Emergency Preparedness Training and Testing: CMS Rule

by | May 26, 2017

emergency-preparedness-training-testing-cms-ruleEmergency preparedness plans that seem great on paper can fall apart in practice. That’s why a crucial part of the CMS emergency preparedness rule is training and testing. Drills and exercises prepare your staff, service providers and volunteers for a disaster and give your organization’s leadership a chance to find problems in a low-stakes setting, ideally in a scenario that involves coordination with community partners.

4 requirements for training and testing for the CMS emergency preparedness rule

  • Create a well-organized, effective program that includes both initial training for new staff and recurring update sessions for existing staff to maintain a high level of awareness and exposure to the most current emergency preparedness policies and procedures. This education is not just for your employees — you need to include contract service providers and volunteers as well.
  • Provide annual refresher training to allow all staff to demonstrate their knowledge of policies and procedures, relative to their roles.
  • Conduct drills that demonstrate the healthcare organizations’ response under duress as well as familiarity with emergency management procedures to detect areas for improvement prior to an actual crisis situation.
  • Participate in community-based mock disaster drills, if available, to ensure community-wide coordination during a disaster. (For example, be a part of a coalition or region-wide emergency preparedness exercise that involves police, fire, health agencies, and health delivery organizations from your region.)

The basic requirements for complying with the CMS rule are straightforward. We’ll look at each element separately to find the important details:

Create a well-organized, effective training program for all staff

A key aspect of the CMS emergency preparedness training requirement is that all staff must participate in emergency preparedness training — no one is exempt, even if their roles aren’t usually related to emergency management. With a key goal of the CMS emergency preparedness rule being continuity of care delivery, it’s not just the emergency preparedness coordinator that needs to know what to do and how to respond in specific crisis and hazardous situations.

Cross-training is especially useful for emergency preparedness, since the usual means of fulfilling a role may be disrupted and alternate procedures must be followed instead. That said, facilities have flexibility in determining what kind of training is best suited to different roles in the hospital.

Provide annual refresher training for emergency preparedness

At a minimum, every staff member should receive initial training on the plan and annual training on updates to the plan generated by testing and review. Here again, CMS allows a great deal of discretion for facilities to determine the level of refresher training, and to determine how much emergency preparedness training is needed for each role.

Conduct emergency preparedness drills to test the emergency plan

Not surprisingly, this requirement caused the most concern for many of the commenters to the initial draft of the CMS emergency preparedness rule. Drills and exercises can be costly, and they demand many personnel hours from participants. Nevertheless, CMS resolved — and many respondents agreed — that testing was an indispensable part of emergency preparedness, one that no facility could afford to overlook.

The following are critical points to keep in mind when implementing or adapting a testing program:

Train for community collaboration during an emergency:  To meet the testing requirement, facilities may either conduct one full-scale community exercise annually and one tabletop exercise annually, or conduct two full-scale community exercises annually. (Note that a facility that experiences a disaster that requires activating its plan is exempt for one year.)

The full-scale exercise must be community-based unless a community exercise is not available, and facilities are encouraged to include community-based partners in all of their additional exercises where appropriate. Facilities are not required to plan and execute a community-wide exercise, only to participate in one to the extent their facility would contribute in an emergency situation if the whole community/town is impacted. Facilities may define for themselves the community that is most relevant to their risk assessment.

Document for analysis and improvement: All emergency preparedness testing exercises and emergency events must be thoroughly documented, not only to demonstrate compliance, but more importantly to provide an opportunity for review and improvement. Leadership and emergency managers can analyze results after the fact and revise the emergency plan as needed.

After Action Reports (AARs) are not mandated, but the CMS rule notes that AARs provide a user-friendly template. This is especially true for AARs that are automatically generated by an emergency management solution.

Seek out coalition and community partners for joint drills: The CMS emergency preparedness rule notes that the expense and labor of testing exercises can be mitigated when facilities work together. Smaller facilities in particular may want to work within a larger system to ease some of the burden. That participation applies to all aspects of emergency preparedness planning, but it is especially advantageous for training and testing.

Facilities that have no community partners (e.g., facilities in very remote areas) may substitute testing that is only facility-wide, but all facilities benefit from coordinating with local, state, or regional emergency management agencies as a part of their testing process.

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What’s next?

Read the LiveProcess Emergency Manager datasheet.

This post is part of a series on the CMS emergency preparedness rule. If you’ve missed any part of the series, I encourage you to explore the following:

LiveProcess Emergency Manager aligns with each element of the CMS emergency preparedness rule. Learn how LiveProcess structures your emergency plans, serves as a virtual command center in a crisis, and provides a central repository for information sharing and critical assets.

terry-zysk-100x100Terry Zysk, CEO of LiveProcess, has more than two decades of experience in leading organizations that provide innovative solutions to the healthcare industry.