✨Safety and Emergency Management

Panorama is a nonprofit Corporation. Resident contracts are Type C. Panorama management has made it clear that they are not responsible for and do not plan on assisting those in Independent Living in case of a disaster or widespread emergency, so we have a resident committee patterned after the Map Your Neighborhood program of a few years ago. Residences are individual homes, duplexes, or multiplexes. There are also three multilevel apartment buildings. Few residences have much space for storing emergency food and water or other supplies. Apartments have even less space for this.

The Corporation is legally required to provide disaster support for those in Assisted Living and Convalescent/Rehab, but so far have not been willing to share those plans with us in Independent Living. One of our multistory buildings houses some Assisted Living and some Independent Living apartments and there is no clear information on what would happen there in a major disaster.

I'm interested to hear how other communities approach this issue. In our area it's not a matter of IF, it's a matter of WHEN, and the Cascadia fault is overdue for a major earthquake.

• How do you motivate residents to prepare to take care of themselves?
• Does the Corporation provide space for storing emergency supplies? Do they store any supplies?
• In multistory buildings, do you have evacuation drills (like fire drills or emergency drills?)

Thank you for sharing your plans. ideas, and thoughts.

Karren Lore

Panorama in Lacey, WA

Karren,

Thank you for raising this. Emergency preparedness for Independent Living residents is a serious issue, and your questions about resident motivation, storage space, supplies, and evacuation drills are exactly the kinds of practical questions that other communities may be able to help address.

I do want to offer one clarification, however, because the distinction is important. In a Type C contract, Independent Living residents are generally living in their own homes without the same staff oversight that applies in Assisted Living or skilled nursing. In that sense, the community may not assume responsibility for in-home care, individual evacuation, or household emergency supplies for IL residents during a widespread disaster. That is a contractual and structural distinction, not necessarily an indication that the organization has no emergency plan or would provide no help.

My understanding is that Panorama does have services available to Independent Living residents, including Urgent Response Aides, the SARA emergency pendant system, Security, and Social Services. Those services do not remove the need for household preparedness, nor do they answer every question about what would happen in a major regional disaster, but they are part of the overall picture.

Your resident committee, especially if patterned after Map Your Neighborhood, seems to me to be a constructive and appropriate neighbor-to-neighbor layer. It can complement the formal services of the organization while helping residents think realistically about what they can and should do for themselves.

The storage issue you raise also seems very real. Residents in homes, duplexes, multiplexes, and especially apartments may have limited space for water, food, medicines, flashlights, batteries, and other emergency supplies. That is a good subject for dialogue with management and with other residents: What is reasonable for each household? What can neighbors do together? Are there common storage options? What special issues arise in multistory buildings, especially where Assisted Living and Independent Living are in the same structure?

So I would suggest reframing the issue this way: not “the corporation is not there to help,” but “what are the respective responsibilities of the corporation, staff, residents, and neighbors in a widespread disaster?” That question preserves the seriousness of your concern while also allowing for a more accurate and productive conversation.

Richmond Shreve

NaCCRA Board Member & VP

Forum Moderator

FEMA’s current guidance supports a “whole community” idea: emergency plans work best when institutions, residents, households, and neighbors all understand their roles, and ready.gov specifically urges older adults to create plans and kits tailored to their own needs. (FEMA)

In the attached PDF you will find my thoughts on personal readiness.

Richmond Shreve

NaCCRA Board Member & VP

Forum Moderator

Karren and others,

Yes, you may reproduce the emergency management essay freely. This is generally true of materials I write and publish here. It's always wise and courteous to ask the author directly when the source is a third party.

Richmond Shreve

NaCCRA Board Member & VP

Forum Moderator

Thanks for the excellent info you shared, Richmond.

In some CCRCs that I know about, many residents in IL decide to stay in IL and "age in place" to avoid a move, a move to a much smaller residence, into AL where many people do not care to move to even when they need it. Those who decide not to move usually get care by hiring caregivers to get the help they require.

If a disaster happens (major earthquake or fire) and someone is in IL on the 7th floor and can no longer deal with stairs, are they on their own if they did not want to move to AL?

Major earthquake and a fire differ in scale. Most urban areas have well established response protocols to deal with an apartment house fire. The response is local and immediate. So the timeline is a matter of a couple of hours at most. Your hypothetical person on the seventh floor, and their aids, should know where it is safe to remain. This could be the apartment, a balcony, a stairwell, or even the opposite end of the corridor if there are fire doors. They need to identify a place to shelter until enough first responders and equipment arrive to evacuate them.

The earthquake creates an overwhelming flood of emergencies for the local first responders. Consequently the resident who can't get themselves to safety, and remains in independent living, may have a long wait before they are evacuated. But, county and state emergency management has planned for such situations and has mutual aid arrangements to summon help from areas not affected. The timeline to mobilize that help is hours and days. So the individual resident's preparation would be to store supplies to shelter in place. You can live without food for a week. You need water daily.

Quite apart from the emergency contingency, we should all consider the isolation that personal care at home is likely to cause. Even a person who is fully capable does not do well if their only social contact is a housekeeper. We may want to be surrounded by our familiar stuff . . . but is that better than being in the company of friends with companionship and conversation just outside the door? It's a personal and family decision.

