The torrent of executive orders, policy announcements, and lawsuits during the first weeks of the Trump administration have created substantial uncertainty for community health centers (CHCs) and other non-profit organizations as they worry about their funding, their patients, their staff members and their communities. While some of these actions could have a direct impact on all federal grantees , some will have a more significant impact on health care providers and to entities serving certain populations (immigration raids). The actions may significantly impact health care service delivery.

One way for CHCs to prepare for and respond to uncertainty is to employ tabletop exercises during which the organization identifies vulnerabilities, enhances strategic planning, and ensures continuity of services in their communities.

What is a Tabletop Exercise?

A tabletop exercise (TTX) is a structured, scenario-based discussion designed to help organizations anticipate and plan for challenges. Participants on all levels, from leadership to front line workers, work through a hypothetical situation, testing their response plans, strategies and identifying gaps in preparedness.

Why use a Tabletop Exercise?

Tabletop exercises build capacity, help organizations evaluate their business continuity plans and identify strengths and areas for improvement. These exercises provide training and awareness to staff who have an opportunity to rehearse their roles and responsibilities during an incident. Plus, they are low-cost and low-stakes. A properly documented TTX may help CHCs meet emergency preparedness requirements for rural health centers and federally qualified health centers, i.e., 42 CFR 491.12(d)(2).

How Long is a Tabletop Exercise?

A tabletop exercise usually lasts from 1 to 4 hours but can vary depending on the scenario. Discussion times are usually open-ended and flexible, and participants work with a facilitator to arrive at in-depth decisions within exercise modules. When the time is up, the activity is concluded.

Tabletop Exercise Example[1]

Scenario

Immigration and Customs Enforcement (ICE) agents arrive at a health center location to conduct an immigration status check.

Background

It is a regular working day at a community health center. Front desk staff realize that Immigration and Customs Enforcement (ICE) agents have arrived on the premises. One ICE agent provides the front desk staff with the names of three individuals and asks whether they are patients. After scanning the patient sign-in sheet, he then requests access to the records of two patients on the list. The other ICE agents take seats in the waiting room and attempt to question the individuals in the waiting room about their immigration status. The health center must determine how to respond while complying with legal requirements and ensuring the safety and confidentiality of its patients.

Exercise Objectives

1. Identify legal and ethical responsibilities when responding to inquiries from law enforcement, including ICE agents.
2. Develop / review a protocol to protect patient information and staff.
3. Ensure staff members are trained on handling such situations appropriately.

Exercise Conduct:

1. Scenario Introduction:
   • The facilitator briefs participants on the ICE visit and its immediate impact on operations.
   • Discuss the center’s legal obligations under HIPAA and other privacy laws.
2. Discussion Questions:
   • What legal rights do patients and staff have in this situation?
   • How should staff respond to law enforcement requests for patient information?
   • What measures can be taken to de-escalate the situation while ensuring compliance with federal and state laws?
   • What are the best practices for communicating with patients and staff during and after the event?
3. Debrief /Hotwash:
   • Participants reflect on insights gained from the exercise.
4. After-Action Plan:
   • Document key action points and integrate them into an organizational response plan.

Suggested Action Planning Items

1. Develop / review a step-by-step protocol for staff to follow when approached by law enforcement.
2. Train employees on patient confidentiality and privacy laws and their rights regarding federal inquiries.
3. Establish a rapid response team to provide legal and psychological assistance and support.
4. Create an external communications strategy to manage media or community concerns.

Tabletop exercises are an excellent tool for being proactive. They provide a structured way to anticipate challenges, strengthen internal preparedness, and ensure the continued provision of critical health care services to vulnerable populations.

For questions concerning anticipating and planning for challenges with Tabletop Exercises, please contact Compliance & Risk Management Services Manager Alexander S. Lipovtsev and Partner Dianne K. Pledgie.

[1] This exercise is provided as an example only and should be modified as appropriate for your organization’s size, staffing pattern, resources and specific health care setting. For a more expanded exercise example that follows the Homeland Security Exercise and Evaluation Program’s (HSEEP) practices and guidance, see Michigan Primary Care Association’s Tabletop Exercise – Interacting with Immigration and Customs Enforcement (Health Center Scenarios).