Monitoring of performance regarding actual or potential risks related to the following areas are conducted on an ongoing basis in different ways.

A) Staff knowledge and skills
The monitoring of staff knowledge and skills (e.g., EMTs, trained First Responders) is conducted through regular observation of performance by supervisors, through formal supervision meetings, through annual performance evaluations, and through at least 24 hours of training and staff development conducted each year. Training in emergency procedures is conducted quarterly, as required by DEEC regulations.

B) Level of staff participation
The monitoring of staff participation is accomplished through means described above in section A). Training in emergency procedures is conducted quarterly, as required by DEEC regulations.

C) Monitoring and inspection activities
As noted in other Environment of Care Plans, all utility systems at residential campuses are tested and/or inspected quarterly. Equipment is tested/inspected on a schedule recommended by the manufacturer. All facilities are inspected for safety and maintenance issues at least monthly.

D) Emergency and incident reporting
All incident reports, including reports related to emergency situations and physical restraints, are reviewed by supervisors, nursing staff, clinical staff, and program managers. Incidents which are not documented require follow up by supervisors, and incident reports which are not completed correctly or according to procedure, are returned for follow up by the supervisor.

Data on emergency incidents is maintained and is reviewed on a regular basis by the campus Improving Organizational Performance Committee and agency administration. Data on emergency events is reviewed on an as needed basis by the campus/program Environment of Care Committee.

E) Inspection, preventive maintenance and testing of equipment
As noted above in Section C), residential campus equipment is tested/inspected and maintained on a schedule recommended by the manufacturer.

Internal communications on campuses can be conducted in at least five ways: in-person, via the telephone intercom system, via walkie talkie, via urgent priority email, and via cell phone text messages, and one-way communications via the campus paging system. In the event that the telephone intercom and paging systems are not operational, alternative measures will be employed.

Communications between campuses and Central Administration and other parts of the “outside world” are conducted in four ways: in-person, via the regular telephone, via cell phone, and via email sent through T1 cable.

In the event that none of these electronic communication methods are operative, in-person communication will be attempted (e.g., with the fire department or police).

[Note: Program specific Evacuation and Intruder Protocol procedures are also covered in the Hillcrest Emergency Manuals.]

If, as a result of an emergency/disaster, the threat of such, or for any other reason, campus facilities cannot support adequate safety for students and staff, and/or care and treatment of students, evacuation procedures will be implemented. Evacuation procedures will only be initiated by the Executive Director, Senior Vice President, the Program Director and/or his/her designee, or by an authorized member of the agency Senior Management Team.

After being notified and confirming, and/or determining that an emergency evacuation is necessary, the Executive Director, Senior Vice President, and/or the Program Director or the administrator in charge will contact Central Administration and apprise them of the situation. The administrator in charge will make arrangements to evacuate the campus, including all students and staff, to the nearest suitable relocation site, preferably another Hillcrest site. The day program will relocate students to their residences, if that can be safely done. The Executive Director, Senior Vice President, and/or the Program Director will determine what supplies, medication and records can safely be prepared for evacuation, and when. However, the safety, well-being, and protection of the students and staff are always the first and foremost priority of all decision makers during the evacuation process.

If conditions are such that supplies, water and food, medication and records can be prepared for transport without compromising the safety of students and staff, the Executive Director, Senior Vice President, and/or the Program Director or his/her designee will notify all available department heads and supervisors of the need to evacuate the campus. He/she will provide direction to department heads as to how they and their staff will be deployed during the evacuation and relocation with regard to preparing supplies, food and water, medication and records; securing and preparing vehicles; communications; or assisting direct care staff with students.

If conditions are such that supplies, water and food, medication and records cannot safely be prepared for transport, department heads and their available staff, and supervisors will be deployed in preparing the students and staff for transport as soon as possible, initiating security procedures for the campus, and gathering telephones, cell phones and walkie talkies for emergency communication during the evacuation.

If conditions allow, the nursing staff at residential programs will prepare at least one day’s medication for all students. They will also secure for travel all lists and information related to the daily meds and medical needs of the students being evacuated.