Richmond Shreve

NaCCRA Board Member & VP

Forum Moderator

Susan,

Just as a practical matter, somebody on a high floor who can't use the stairs in an emergency situation could be on their own, at least for a while, simply because there wouldn't be anybody immediately available to help them. In that situation they might have to be carried down the stairs, which could require two people.

State or local regulations are relevant. Your state apparently allows retirement community residents to live on a high floor even if they can't get out on their own. When the management of my father's CCRC in California approached him about moving into Assisted Living, they said they were prohibited from having residents on a high floor who can't use the fire stairs. Assisted Living and Skilled Nursing were in a separate one-story building.

I used to work in a medical building. My boss was a strict follower of Life Safety laws (from the National Fire Protection Association). He taught us that in a fully sprinkled building, in a fire alarm situation, non ambulatory people (for example in wheelchairs) would be allowed (according to code) to remain in the elevator lobby of whatever floor they are on.

Of course they are not supposed to go in an elevator, and likely the elevators won't respond to the push button anyway. Sorry, I can't provide any code number to verify this, as the code books are huge, and I haven't been successful in searching for this.

I strongly suggest that you read the excellent book "Inflamed, Abandonment, Heroism and Outrage in Wine Country's Deadliest Firestorm" by two seasoned journalists. It is the real, harrowing story of the 2017 Tubbs fire and how 2 sister CCRCs dealt with it. Despite what was believed and assumed, they were horribly unprepared, left the residents on their own and their management washed their hands and got away with it.

It is unfortunate, but probably if you really started to look into it (understand what should be done and how to prepare) and scratch the surface, you might find out that you could be in a similar situation like the residents in the 2 CCRCs in the Tubbs fire.

I do not even want to think about the Cascadia earthquake (that we learned about after we moved to Portland). If that happened, probably it would not matter if one lived on the first or the 7th fl. The earthquakes in Venezuela were "only" a 7.... , Cascadia could be a 9 or more.

In a major disaster like a firestorm or a serious earthquake, one cannot count on others and CCRCs do not make it easy to store the recommended water, food and other supplies. State and local regulations unfortunately do not mean that emergency staff will show up and save people, particularly those who are not mobile.

Does any of the CCRCs where you live provide shareable space for storing the residents' emergency supplies?

Susan, thanks for this reference. It may provide useful in our committee's discussion about emergency preparation. In our typeC contract, management is not obligated to provide this type of assistance or planning.

We have approached management regarding finding areas to store emergency water. Management is ope to these discussions.

Aside from all the benefits of a continuum of care (and there are many as we know), in some senses Independent Living is not so much different from buying a house in a neighborhood where the association maintains landscaping and there are other shared amenities like gathering places, fitness/pool facilities etc. Homes on our campus have no personal yard space beyond a patio. Apartments have balconies and some have small storage closets. In an off-campus neighborhood people would have yards where they could store emergency supplies if they wished. Apartment buildings would be a different story though.

Our disaster prep committee is trying to be really creative with suggestions for personal storage of water and emergency food when space is limited. For those who have patios we are investigating "rain barrel" type storage We've found "prepper" web sites to have interesting solutions to water collection and storage. There are various small-container solutions for storing water. Many are stackable and/or will fit under a bed or on a patio perhaps disguised by some planters to comply with campus appearance guidelines. Many emergency food kits don't take up much space.

All this to say that we are working on finding individual solutions to supply storage because there is no space available for common-area storage.

Karren, can you provide the links for the sites you mentioned for emergency food kits and water storage barrels? Thank you. Kris Loken

Kristin,

Our research is still rather spotty and disorganized. I will post something more complete and organized in a few days.

Karren

Kristin,

Wow, there is a lot of information out there! And everyone's situation is different, so the choices will be specific to individuals or communities. Here are just some links and if you follow them you'll doubtless find more. Also included are some search strings that have turned up more ideas for us.

Surprisingly, we've found "prepper" web sites as well as camping and outdoor survival sites, to be great sources of brainstorming ideas. We're still searching and working on our plan. I hope these give you some ideas. Sorry if it's too much!

Apologies for the rather disjointed conglomeration of links.

Water storage for volumes:

Emergency Water Tanks https://emergencywatertanks.com/collections/all

Tank and Barrel https://www.tankandbarrel.com/water-storage-tanks-emergency-water-tanks-c-192_194.html

The CDC has detailed information on creating and storing emergency water supplies: https://www.cdc.gov/water-emergency/about/how-to-create-and-store-an-emergency-water-supply.html

Search Amazon for "rain barrel" or "emergency water storage tank" or "water storage barrel". You'll find all kinds of water storage, from 3 gallon "bricks" to 5-gallon jugs, to 30 gallon barrels.

Home Depot, Lowe's and similar businesses also have different types of rain barrels and even decorative planters that have water reservoirs.

