CMS Emergency Preparedness: Training & Testing
Original publication date: May 26, 2017. Updated July 11, 2019, to reflect revisions proposed September 2018.
Emergency 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. Emergency preparedness 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 regular 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 training and testing to comply with CMS emergency preparedness 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.
For example, employees need to know:
- Location of the emergency plan
- Training they have received on the emergency plan
- Types of emergency exercises in which they have participated
- Their specific roles in an emergency
- How to report an emergency and how to activate the plan if needed
Use this checklist to ensure not to miss anyone when planning your emergency preparedness training and testing program:
- All executive leadership personnel will need an overview of their roles and responsibilities.
- All incident command system staff will need ICS role-specific training.
- All responder staff will need role-specific training.
- All other staff and volunteers will need general emergency preparedness training.
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 refresher training for emergency preparedness
Every staff member should receive initial training on the plan and regular training on updates to the plan generated by testing and review. CMS allows a great deal of discretion for facilities to determine the level of refresher training appropriate to their facility, and to determine how much emergency preparedness training is needed for each role. Currently, training review is required annually. However, under changes proposed September 2018, review would be required biennially unless the plan had been substantially revised.
All training must be documented. Additionally, facilities should expect the CMS emergency preparedness surveyor to ask selected employees to demonstrate their ability to carry out their appointed role in the emergency plan during a survey.
Conduct emergency preparedness drills to test the emergency plan
Not surprisingly, the requirements around emergency preparedness drills and exercises 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 the plan was an indispensable part of emergency preparedness, one that no facility could afford to overlook.
There are two main types of exercises: discussion-based exercises and operations-based exercises. Discussion-based exercises could be seminars, workshops, table-top exercises (TTX) or games, for example. Operations-based exercises could be drills, functional exercises or full-scale exercises (FSE).
The following are critical points to keep in mind when implementing or adapting an emergency preparedness training and testing program:
Train for community collaboration during an emergency: To meet the the current CMS emergency preparedness 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.) Revisions currently under consideration would adapt the rule to allow more choice regarding the type of testing, and would permit outpatient providers to participate in only one exercise annually.
The full-scale exercise must be community-based, unless a community exercise is not available. Facilities are encouraged to include community-based partners in all of their exercises where appropriate. Facilities are not required to plan and execute a community-wide exercise themselves, only to participate in one to the extent their facility would contribute in an emergency situation if the whole community or town were impacted. Facilities may define for themselves the community that is most relevant to their risk assessment.
Start simple if your facility is new to exercise planning. Enlist support and assistance from experienced exercise planners, such as local emergency management agencies, regional healthcare coalitions and community partner facilities. CMS requires community involvement, and reaching out for help supports the CMS requirement. Be sure to document all community involvement in your emergency preparedness training and testing program.
As your planning may start simple and mature over time, consider the following checklist to develop your training & testing program:
- Test specific objectives related to the plan
- Test a variety of objectives over time
- Build upon prior exercises or plan activations
- Increase in complexity as your plan matures, from simple discussion-based exercises to full-scale operations-based exercises
Document for compliance, analysis and improvement: All emergency preparedness testing exercises and emergency events must be thoroughly documented, both to demonstrate compliance, and more importantly to provide an opportunity for review and improvement. Leadership and emergency managers can analyze results after the exercise or event and revise the emergency plan for improvement.
After Action Reports (AARs) are not mandated, but the CMS emergency preparedness rule notes that AARs provide a user-friendly template. This is especially true for AARs that are automatically generated by an emergency management solution, such as LiveProcess Emergency Manager.
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, and it is especially advantageous for emergency preparedness 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.
LiveProcess Emergency Manager is a proven system for healthcare emergency preparedness planning, mass 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.
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:
- Are You Ready for the CMS Emergency Preparedness Final Rule?
- Start Here: Hospital CMS Emergency Preparedness
- CMS Emergency Preparedness Regulations Overview
- All-Hazards Approach: Risk Assessment for CMS Rule
- Hospital Readiness for Likely Threats: CMS Emergency Preparedness
- Policies and Procedures for Continuity: CMS Emergency Preparedness Rule
- Communication Plan, Collaboration and Continuity: CMS Emergency Preparedness Rule
- Planning for Collaboration: CMS Emergency Preparedness
- CMS Home Health Emergency Preparedness