Provided it is safe to do so, the residential supervisor on duty will bring the students’ Emergency Medical Files and, additionally, necessary supplies from the campus to the relocation site. Supplies will be selected based on current, emerging and projected conditions, and the selected relocation site. Supplies may include such things as bed linens, articles of clothing, ADL supplies.

Once the students and staff have reached the relocation site, the supervisor on duty will notify the Program Director or the manager in charge if he/she is not at the relocation site. The supervisor and/or available administrators will survey the site and make a list of supplies that are needed. Once the list of supplies has been compiled, the supervisor will call the other campuses and/or emergency management agencies to procure the needed supplies.

If there is not enough bed space at a single campus, the students will then be placed in the other campuses or relocation sites on a space available basis. The Program Director or the manager in charge will then notify the nursing department that the students are being evacuated and the nursing department shall insure that the students’ medications and medication charts, if available, are delivered to the campus(s), provided it is safe to do so. The supervisor will also bring student case records and medication files, and deliver them to the campus nurse.
If evacuated residential students cannot be housed at either a Hillcrest campus or the administrative offices, the students shall be housed at a motel or emergency shelter until suitable on campus quarters are available. If this contingency becomes necessary, the Program Director or the manager in charge and Central Administration will arrange for necessary staffing and support.

If this contingency becomes necessary, the Program Director or the manager in charge will contact motels and/or emergency shelters in the area and reserve space for the students and staff.

The Program Director or the manager in charge will keep the nursing department and Central Administration appraised of the students’ relocation sites. The nursing department will insure that the students’ medications and any necessary medical supplies, if available, are in place at the relocation site, provided it is safe to do so.

Finally, in the event that a student at any program refuses to leave a building during an actual disaster evacuation, as opposed to an evacuation drill, the student will be physically removed by staff in a manner consistent with Hillcrest’s physical intervention policy, if possible. However, since an evacuation would only be conducted if remaining inside a building or on a campus would present imminent danger of serious injury to students and staff, any student refusing to cooperate with evacuation procedures will be physically removed by staff as quickly and safely as possible.

At each campus, the residential and overnight shifts perform fire drills each quarter in the dorm buildings, and the academic shift conducts fire drills each month in all areas used as classrooms. At least 50% of all fire drills are unscheduled. All fire drills are documented on the appropriate agency forms and are reviewed by campus administrators as they are conducted and by the EOC Committee every other month.

Each Hillcrest campus conducts two evacuation drills each year separated by no less than four months and no more than eight months. All evacuation drills are documented on the appropriate agency forms and are reviewed by the Senior Vice President, Director of Quality Assurance, and the Program Director or his/her designee. All evacuation drills are critiqued through a multidisciplinary process to identify deficiencies and opportunities for improvement based upon all monitoring activities and observations during the exercises. The effectiveness of corrected deficiencies and/or of improvements made in response to critiques are evaluated during the next drill.

The overall objective for evacuation drills is to keep students and staff safe under emergency/disaster conditions. Hillcrest must balance:
• the ability to evacuate our facilities in an efficient and timely manner, with
• either having, or being able to acquire, necessary supplies, materials and equipment related to the safety and well-being of our students and staff while in a relocation site.

Hillcrest will also achieve this balance in a manner consistent with Massachusetts DEEC requirements and Joint Commission standards.

Hillcrest has no formal role or responsibility in community wide emergency response activities. However, depending on specific events and/or conditions, Hillcrest Central Administration may determine ways in which Hillcrest resources (e.g., space, vehicles, staff) may be put at the disposal of community emergency response agencies, on a completely voluntary basis.

Both on a campus specific and agency wide basis, Hillcrest strives to maintain positive, open and mutually supportive relationships with all local community emergency response agencies.

The management of space, supplies and security will be conducted by on site administrators and/or supervisors, who will make decisions based on current and emerging conditions, with the safety, well-being and protection of students and staff being the highest priority.

Arrangements have been made with vendors and suppliers to ensure that Hillcrest, as a high priority client, will be able to obtain medication and related supplies, and essential non-medical supplies during emergencies of varying severity and geographic scope.