Just remember that if you are going to store water in big barrels you need to have a way (like a spigot or pump) to get it out when you need it! Also a way to make it safe to drink if you're not going to rotate it

Amazon has "water preserver drops"

Water for individuals

Search Amazon for "emergency water" you'll find Red Cross water in cans with 50 year shelf life, water in packets with multi-year shelf life, and more

Blue Can Water has a 50 year shelf life. You can buy cases or pallets. https://50yearbluecanwater.com/

Primal Survivor, a prepper site, has a posting on how to store water for emergencies https://www.primalsurvivor.net/how-to-store-water-for-emergencies/

Emergency Food

You can just stockpile nonperishable food such as cases of canned vegetables (also a source of liquid in an emergency). Depending on how much space you have. Periodically give it to the food bank and buy more.

Possibly a smaller "footprint" and requiring less monitoring and rotation, there are freeze-dried or dehydrated meals that are created for camping and outdoor activities.

Also available are complete "kits" designed to feed individuals or families for a week, a month, or more. Costco has these and will deliver. They come in a plastic bucket. Search for "emergency supplies" on the Costco site. This type of emergency food is available on camping/outdoor sites as well.

NOTE: If you are going to use freeze-dried or dehydrated food you need to think about how you will heat the water to reconstitute it!

Another options is MREs. These are military field rations, high-calorie meals each individually sealed and I understand they even have a way to self-heat. Some sources of these are:

MRE Supply https://mresupply.com

MREs World https://mresworld.com

MRE Depot https://mredepot.com

Emergency Kits

The Red Cross has backpack-sized relatively complete emergency kits: https://www.redcross.org/store/emergency-preparedness

The Federal Government has information on how to build your own emergency kit: Build-a-kit https://www.ready.gov/kit

Search Amazon for "emergency survival kits"

Prepper sites

Here are just a few that have all kinds of information and opinions

https://trueprepper.com/

https://prepper.com/

https://www.skilledsurvival.com/preppers-checklist/

https://www.primalsurvivor.net/how-to-store-water-for-emergencies/

Susan,

According to its Resident Handbook, Channing House in California maintains a supply of water and food for emergency purposes in both the Independent Living and Skilled Nursing/Assisted Living buildings. It also advises IL residents to put together their own survival kit, with a detailed list of what that should include, which is much more than just water and food.

It does not provide a common storage area for the latter, but it seems to me a storage area outside one’s own apartment might not be accessible, depending on the nature of the emergency.

Here at Panorama, that would be the case. Our contract is clear about that. For example, the people in the single-level fourplex who live immediately next to me have a full-time live-in caregiver (their son) plus one from an outside agency who's there for about six hours every day. The man is confined to an electric wheelchair. He is unable to transfer. The woman uses oxygen much of the day.

They have asked me, as the "Prep rep," who will help them in an emergency. I had no good answer. In a major earthquake, their outside caregiver (as well as emergency services) might not be able to get here. The chair will not work, nor will the oxygen, without electricity. About the best I could come up with was to have a fairly substantial power pack for backup electricity (and keep it charged). and of course substantial stored water and food.

Perhaps other communities would have different contracts or interpretations of their contracts. I am learning via NaCCRA, that some states have varying and much more robust and protective regulations for CCRC type communities.

It's interesting that various blogs, news articles, and senior living sites don't seem to emphasize disaster planning as one of the items to consider when making retirement plans and choosing a community.

What Gemini has to say about emergency preparation for CCRCs:

When evaluating a Continuing Care Retirement Community (CCRC), emergency preparation requires analyzing distinct layers of operational risk. When evaluating a Continuing Care Retirement Community (CCRC), you must confirm that their emergency plans are fully actionable, not just binders on a shelf. CCRCs span multiple levels of care—from independent living to skilled nursing—meaning emergency protocols must be dynamic enough to handle varying levels of resident mobility and cognitive function. The most critical questions to ask management cover the following:

Important Questions to Ask a CCRC

1. Infrastructure & Self-Sufficiency

• What is the facility’s exact backup generator capacity, and what does it power? How long can those generators run? Ensure the generator powers not just emergency lighting, but also residential heating/cooling, medical equipment (e.g., oxygen concentrators, ventilators, etc.), and medication refrigeration.
• How many days of autonomous subsistence supplies are maintained on-site? Ask for the precise inventory duration for potable water, non-perishable food, and essential medical supplies (72 hours is the standard minimum; 7 to 14 days is ideal for major regional disasters like earthquakes).
• Are independent living units structurally integrated into the main backup systems? Often, skilled nursing wings have robust backups while independent apartments have limited emergency power.

2. Evacuation & Mobility Logistics

• What is the exact procedure for evacuating physically impaired or non-ambulatory residents down the stairs if elevators lose power during a major fire or earthquake?
• What are the designated evacuation thresholds and pre-arranged receiving locations? Ask where residents will be moved if the building is compromised, and verify that the CCRC holds active transfer agreements with those backup facilities.
• How is resident accountability maintained during an evacuation? Inquire whether they use digital check-ins, wristbands, or paper rosters to track residents across different levels of care.
• What is the vehicle and transportation staging plan? Determine if they own an independent fleet for evacuations or rely on third-party transportation vendors (which may be unavailable during a regional crisis).

