent (care needed within 48 hours) or Emergent (care needed within two hours). If Customer Services personnel determine a mobile crisis response unit is needed to support onsite efforts, a team will be dispatched to the disaster location. Customer Services personnel can also determine if the person in need is already in the public service system and has a clinical home service provider who serves as a "First Responder." NOTE: Crisis Provider Services may be utilized in certain circumstances to provide crisis response on site and to offer ongoing services. CenterPoint's Disaster Response Coordinator will communicate needs to these providers for response. 37 Appendix 2 Procedure on Succession Planning 38 Position (Current Credential) CEO (JD) Chief Administrative Officer (LCSW) Skills Required Understanding financial, operational, political, state and federal funding, strategic planning, governance support, marketing and development, information systems, policies & directives G.S. §122-C-121 (minimum), extensive supervisory experience Community operations, provider network, resource development, consumer affairs, complaints, appeals, strategic planning, human rights, data analysis/reporting, needs assessment, Human Resources Masters Human Services or related field, extensive supervisory experience Chief Finance Officer/Contracts (CPA) Chief Clinical Officer/Medical Director (Board certified psychiatrist & Board of Addiction Medicine) Financial operations including software, office operations, business functions, funder regulations, compliance, contracts and facilities C.P.A., extensive supervisory experience Clinical oversight for all operations Board Certified, extensive supervisory experience Interim Plan Chief Administrative Officer Network Management Director & Community Operations Director Deputy Chief Financial Officer Chief Operations Officer & Chief Operations Administrative and clinical leadership for consumer care in the areas of customer services, care coordination, utilization management, Officer (LPC NCC) pharmaceuticals, laboratory services, quality management and accreditation Psychiatrist (contracted) for consultation Utilization Management Director & Master’s degree with coursework in human services or related field, licensure, and considerable experience in provision of clinical services to consumers in the adult, adolescent and child MH/DD/SA disability areas Care Coordination Director 39 Chief Information Officer (RN, MBA) Vision and leadership for developing and implementing information technology initiatives in support of business operations in order to improve cost effectiveness, service quality and business development Prefer Master degree and at least 3 years’ experience in service field or Bachelor’s degree, preferably in a technology with experience in health services field and a minimum of five years successful executive/ level experience in a technical arena for an organization of similar size and scope The Succession Plan is reviewed each May and revised as needed. Business Process Manager & Business Operations Manager 40 Appendix 3 FEMA Budget Guidelines Allowable and non-allowable costs for CCP grant funds: (Excerpt from Fiscal Guidelines for the Crisis Counseling Assistance and Training Program, Substance Abuse and Mental Health Administration, Center for Mental Health Services, January 2001). The following categories will detail appropriate, allowable and reasonable costs, as well as describe inappropriate and typical in-kind contributions. DHHS/FEMA is not required to approve all allowable costs and has the discretion to elect not to fund any allowable cost items if it is determined they are not appropriate, reasonable or beyond State resources. (See Summary Table outlining fundable and non-fundable expenses). Personnel/salary and wages: salary and wages are based on current levels paid by State and local providers for similar skill levels. The number of personnel or full time equivalents (FTEs), percentage of time dedicated to the project and hourly or monthly rate for each staff category (e.g., Program Coordinator, Team Leader, Crisis Counselor/Outreach Worker, Administrative Assistant) should be detailed. Salary, wages and fringe benefits are generally the largest portion of the budget. Appropriate expenses: include crisis counselors/outreach workers to provide direct services to disaster-impacted residents; managers or supervisors of crisis counseling staff at State and local levels; and administrative and fiscal support staff. Staffing should be proportional to the size of the disaster and be internally consistent when there are multiple local providers. Inappropriate expenses: include mental health professionals providing long-term, more formal mental health or substance abuse treatment services such as diagnostic testing and therapy; and reimbursement for uncollected revenue. For example, if mental health workers respond to a disaster resulting in fewer Medicaid billings, the State should not expect to be reimbursed for lost Medicaid billings from crisis counseling funds. Costs to support mutual aid and overtime rates will be reviewed on a case-by-case basis. In-kind contributions: include salary and wages of existing State and local staff such as the State disaster mental health coordinator and local area provider agency managers who dedicate a percentage of time to the crisis-counseling program in addition to their existing duties. Fringe benefits: Established State and local personnel policies and fringe benefits rates should be followed. Temporary and part-time employees may or may not be eligible for all or some fringe benefits. Appropriate expenses: include the existing fringe benefit policies, which are the usual and customary costs for personnel at the State and local level. 