If an event is localized, sites may be able to share or pool necessary supplies and deploy staff among sites.

Under emergency/disaster conditions program managers and/or supervisors are authorized to deploy any and all available staff as necessary. Staff on shift may be held over, as needed, and staff from other campuses and/or from Central Administration may be deployed at one or more campuses, as necessary.

Staff deployment decisions (e.g., the assistant supervisor to “sweep” evacuated buildings) will be made by supervisor and administrators at the program site based on the variety of conditions existing at the time. Program managers and/or supervisors make the safety, well-being and protection of students and staff their highest priority when making staff deployment decisions.

1) Notifying On Campus Staff
On campus, as soon as it has been determined that Emergency Response Measures will be initiated, the program manager, supervisor and/or designees will notify all staff via telephone, walkie-talkie, computer email, and/or in-person contact.

Regardless of the conditions, these communications will be conducted in a professional and calm manner so that students will not be unduly frightened or agitated.

If conditions require that Emergency Response Measures must be initiated or directed from Central Administration, a member of the Senior Management Team will telephone or have in-person contact with a campus/program manager or supervisor. Campus/program procedures will then be implemented.

2) Notifying Hillcrest Central Office Administration
Consistent with Hillcrest Policies and Procedures, the Senior Manager on call will be contacted when any of the following situations occur, among others:
a. A student or staff requiring hospitalization.
b. Serious physical plant or vehicle damage.
c. Fire and/or need to evacuate a building or the campus.

In the event of urgent and/or life threatening circumstances (as defined herein):
1) If staff can access an outside telephone line, staff are authorized to call 911 for emergency assistance from fire and rescue or emergency medical services.
2) If staff cannot access an outside telephone line, staff will notify the supervisor or available administrator of the need for community emergency assistance.

If the circumstances or conditions are potentially dangerous, but are not urgent and/or immediately life threatening, staff will notify the supervisor.

If the situation might require police intervention rather than fire and rescue or medical services, staff will notify the supervisor.

The supervisor is authorized to determine further action, such as immediately notifying external authorities (e.g., calling 911, fire or police) or notifying a program manager.”

“Urgent and/or life threatening circumstances” – Definition:
• A situation that poses an immediate and unexpected risk to health, life or property, and that requires urgent intervention from community services (e.g., fire and rescue) to prevent further injury, death or serious damage.
• A condition of urgent and immediate need for action and/or assistance by community services.
• An apparent and presenting (not potential) condition that presents a very serious, clear, present injury, damage or danger to persons or property, and that cannot be managed by HEC personnel, Supervisors or Managers..
• A state of crisis that is present and unfolding in the present (rather than potentially or possible), and that presents an unmanageable threat to lives or serious and major damage to property.

Examples of Urgent and /or Life Threatening Circumstances:
• A person has lost consciousness, or cannot breathe, or is losing copious amounts of blood.
• A fire in a building.
• Serious, major storm damage to a building to the extent that lives or well-being are threatened.

Examples of what does NOT constitute Urgent and /or Life Threatening Circumstances:
In these types of situations, the Supervisor should be notified, not community intervention services.
• A student is verbally or even physically threatening, destroying property or is running away.
• A student or staff has physical symptoms that should be checked by a nurse but are not serious or life threatening.
• A situation that might eventually require police intervention.

In the event that advanced warning of potential emergency conditions are available (e.g., predictions of severe inclement weather), all Hillcrest sites will make advanced preparations to ensure safe and relatively comfortable operations. Advanced preparations will differ depending on the nature and severity of the predicted conditions, cautions and warnings. Safety measures and precautions will have the highest priority

Advanced preparations at all sites (as appropriate) may include but not be limited to:
• Monitor weather communications.
• Securing the campus grounds, property and buildings in anticipation of severe weather (e.g., high winds, ice).
• Testing generators and generator gas supply (when applicable).
• Checking emergency food and water supplies.
• Filling vans and snow removal vehicles with gas.
• Recharging communications devices (e.g., walkie-talkies, cell phones).
• Check battery supplies for flashlights.
• Prepare students and staff.

Advanced preparations at non-residential may also include canceling appointments and/or suspending services.