3. Staffing & Communication

• What are the minimum staffing ratios for overnight and weekend shifts during an emergency? Disasters rarely happen during peak daytime hours; ensure the skeleton crew on a Sunday night is explicitly trained to execute immediate evacuations.
• What is the redundant communication protocol if cellular networks and internet fail? Look for landlines, satellite phones, or two-way radio systems.
• How and when are families notified? Ask for the structured timeline and channels (automated text, email portal, dedicated off-site call center) used to update emergency contacts.
• Can they provide a recent log of emergency drills (for both shelter-in-place and evacuation scenarios)? 

HOW TO ENSURE THAT PLANS ARE ACTIONABLE:

An emergency plan is only as good as its real-world execution. To move a plan from a binder to an actionable strategy, it must be continuously tested, structurally integrated with local authorities, and clearly understood by the people on the ground.

Key Strategies for Actionable Verification

1. Rigorous, Multi-Scenario Testing

• Simulate Worst-Case Timing: Drills should not only occur during Tuesday mornings when full administrative staff is present. Demand data on unannounced drills conducted during weekend nights or holidays when staffing levels are at their lowest.
• Test the Chain of Command: Drills must include "tabletop exercises" where key leaders are simulated as unavailable or incapacitated. This ensures lower-level staff members know exactly who holds decision-making authority.
• Vary the Hazard Type: Ensure drills distinctively test both fire evacuation (rapid egress) and earthquake response (drop, cover, hold, followed by structural assessment before movement).

2. Independent Integration & Audits

• Local First Responder Reviews: The CCRC should actively share its floor plans, utility shut-off locations, and evacuation routes with local fire and police departments. First responders should ideally participate in or observe major on-site drills.
• Third-Party Regulatory Audits: Review the facility’s latest state department of health or social services inspection reports. Look specifically for citations regarding life-safety codes, emergency lighting, or drill compliance.

3. Redundant & Decentralized Logistics

• Dual-Source Vendors: Emergency supply contracts (for water, fuel, food, and transport) should have secondary vendors located in a different geographic zone. If a regional disaster strikes, a local vendor may face the exact same infrastructure collapse.
• Hardcopy Redundancy: Digital resident rosters, medication logs, and contact sheets are useless if server grids or power systems fail. Actionable plans rely on frequently updated, physical, waterproof binders kept at designated muster stations.
• Clear, Universal Signage: Evacuation routes and emergency equipment must be marked with high-visibility, photoluminescent (glow-in-the-dark) signage that does not rely on emergency backup power to be visible in a smoke-filled or dark corridor.
• 
  

WHAT SHOULD HAVE NOT HAPPENED BUT IT DID IN THE TUBBS FIRE

The book Inflamed: Abandonment, Heroism, and Outrage in Wine Country's Deadliest Firestorm by Anne E. Belden and Paul Gullixson meticulously documents the systemic and logistical breakdowns at two adjoining Oakmont Senior Living facilities in Santa Rosa—Villa Capri (assisted living/memory care) and Varenna(independent living)—during the 2017 Tubbs Fire.

The following is a factual summary of exactly what went wrong and the critical problems encountered, based on the documented investigations and accounts in the book.

Critical Breakdown of Failures and Problems Encountered

1. Total Abandonment by Staff and Administration

• What Happened: On the night of the fire, only three or four overnight staff members were on duty at Villa Capri to care for approximately 62 elderly and highly vulnerable residents (including 25 in a locked dementia/memory care unit).
• The Failure: As the fire encroached around 3:00 AM, the designated substitute administrator left with a group of residents. The remaining staff members, completely untrained on what to do, eventually panicked and fled in their own vehicles, leaving 24 frail, non-ambulatory, and cognitively impaired seniors entirely alone in the dark as the building began to burn. 

2. Lack of Keys and Immobilized Evacuation Vehicles

• What Happened: Both facilities had large transport buses parked on-site that were specifically intended to move large numbers of seniors during an emergency.
• The Failure: When family members and everyday citizens arrived to rescue the residents, the staff members could not locate the keys to the buses, nor did they know where they were stored. The facility's administrator had left the scene without handing over or disclosing the location of the keys, rendering the highest-capacity evacuation vehicles completely useless. 

3. Total Communication and Command Collapse

• What Happened: The power failed, plunging the facilities into pitch darkness.
• The Failure:
• There were no backup generators functioning at Villa Capri to provide light or power.
• Staff could not establish contact with the facility’s executive director.
• When family members arrived and asked the remaining skeleton crew for the official evacuation plan, staff explicitly told them that no evacuation plan existed and suggested that dementia residents should simply "be evacuated last."
• At Varenna, the administrator reportedly instructed staff who had begun moving residents to actually return them to their rooms because he didn't want to "make trouble" for the company, before eventually leaving the site himself.

4. No Accountability, Documentation, or Rosters

• What Happened: Emergency responders and families had to search rooms blindly in thick smoke using cell phones as flashlights.
• The Failure: Because the evacuation was completely uncoordinated by management, there was no master roster or tracking system used. When police officers and fire crews arrived at the scene, no one could tell them how many residents had already been picked up by family, how many were still trapped inside, or where the evacuated residents had been taken. 