41 Inappropriate expenses: include costs beyond the usual and customary for personnel at the State or local level. Consultants: Consultants are used to provide technical assistance and consultation to State and local project staff on program development and/or management of a project. CMHS Project Officers will identify experienced disaster mental health personnel from other experienced State and local departments of mental health that have implemented Crisis Counseling Projects for previous disasters. Appropriate expenses: include reimbursement for travel and regular salary expenses incurred by the State or local representative. For contracted consultants, the maximum reimbursement rate is $750 per day, which includes preparation time, travel time and materials. Reimbursable travel expenses include airfare, hotel and per diem. In-kind contributions: include costs and time associated with the use of State and local inhouse consultants. Travel/transportation: program staff is expected to provide outreach services to communities affected by a disaster and may use personal vehicles. Appropriate expenses: include mileage based on State or local standard rates for staff to conduct outreach to survivors' homes, to meet with community groups or agency personnel, or to conduct or receive training. When personnel must travel beyond their home area, expenses for transportation, lodging, and meals may be appropriate. Costs for program sanctioned training events beyond the home area would be typical examples. Usual and customary State and local travel policy should be followed. Inappropriate expenses: include travel/transportation costs for disaster survivors and out-ofstate travel for staff. The use of State or local agency vehicles is encouraged and the standard motor-pool cost may be covered or considered an in-kind contribution. Rental or leasing of vehicles is permitted only in unusual circumstances where it can be demonstrated that the use of personal vehicles is not a reasonable option. Unusual circumstances include those in which the disaster occurred throughout a very large geographic area or in remote areas. Training: the March 19, 1995 FEMA training policy memorandum must be followed. Appropriate expenses: include those described in the FEMA training policy memorandum and training materials. Inappropriate expenses: include those that do not comply with the training policy memorandum. Also included: food and beverages, preparedness training, attending conferences or workshops not directly related to the project, out-of-State training and other training primarily designed to prepare staff for future disasters. Training for Critical Incident Stress Debriefing (CISD), an intervention offered to emergency responders soon after a traumatic incident, is considered preparedness training and is an inappropriate expenditure for this program. 42 In-kind contributions: include costs and time associated with the use of State and local inhouse trainers. CMHS has training resources available to assist State and local providers. Evaluation: program evaluation is optional for States. CMHS is currently developing guidelines on program evaluation for States. Costs related to the data collection/evaluation component include collecting, collating and reporting data for required project reports. These costs can include on-going data collection, surveys, outcome assessment, etc. Research is prohibited under the CCP. Supplies: supplies may include any item with a per item cost of less than $5,000. General supplies should be described but do not need to be itemized. Computers, cell phones and pagers must be itemized and include number needed and cost per unit. Appropriate expenses: include copy and fax paper, printer cartridges, basic office supplies, copy or reproduction costs for outreach materials, cellular phones and pagers. Cellular phones and pagers can help to assure the safety of staff traveling to remote or dangerous areas. Computers and fax and copier machines may be appropriate, but verification should be made that the equipment is not available through in-kind contributions, State or local inventories or through donations. If a State has had a previous crisis counseling grant program in which items of equipment were purchased, that equipment should be used. Requests for computers require a strong justification related to the need, number, cost and type (i.e. laptops or desktops). Inappropriate expenses: include food and beverages, medications, stuffed animals, toys, disaster kits, materials or playground items for recreational programs, video cameras, video recording equipment, and other types of video production