CMS Emergency Preparedness Rule Takes Effect — Are You Ready?
Evaluating your compliance with CMS emergency preparedness final rule
This post was originally published October 19, 2017. It has been updated to reflect clarifications released February 2019 and revisions proposed September 2018.
With the November 2017 deadline behind us, now is a good time for healthcare organizations to re-assess their compliance with the Centers for Medicare and Medicaid (CMS) emergency preparedness rule.
In their lengthy final rule, CMS named four core elements for healthcare emergency preparedness:
- Risk Assessment and Emergency Plan: Facilities should ensure that their Emergency Operations Plan (EOP) or continuity of operations plan (COOP) is informed by an all-hazards risk assessment. Emphasis should be on risks specific to a facility’s geographic area as well as the facility’s patient population, especially at-risk patients. CMS has also directed facilities to consider emerging infectious diseases such as the Ebola and Zika viruses.
- Policies and Procedures: Policies and procedures flow directly from the all-hazards risk assessment, with an emphasis on maintaining continuity of care. Policy and procedures should address staff and patient needs ranging from adequate food, water and medical supplies to tracking their location and sharing patient records appropriately.
- Communication Plan: For many healthcare facilities, a stand-alone communication plan is a new addition to emergency planning. To comply with the CMS emergency preparedness rule, facilities need to include communication both within their building or system and across a coalition of healthcare providers and emergency management agencies.
- Training and Testing: Finding gaps in planning and helping staff stay prepared are key functions of the CMS testing and training requirement. Essential features of the rule include an annual full-scale community exercise for all types of healthcare facilities (along with a second exercise that is full-scale or tabletop), and documenting all exercises and events for review and annual updates to the plan. In revisions currently under review, requirements for outpatient providers may be reduced to one test annually.
CMS emergency preparedness rule focuses on continuity of operations and community
Understanding the bigger vision behind the CMS emergency preparedness rule can help ensure that emergency plans are addressing new CMS expectations when the deadline arrives. The key words for the new rule are continuity, communication, and collaboration.
Motivated by large-scale disasters, the CMS emergency preparedness requirements aim to get facilities on the same page, so that that when disaster strikes healthcare coalitions can work together smoothly to ensure that critical patient care services experience minimized interruptions.
Healthcare organizations should look for alignment between their emergency management plans and the CMS emergency preparedness rule in several areas, including:
- Making the potential for partnerships a part of the risk assessment
- Establishing protocols and recordkeeping for requesting, sharing and reallocating resources
- Ensuring multiple modes of communication with a current contact list of staff, suppliers and agencies at all levels of government
- Reaching out to community partners to allow multiple types of healthcare facilities to participate in testing and training exercises
LiveProcess Emergency Manager is a proven system for healthcare emergency preparedness planning, mass notification and mobilization, real-time coordination and tracking. Hospitals and health systems, ambulatory centers, home health agencies, nursing homes, and public agencies use Emergency Manager to prepare for and respond to disaster events and for everyday coordination.
We’ve prepared a short self-assessment to help identify your organization’s readiness for the CMS emergency preparedness final rule. We’ll email your results and suggest resources you can use based on your current level of emergency preparedness.