5. Physical Infrastructure Traps

• What Happened: Multiple disabled, blind, and non-ambulatory residents were located on the second floor of the facility.
• The Failure: When the power went out, the elevators immediately stopped working. Because there was no mechanical or structured plan to move immobile residents down the stairwells, family members and a passing police officer (who was originally driving to a completely different facility) had to physically bump wheelchairs down the stairs and carry frail seniors through blinding smoke.

The Outcome: Villa Capri burned entirely to the ground less than an hour after the last seniors were pulled out. The book underscores that it was a miracle no one died inside the facilities, a result credited entirely to the "Herculean efforts" of civilian family members, strangers, and a few chance first responders who stepped into the vacuum left by management.

=======================

Emergency preparedness article from myLifeSite;

https://mylifesite.net/blog/post/ccrcs-emergency-preparedness#:~:text=Verify%20with%20management%20that%20there,center%E2%80%94and%20is%20practiced%20regularly.

Susan, I do not know what your initial question / comment was that you submitted to Gemini. So, I took your first paragraph and ended with this question - The most critical questions to ask management should be what?

Keeping it that simple, I submitted that also to Gemini (I have the Pro subscription) to see if I'd get anything more / different. See below.

Linda Kilcrease

Resident of a CCRC

You are looking at this exactly right. Your premise highlights the most dangerous blind spot in CCRC management: a plan that works for an active 75-year-old in Independent Living is useless for an 85-year-old in Memory Care or a bed-bound patient in Skilled Nursing.

When you sit down with CCRC management, you need to push past the glossy brochures and ask pointed, logistical questions that test the actionability of their plans.

Here are the most critical questions to ask, categorized by operational risk:

1. Staffing and Execution Under Duress

A plan is only as good as the people available to execute it. Crises often happen off-hours or during severe weather when staff cannot travel.

• "If a zero-notice evacuation is ordered at 2:00 AM on a Sunday, what is your guaranteed minimum staff-to-resident ratio in the skilled nursing and memory care wings?" (You want to know their absolute worst-case baseline, not their fully staffed Tuesday afternoon numbers.)
• "Do you have an 'A-Team' or 'Ride-Out Team' contract for staff during natural disasters?" (Best-in-class CCRCs require certain staff to shelter in place and often allow them to bring their immediate families or pets so they don’t abandon their posts to protect their own homes.)
• "Who has the ultimate authority to call an evacuation, and what is the chain of command if the Executive Director is unreachable?"
• 
  

2. Power and Infrastructure Redundancy

"We have a backup generator" is not a sufficient answer. You need to know exactly what that generator is capable of keeping alive.

• "Does your generator power the entire HVAC system and kitchen refrigeration, or just 'red-plug' life-support outlets and hallway lighting?" (In extreme heat or cold, a lack of HVAC can become deadly faster than the original crisis.)
• "How many days of standalone fuel, potable water, and oxygen do you physically have on-site at this exact moment?" (Relying on "priority delivery contracts" during a regional disaster is a massive risk. They should have a minimum of 3 to 7 days of supplies physically on campus.)
• 
  

3. The Mobility Gap (Evacuation vs. Shelter-in-Place)

Because CCRCs span the full spectrum of aging, the logistics of moving residents vary wildly.

• "With which specific transport companies do you have pre-paid, guaranteed contracts for moving bed-bound and wheelchair-dependent residents?" (During a regional evacuation, every facility in the state will be calling for ambulances and wheelchair vans. If the CCRC doesn't have an ironclad, retainer-based contract, they will be left waiting.)
• "For Independent Living residents, at what specific trigger point does management take over their evacuation?" (Many CCRCs leave Independent Living residents to fend for themselves until the last minute. You need clear boundaries on when the facility assumes responsibility for their transport.)
• "Where are your pre-arranged destination facilities, and do they match the level of care required?" (Memory care residents cannot be evacuated to a high school gymnasium; they require secure, anti-wandering environments.)
• 
  

4. Drills and Transparency

This tests your premise directly: is the plan just a binder on a shelf?

• "Can I see the 'After-Action Report' from your most recent full-scale drill?" (A tabletop exercise doesn't count. They should be able to show you a document that details what went wrong during their last physical drill and how they fixed it. If they claim the drill went perfectly, they aren't testing hard enough.)
• "When cellular networks and local internet fail, what is your redundant system for updating out-of-town family members?" (Look for satellite communication capabilities, out-of-state call centers, or automated text systems powered by off-site servers.)

Linda, my experience w. Gemini is that even if the question is the same but asked at different times, the answers might be somewhat different. Between the answers that I got and you got, someone could come up with a very useful and theoretically practical document. I mentioned theoretical, because:

- I am not sure if CCRC administration would be willing to go beyond their standard practices (if the standard is less)

-I do not know if residents would be willing to take this seriously, participate, contribute and cooperate

-as a prospect, my experience is that marketing only provides superficial answers to questions like these and it is not easy to get time with someone who has answers. Probably they could not afford spending this much time to explain and I am not sure if they have this info at their fingertips ...