equipment and materials. In-kind contributions: typically include furniture, computers, and fax and copier machines. Rental office space: office space may be funded if it is demonstrated in-kind or donated space is not available. Outreach to disaster survivors is a major goal of the program and staff is expected to spend minimal time in an office setting. Appropriate expenses: include a minimal amount of office space for the management and administration functions of the program when donated space is not available. Inappropriate expenses: include facility renovation, repair or construction. Telephone and utilities: these costs should be estimated. Medial/public information: the development and dissemination of brochures, flyers, posters and information about the program is encouraged. In addition, CMHS has videotapes and publications on a variety of topics to assist State and local crisis counseling programs. 43 Appropriate expenses: include advertisements to recruit staff, publicize services available to disaster survivors, or educate the public concerning typical reactions to the disaster; pamphlets, flyers, newspapers, publications, booths exhibits/displays and duplication of CMHS/FEMA disaster mental health videotapes and materials, if the State requires more copies than CMHS can provide. Television and radio broadcasts are appropriate but attempts should be made to obtain donated space and airtime for print ads and broadcasts. Funds for video development may be included if the following three criteria are met: There is no similar resource. No comparable resource is available from another crisis counseling program, any Federal agency, State agency, or the commercial market. The State has provided a comprehensive description of the objectives, format of the videotape, and has demonstrated the disaster mental health knowledge and experience necessary to develop a quality product. The video tape can be completed early enough in the program period to allow it to be used as an educational and training tool during the nine-month grant. Preparedness activities will not be funded. Inappropriate expenses include expensive print ads or broadcast and video development costs that fail to meet the above criteria. Postage: Postage for mailings may be funded. Indirect costs: As a supplemental program, FEMA does not fund a line item category for indirect costs. All charges must be direct. Indirect costs (blanket percentage charges) and administrative overhead costs to manage and monitor the program are not allowed. Costs that are typically included in indirect cost rates may be submitted for consideration as direct costs. Miscellaneous/other: Funds may not be requested as "miscellaneous." All costs must be itemized. Summary Table on Fundable and Non-Fundable Expenses Budget category Appropriate expenses Non-fundable expenses Personnel List total personnel costs and also break this figure into number of FTEs, number of hours and hourly rate for each staff category (i.e., Team Leader, outreach worker) Crisis counselors/outreach workers to provide services directly to disaster- impacted residents; managers or supervisors of crisis counseling staff at state and local levels, secretarial and administrative support staff, program and fiscal monitoring staff, etc. Staffing should be proportional to the size of the disaster, i.e. appropriate administrative vs. service delivery ratio. 1. Mental health professionals providing longer-term, more formal mental health services such as diagnosis and therapy. Longer-term, more formal mental health services to existing or new clients, substance abuse treatment and advocacy are not supported in the crisis counseling programs. Critical Incident Stress 44 Debriefing (CISD) services are not appropriate more than 48 hours following an incident. In the past, CISD services have been funded for human-caused Immediate Services programs as in the Oklahoma Bombing. 2. Reimbursement for uncollected revenue. For example, if mental health workers respond to the disaster, resulting in fewer Medicaid billings, the State will not be reimbursed for the lost Medicaid billings. Fringe Benefits Apply the existing state and local fringe benefit costs, which are the usual and customary costs for personnel. Fringe benefit costs above the usual and customary for the state and local level personnel. Travel It is allowable to charge mileage for crisis counselors to travel to deliver services in survivors’ homes, to meet with community groups or agency personnel and/or to conduct or receive training. Often state cars are used and the standard motor-pool cost is covered by the grant or the agency may use the motor pool as an in-kind contribution. If a motor pool is not available, leasing of vehicles may be funded. Out of state travel of any kind is not allowed. The only exception is to bring a trainer/consultant to the disaster-impacted state for training or consultation. Leasing of vehicles will be carefully scrutinized. Providing transportation for survivors is not allowable. Program Consultants Consultants are used to provide technical assistance and consultation to State and local project staff on program development and/or management of a project. CMHS Project