CMS Emergency Preparedness Requirements
The Centers for Medicare and Medicaid Services (CMS) has issued two Survey and Certification (S&C) letters related to the Emergency Preparedness requirements that are effective as of Nov. 15, 2017. S&C 17-21 clarifies the requirement related to participating in a community-wide exercise.
In order to meet these requirements, CMS strongly encourages providers and suppliers to seek out and participate in a full-scale, community-based exercise with their local and/or state emergency agencies and health care coalitions, and to have completed a tabletop exercise by the implementation date. CMS notes that some providers and suppliers are waiting for the release of the interpretive guidance to begin planning these exercises; however, that is not necessary, nor is it advised. CMS indicates that providers and suppliers who are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance.
CMS adds that while providers and suppliers are encouraged to partner with local and state emergency agencies and health care coalitions to conduct full-scale community-based exercises, not all agencies and coalitions will have the ability or resources to engage with all providers and suppliers. Therefore, a full-scale, community-based exercise may not always be possible for some providers and suppliers. In such cases, it is expected that those providers who have been unable to complete a full-scale exercise by Nov. 15, 2017 will complete an individual facility-based exercise and document the circumstances as to why a full-scale, community-based exercise was not completed. The documentation should include what emergency agencies and/or health care coalitions the provider or supplier contacted to partner in a full-scale community exercise and the specific reason(s) why a full-scale exercise was not possible.
The S&C provides resource information including links to emergency preparedness agencies, planning templates, and many other valuable resources.
S&C 17-22 provides information on registering for the upcoming Medicare Learning Network (MLN) call on Thurs., April 27th from 2:30 to 3:30 pm. The MLN call will review the training and testing requirements of the new CMS Emergency Preparedness regulations. You can register for the call by clicking here.
Contact: Elliott Frost, efrost@leadingageny.org, 518-867-8832