In my house I do what I want. I had it retrofitted. I am storing twelve 5 gal containers with water, food, etc. It is a royal pain to keep replenishing it, but at least I have storage place. In a CCRC, that's an obvious issue. However, it should not be, as my life is just as valuable in my house, as it should be in a CCRC. Disasters unfortunately happen. While one cannot make sure that no harm ever happens, CCRCs could do more as they are responsible for providing safe accommodations for all of their residents. Residents pay a lot for the privilege of living there.

A few more points to add:

Residents in the Independent Living (IL) segment of a CCRC generally do not share the same strict legal protections as those in assisted living or skilled nursing. Because IL units are legally categorized as housing rather than medical care, emergency regulations differ drastically by state and by the specific section of the campus. The Takeaway: Unless you are in a state with explicit laws sweeping IL units into care-level disaster mandates, a CCRC's legal obligation to an independent resident mirrors that of a standard landlord. When evaluating a contract, look for a "Continuum of Care" disaster clause that explicitly pledges staff and resource coordination to all residents regardless of their care tier.

1. The Legal Gap Between Care Levels

CCRCs are hybrid entities, and the law views them through entirely different lenses depending on where you sleep.

• Assisted Living & Skilled Nursing: These wings fall under state healthcare/social service licensing and federal Centers for Medicare & Medicaid Services (CMS) regulations. Staff have an explicit, non-waivable custodial duty to physically protect and evacuate these residents.
• Independent Living: IL apartments are legally classified as congregate housing or senior apartments. Because residents are technically independent in their daily activities, the facility’s legal obligation is tied primarily to building codes and landlord-tenant law. While the facility must provide safe physical exits and working fire alarms, staff are generally not legally mandated to physically lift, carry, or individually evacuate an IL resident unless a specific state law mandates campus-wide disaster execution.

2. Stark Differences by State

CCRC oversight is heavily decentralized, and emergency obligations vary widely by jurisdiction.

Unless you are in a state with explicit laws sweeping IL units into care-level disaster mandates, a CCRC's legal obligation to an independent resident mirrors that of a standard landlord. When evaluating a contract, look for a "Continuum of Care" disaster clause that explicitly pledges staff and resource coordination to all residents regardless of their care tier.

The Cross-Campus Clause: Ensure the CCRC's written Emergency Operations Plan (EOP) voluntarily and explicitly integrates the IL units into the main campus triage system, rather than treating them as a separate apartment complex.

• Ask if their 3-day shelter-in-place supply calculations include the total headcount of the independent living buildings.
• Confirm whether IL residents are included in the facility's emergency communication network (such as automated text/call alerts) during regional threats like Pacific Northwest earthquakes or seasonal wildfires.

CCRCs and senior living facilities have explicit legal obligations to protect, care for, and safely evacuate residents during a disaster.

The idea that a facility can simply tell residents to "fend for themselves" or walk away during a crisis is a severe violation of both federal and state laws. Following the exact breakdowns documented in Inflamed (the Tubbs Fire), the legal landscape tightened significantly to prevent future administrative abandonment.

The legal obligations break down into three primary categories:

1. The Statutory "Duty of Care"

Under elder abuse and licensing laws, senior living operators assume a legal custodial duty of care. This means because residents pay the facility for housing, supervision, and medical care, the operator is legally liable for protecting them from foreseeable harm—including natural disasters.

• Failing to execute this duty, leaving vulnerable residents behind, or failing to train staff constitutes criminal elder neglect and reckless endangerment.

2. State Licensing and "The Oakmont Laws"

Because CCRCs house different levels of care, they are governed by state regulatory bodies (such as the Department of Social Services for assisted living and the Department of Public Health for skilled nursing).

• The Tubbs Fire Precedent: Following the abandonment at Villa Capri and Varenna, the California District Attorney and Attorney General filed a massive law enforcement action against Oakmont Senior Living, resulting in a $500,000 settlement, strict injunctions, and an independent monitor to oversee compliance.
• Legislative Overhauls: The disaster directly spurred new state laws (such as AB 3098 in California) that explicitly criminalized the gaps highlighted in the book. By law, facilities must now legally prove they have:
• Instantly accessible evacuation keys.
• Specialized evacuation chairs permanently staged at stairwells.
• Multiple designated, pre-contracted out-of-area evacuation destinations.
• Rigorous, documented staff drills across all shifts.

3. Federal CMS Regulations

For the segments of a CCRC that receive Medicare or Medicaid funding (typically the skilled nursing and rehabilitation wings), the federal Centers for Medicare & Medicaid Services (CMS) enforces the Emergency Preparedness Final Rule. This mandates that facilities strictly maintain:

• An "All-Hazards" Emergency Plan: A documented strategy that can flex for any disaster type.
• 72-Hour Autonomous Subsistence: A legal mandate to maintain enough on-site power, fuel, water, food, and medical supplies to sustain life for a minimum of 72 hours without outside emergency assistance.
• Failure Consequences: Violating these rules results in immediate federal "condition-level deficiencies," stripping of licenses, and the termination of federal funding.

The Legal Reality: A CCRC cannot contractually wave away its disaster obligations. If an emergency occurs, they are legally required to manage the crisis, account for every resident on their roster, and safely coordinate transportation and continuity of medical care.