Officers will 45 identify experienced disaster mental health personnel from experienced State and local departments of mental health that have implemented Crisis Counseling programs for other disasters. FEMA will reimburse regular salary and travel expenses incurred by the State or local representative. For contracted consultants, the maximum reimbursement rate is $750 per day, which includes preparation time, material and travel time. Travel costs for consultants are also reimbursable. Training If FEMA has funded an ISP in the State within the past three years, then qualified trainers may be available within the State. Otherwise, FEMA/CMHS prefer for grantees to use experienced disaster mental health personnel from experienced States. The intent is for the declared State to develop their own resources with assistance from experienced State representatives. CMHS will suggest experienced State personnel to serve as trainers. If the State does not have in-State disaster mental health trainers and after consultation with CMHS cannot identify or access resources from other States, then FEMA will consider funding a contractor. FEMA will reimburse a grantee for airfare, mileage, hotel and per diem to bring a trainer to the State. In addition, the maximum amount that FEMA will reimburse for a trainer is $750 per day, which includes preparation, materials, travel time and all other expenses. For example, if the State has two-day training then the consultant will receive $750 per day for the two-day training in addition to airfare, mileage hotel and per diem. If the consultant charges more 46 than the $750 per day, then the State must pay any costs that exceed that amount. States are advised not to misrepresent consultant costs so that Federal funds are used to cover fees in excess of $750/day. Such misrepresentation constitutes fraud. CISD training will not be funded. Disaster preparedness training will not be funded. Evaluation Process evaluation is encouraged. Research will NOT be funded. Office Supplies Copier and fax paper, printer cartridges and basic office supplies are appropriate expenses. General supplies must be described but do not need to be itemized. Requests for furniture, computers, cellular phones, pagers, fax machines or photocopiers must be itemized and include a written justification. If the disaster is of a magnitude and duration that a Regular Services Grant seems likely, investigate whether it is more cost effective to lease or buy supplies such as office furniture, computers, mobile phones, pagers, fax machines, and photocopiers. Determine what items may be offered by the agency for use in-kind and whether some items may be available from State warehouses or donated by a corporation Food and beverages, medications, toys, stuffed animals, disaster kits, materials or playground items for recreational programs. Video cameras, video recording equipment, televisions and other types of video production/equipment materials are not allowable. However, duplication of CMHS/FEMA disaster mental health training videotapes is allowed. In addition, video production may be permitted. See Media Costs/Public Information. 47 with local interests. Telephone and Utilities Justification should include estimated costs. Rental Office Space Office space may be funded if demonstrated that in-kind resources or donated space is not available. Outreach to disaster survivors is a major goal of the program and staff is expected to spend a small portion of their time in an office setting. Facility renovation, repair, or construction. Media Costs/Public Information Programs may need to advertise to recruit crisis counselors, publicize services available to disaster survivors/survivors or educate the public about how to deal with typical reactions to the disaster through pamphlets, flyers and handouts. States should work with the FEMA and SEMA Public Information offices to coordinate announcements and public information materials as appropriate. CMHS/FEMA has existing videotapes and publications on a variety of topics to assist local crisis counseling programs. These are available free of charge from CMHS Clearinghouse 1-800789-2647. For print ads and broadcast time, FEMA advises that programs seek donations as a public service for space and airtime announcements. If this is not possible, list these media costs as a budget item and provide ample justification in the narrative. Duplication of CMHS/FEMA disaster mental health training videotapes may be allowed. States can obtain from the CMHS Project Officer training tapes dealing with special populations. If the State requires more copies than CMHS can immediately provide, then the State may recoup the cost of duplicating the additional quantity of tapes required. Video development may be funded if the following three criteria are met: 1. There is no similar resource. No comparable tape is available from another crisis counseling program, any Federal agency, State agency or the commercial market. 2. The State has provided a comprehensive description of the objectives and format of the videotape and has demonstrated the 48 disaster mental health knowledge, experience and access to develop a quality product. 3. The videotape can be completed early enough within the funding program period to be used as an educational and training tool during the nine-month grant. Preparedness activities will not be funded. Indirect Costs Indirect cost is commonly an inkind contribution to the program. As a supplemental program, FEMA does not fund a line item category for indirect costs. All charges must be direct. Indirect and administrative costs to manage and monitor the program are not allowed. Other Costs may be identified that are unique to the disaster and area affected but first assures that these costs do not fall into one of the other categories. If not, provide detailed information to justify the needs for these items/services. Funds may not be requested as "miscellaneous." All costs must be itemized. Facility renovation, repair or construction; client transportation, child care, therapy, diagnostic testing, food and beverage, video tape and recording equipment, longer term, more formal mental health services to existing or new clients, medications, substance abuse treatment, and advocacy, financial assistance for disaster survivors and disaster preparedness are not fundable. 49 Appendix 4 Disaster Response Volunteer Assurance of Confidentiality Agreement Contact with Individually Identifiable Health Information (IIHI) of individuals is likely in any association with CenterPoint Human Services (CenterPoint). As such, State & Federal Confidentiality Laws and HIPAA Privacy and Security Directives necessitate that any individual, which includes employees (full time, part time or temporary), designated representatives, committee members, volunteers, auditors, consultants, etc. must read and indicate by signature their agreement to comply with this Overview of State, Federal, CenterPoint Confidentiality and HIPAA Directives. The intended purpose of this overview is to insure both the legal and ethical protection and privacy of clients and client IIHI by all CenterPoint employees (full time, part time or temporary), designated representatives, committee members, volunteers, auditors, consultants, etc. 1. State Confidentiality Rules for Mental Health/Developmental Disabilities and Substance Abuse Services (APSM 45-1), CenterPoint Confidentiality Policies & Procedures and HIPAA Privacy & Security Directives are lengthy. This legally binding document provides a general overview of the material listed. All person(s) who are permitted access to clients or client’s IIHI in any form are responsible for protecting both legally and ethically the privacy and security of client IIHI. Access includes but is not limited to reviewing hardcopy and/or electronic client IIHI. Please read this general overview attentively. The contents of this overview and all supporting State Confidentiality Rules for Mental Health/Developmental Disabilities and Substance Abuse Services (APSM 45-1), CenterPoint Confidentiality Policies & Procedures and HIPAA Privacy & Security Directives applies to any information regarding the health, mental health, or substance abuse problems of CenterPoint consumers that may be communicated to Correctional Institution. Note: Violations of any of these rules and directives could result in legal proceedings up to and including misdemeanor charges punishable by a fine of $100 to $50,000 or more per violation, up to $1.5 million. 2. “Individually Identifiable Health Information” or “IIHI” (sometimes also referred to as “Protected Health Information” or “PHI”) includes all information pertaining to a client, in verbal, electronic, or hardcopy form. CenterPoint employees, designated representatives, contractors, parties to Memorandums of Agreement, volunteers, auditors, consultants, etc. are responsible for protecting both legally and ethically, the privacy and security of client IIHI. IIHI is not limited to, client service hardcopy records, verbal information, electronic IIHI, faxes, emails, internet information etc. No CenterPoint employees, designated representatives, volunteers, auditors, consultants, etc. shall transmit any IIHI through unsecured external email or the internet. 50 IIHI under HIPAA includes any individually identifiable health information. Identifiable refers not only to data that is explicitly linked to a particular individual (identified information, it also includes health information with data items which reasonably could be expected to allow individual identification. Individually identifiable health information is information that is a subset of health information, including demographic information collected from an individual, and: (1) Is created or received by a health care provider, health plan, employer, or health care clearinghouse; and (2) Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual; and (i) That identifies the individual; or (ii) With respect to which there is a reasonable basis to believe the information can be used to identify the individual. 