Susan - I asked Gemini what this meant for the state of Pennsylvania. below.

Linda Kilcrease

Resident of a CCRC

The situation described in the forum post—where the law views a Continuing Care Retirement Community (CCRC) through entirely different lenses depending on the resident's level of care—is exactly how the legal framework operates in Pennsylvania.

Because CCRCs in PA are hybrid entities, there is no single "CCRC emergency law." Instead, the state regulates the campus through distinct departmental silos, which creates the exact legal gap in Independent Living (IL) that the post warns about.

How Pennsylvania Regulates CCRC Emergencies

The statutory duty to physically protect, sustain, and evacuate residents drops off steeply once you cross the campus line from licensed care into Independent Living.

Care LevelPA Regulatory BodyEmergency ObligationsSkilled NursingDept. of Health & Federal CMSStrict Custodial Duty. Must maintain an "All-Hazards" plan and ensure 72-hour autonomous subsistence (power, food, medicine). Staff are legally mandated to evacuate residents.Assisted Living & Personal CareDept. of Human Services (Ch. 2800 & 2600)Supervisory Duty. Facilities must have localized evacuation plans, conduct regular drills, and keep trained, CPR-certified staff on-site 24/7.Independent LivingDept. of Insurance (Financials only)Landlord-Tenant Duty. Regulated as congregate housing. While fire alarms and safe physical exits must meet municipal building codes, staff have no statutory duty to physically evacuate or provide medical triage to IL residents.

In Pennsylvania, the Insurance Department oversees the financial solvency and disclosure statements of CCRCs (under the Continuing-Care Provider Registration and Disclosure Act), but they do not regulate health, safety, or emergency management. Unless a community voluntarily writes broader protections into its contract, an IL resident in PA is legally viewed as a tenant renting an apartment.

Recent Legislative Shifts in PA

Following national trends to close these dangerous loopholes (like California's Tubbs Fire laws mentioned in your text), Pennsylvania lawmakers have begun targeting emergency protocols for congregant facilities.

On June 26, 2026, the PA legislature introduced SB1399. This bill aims to impose stricter, standardized emergency preparedness requirements on "covered facilities" across the Commonwealth. If passed and applied broadly, it would require facilities to:

• Develop comprehensive plans covering fire, explosion, evacuation, and shelter-in-place scenarios.
• Establish explicit methods to track and account for every individual on campus.
• Designate an on-site emergency coordinator with the authority to interface directly with local first responders.
• 
  

Evaluating Campus-Wide Protocols

For resident councils or safety committees evaluating their own community's disaster readiness, relying on state minimums leaves Independent Living highly vulnerable.

Because the state won't force a CCRC to treat IL residents like care patients during a crisis, the community must voluntarily bridge the gap. When reviewing a community's Emergency Operations Plan (EOP), look for the following:

• The Cross-Campus Clause: Ensure the EOP explicitly integrates IL buildings into the main campus triage and communication networks, rather than siloing them as independent apartments.
• Unified Resource Calculations: Confirm that the 72-hour shelter-in-place resource calculations (water, food, backup generator fuel) account for the total headcount of the IL buildings, not just the licensed beds.
• Safety 2.0 Integration: Ensure that passive sensors or wearable alert systems used by IL residents tie directly into a centralized, 24/7 campus dispatch center that won't go down if regional cellular networks fail.

Pennsylvania Senate Bill 1399, introduced on June 26, 2026, aims to close critical information gaps between high-risk care facilities and local first responders during the chaotic first moments of a crisis.

Here is a breakdown of the specific requirements the bill would impose on covered facilities:

1. Mandatory Emergency Preparedness Plan

Facilities must develop, maintain, and implement a written emergency preparedness plan. This plan must explicitly address scenarios including fire, explosion, evacuation, and shelter-in-place operations.

2. Strict Accountability and Tracking

The plan must establish concrete procedures to account for every single resident, staff member, and visitor during an emergency. This includes specific methods to track individuals' status and communicate that data directly to local emergency responders.

3. Designated On-Site Coordinator

Facilities are required to identify a designated on-site emergency coordinator. This individual must be granted the authority during a crisis to manage the response and serve as the primary point of contact for police, fire, and EMS.

4. Pre-Incident Facility Intelligence

To prevent first responders from flying blind, the plan must document essential building information, including:

• Facility layout and access points
• Building systems and utility shutoffs
• Specific evacuation procedures
• 
  

5. Mandatory Distribution to First Responders

Currently, PA law does not explicitly require care facilities to share their emergency plans with local responders. SB1399 mandates that facilities provide their plan (or a standardized summary) to local law enforcement, fire departments, EMS, and county emergency management:

• Upon initial development.
• After mandatory annual reviews.
• Within 30 days of any "material revision" (significant change) to the plan.

6. Security and Confidentiality

To protect against bad actors, the bill includes a confidentiality clause (Section 7329.6). Any portion of the plan containing security-sensitive information, access controls, or vulnerabilities is exempt from public disclosure under Pennsylvania's Right-to-Know Law.

The Catch for CCRCs: The Independent Living Gap

While SB1399 tightens regulations for skilled nursing, assisted living, and personal care homes, it explicitly defines a "covered facility" as one licensed or regulated by the Department of Health, the Department of Human Services, or the Department of Drug and Alcohol Programs.

Because Independent Living units in Pennsylvania are regulated for financial solvency by the Department of Insurance, they do not appear to meet the bill's definition of a covered facility. Unless the final law expands its definitions, a CCRC would be required to execute these strict tracking and coordination protocols for their care wings, but legally permitted to leave the Independent Living campus out of the mandate.

WHAT HAPPENS WHEN THE SAME BUILDING HOUSES IL AND LICENSED CARE

When Independent Living (IL), Assisted Living (AL), and Memory Care (MC) are stacked within the same physical structure, it creates a high-risk operational challenge. During an emergency—such as a fire or an earthquake—the structural integration forces the facility to treat the building as a single high-care entity under the law, yet the tactical execution on the ground becomes intensely complicated.

Here is exactly what happens structurally, legally, and operationally when these three distinct care levels share the same vertical space.

1. The Legal Reality: The Strictest Rule Wins

When licensed care units (AL/MC) share a building with unlicensed housing (IL), state fire codes and building regulations default to the highest care level present.

• Building Code Transformation: In states like Oregon, a building containing memory care or assisted living must meet strict institutional healthcare construction standards (typically Group I-1 or I-2 occupancy codes). This means the entire building—including the IL floors—must have advanced commercial sprinkler systems, fire-rated smoke barriers, automatic self-closing doors, and emergency backup power grids.
• The Unified Evacuation Mandate: From a fire marshal's perspective, an alarm triggers the whole building. The facility cannot legally leave an IL floor to fend for itself if an active fire threatens the structure, because a failure to manage the IL floors would compromise the evacuation routes (stairwells and elevators) for the vulnerable AL and MC residents below or above them.

2. The Tactical Nightmare: The "Vertical Triage" Problem

While the building is legally unified, the staff's physical capacity is not. If a crisis occurs (especially on a night or weekend shift), the presence of multiple care levels in one tower triggers a strict, predetermined vertical triage:

Phase 1: The Lockdown of Memory Care (MC)

Memory Care is almost always located on a secure, lower floor (often the 1st or 2nd floor) or a completely locked wing.

• The Routine: In a fire or earthquake, MC residents cannot navigate exit routes independently and will panic if exposed to alarms and smoke. Staff will immediately flood the MC unit to secure the heavy magnetic-lock doors (which automatically release during fire alarms) to prevent residents from wandering into danger or blocking the stairwells.

Phase 2: Horizontal Evacuation (Defend in Place)

Modern multi-story senior living buildings are engineered for "horizontal evacuation."

• The Routine: Instead of rushing everyone down the stairs immediately, staff will move AL and MC residents past heavy, fire-rated cross-corridor doors into an adjacent wing on the same floor. These smoke barriers are designed to withstand fire for 1 to 2 hours, buying time for first responders to arrive.

Phase 3: The Independent Living Abandonment Risk

Because the skeleton crew on a night shift must physically wheel, carry, or guide AL and MC residents to safety, IL residents on the upper floors are completely on their own during the initial stages of a vertical evacuation.

• Elevator Shutdown: The moment a fire alarm trips, elevators automatically drop to the ground floor and recall, becoming completely unavailable.
• Stairwell Conflict: If IL residents panic and rush down the stairwells, they risk colliding with or blocking staff members who are trying to carry non-ambulatory AL residents down those same stairs.

3. What You Must Verify If Considering a Multi-Story, Mixed-Use CCRC

If a community features this stacked vertical design, you must ask highly specific logistical questions during your tour:

• Where is Memory Care located relative to Independent Living? If MC is on an upper floor, it is a massive red flag. MC should ideally be on the ground floor for direct egress.
• How does the backup generator route power vertically? Does the generator run the HVAC and emergency lighting for the entire tower, or does it only support the AL/MC floors, leaving the IL floors in pitch blackness?
• What are the specific stairwell evacuation protocols for IL residents? Ask if IL residents are instructed to "shelter in place" in their apartments during the initial alarm to keep the stairwells clear for staff moving the frail AL residents.

The Structural Reality: Living in a mixed-use building guarantees you higher-quality physical safety infrastructure (sprinklers, fire walls, backup power) than a standalone senior apartment. However, it also means your immediate physical rescue by staff will be severely delayed during a major crisis, as their legal and moral mandate forces them to the AL and MC floors first.

1) In 2024, the State of Kansas (HB:2784) "bundled" all residents living in CCRCs under government oversight, specifically including Independent Living seniors. All CCRCs are under the Kansas Department of Aging and Disability (KDADS). This would not help your State now, but is something your residents might want to keep and eye on.

2) Pandemic Response: Looking into how your facility took care of residents during the pandemic may offer you some insights. How were all residents protected then could give you some insight into what you could expect in the future. My facility took care of all resident categories the same (and this was well before the new Kansas law was passed). Good luck.

Maura Conry

NaCCRA

Forum Facilitator