3. No CenterPoint employee, designated representatives, volunteers, auditors, consultants etc., shall access client IIHI in any form unless there is a specific legally justifiable need to know in order to carry out Treatment, Payment or Health Care Operations (TPO). No CenterPoint employee (full time, part time or temporary), designated representatives, volunteers, auditors, consultants etc. shall disclose any client IIHI without appropriate and legal authorization(s) in accordance with (CenterPoint Confidentiality Policies and Procedures), (General Statutes 122 C – 52 through 57), (APSM 45-1), (42 CFR and 34CFR, part 300). Note: For licensed clinicians, it is a violation of licensure requirements and/or ethical responsibilities to access and/or disclose IIHI for any client that is a family member, friend, or acquaintance of the clinician. The Clinical staff should contact their supervisor immediately to handle the case. All other CenterPoint Human Services employees (full time, part time, or temporary). All CenterPoint employees (full time, part time or temporary), designated representatives, volunteers, auditors, consultants etc., regardless of position or purpose are bound both legally and ethically, to protect the privacy and security of IIHI. 4. IIHI shall not be released or disclosed in any form by anyone other than the person(s) designated by CenterPoint as “Designated Staff”” or “Responsible Professional”. The designated release staff should process all IIHI requests and disclosures in order to ensure IIHI disclosure is done in accordance with all State & Federal Confidentiality General Statutes, (referenced in paragraph 3), HIPAA Privacy and Security Directives, and CenterPoint Confidentiality Policies and Procedures. Note: Verbal or written acknowledgement of the fact that a person is a client without appropriate authorization is considered an inappropriate disclosure. 51 5. The “Designated Staff” or “Responsible Professional” responsible for processing receipt of IIHI from CenterPoint must take all necessary steps to ensure that all requests, consents, court orders, subpoenas or authorizations are valid and complete before any disclosure of client IIHI is made. 6. Employees governed by the State Personnel Act (N.C.G.S. Chapter 126) must adhere to all State Confidentiality Rules for Mental Health/Developmental Disabilities and Substance Abuse Services (APSM 45-1), CenterPoint Confidentiality Policies & Procedures and HIPAA Privacy & Security Directives. Failure to comply may result in disciplinary action up to suspension and/or dismissal and/or a fine of $100 to $50,000 or more per violation, up to $1.5 million. 7. Client IIHI records, hardcopy or electronic are the property of CenterPoint. All employees (full time, part time or temporary), designated representatives, volunteers, auditors, consultants etc. shall, both ethically and legally, protect the privacy and security of client IIHI from improper access and/or illegal dissemination. Original client IIHI records may be removed from CenterPoint only by a valid and complete Court Order or Subpoena to produce the client record. Such removal must be authorized by the CEO or their designated employee. 8. All CenterPoint employees (full time, part time or temporary), designated representatives, volunteers, auditors, consultants, etc., granted IIHI access shall indicate their understanding and agreement to comply with all Federal & State Confidentiality Rules and Directives, CenterPoint Confidentiality Policies and Procedures and all HIPAA Privacy and Security rules and guidelines by signing this Statement of Compliance and Assurance of Confidentiality. 52 The CenterPoint Human Resources Department shall maintain this document. CenterPoint Human Services Assurance of Confidentiality/ Compliance Statement I have read and clearly understand all contents of this Overview of Confidentiality and HIPAA Directives which are intended to insure both the legal and ethical protection and privacy of clients and client Individually Identifiable Health Information (IIHI). I understand that in accordance with G.S. 122C-52-(e) and CenterPoint Human Services Confidentiality Policies and Procedures any CenterPoint Human Services employees (full time, part time or temporary), designated representatives, committee members, volunteers, auditors, consultants, etc. who unethically or illegally accesses, uses and/or discloses Client IIHI may be punished by fine or imprisonment. Failure to comply with all State & Federal Confidentiality Directives, HIPAA Privacy and Security Rules and/or CenterPoint Human Services Policies and Procedures may result in disciplinary action up to suspension and/or dismissal and/or up to ten years imprisonment and up to $ 1.5 million in monetary penalties. I affirm that I will notify my supervisor immediately should I become aware that any individually identifiable health information (IIHI) for any personal family member(s) that has presented in my functional area. My signature indicates that I clearly understand both the legal and ethical liability regarding inappropriate and/or unauthorized access, use or disclosure of client IIHI and that I hereby agree to legally and ethically protect, preserve and secure the nature and privacy of all Client IIHI to which I have access. _____________________________________ ______________ Signature Date _____________________________________ Name (Print) _____________________________________ Position ______________________________________ Department Number (Rev. 06/23/15) 53