Agencies Need to Complete Emergency Preparedness Exercises by November 15

Posted on Thursday, April 13, 2017 8:51 PM

The Centers for Medicare and Medicaid Services (CMS) finalized the Emergency Preparedness Rule last November with an effective date of November 16, 2017. As a reminder, you need to contact your local and/or state emergency agencies and health care coalitions to determine if community-based emergency preparedness exercises will happen near the location of your agency.

According to a March 24 survey and cert memorandum to surveyors, if agencies do not undergo a survey on November 15, and they do not participate in two emergency preparedness exercises, then they could get cited for noncompliance.

Additionally, these exercises required from CMS’ new emergency preparedness regulation.

During an emergency preparedness training session on April 5, disaster preparedness expert Barbara Citarella, let a group of Maryland home health providers know that the federal Medicare agency expects providers to participate in a total of two community exercises, functional exercises and/or tabletop exercises.

CMS encourages providers “to partner with local and state emergency agencies and health care coalitions to conduct full-scale community exercises.”

However, the federal Medicare agency said that not all agencies and coalitions will have resources available or the ability to engage with all providers.

If it’s impossible for your agency to participate in community-based exercise by November 15, CMS requires you to complete an individual facility based exercise.

“Providers must document the circumstances as to why a full-scale, community-based exercise was not completed,” the memo states. “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.”

Note that agencies should the final rule closely prior to conducting exercises, Citarella warned meeting attendees.

Some providers already might participate in annual exercises, Citarella noted, but those exercises might not meet requirements outlined in the rule.

For example, the emergency preparedness regulation defines a tabletop exercise as “a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.”

“CMS is moving full-steam ahead,” Citarella says. “That has been made very clear.”

Aside from being an upcoming requirement, emergency preparedness training is invaluable because, “It can save lives — that’s the bottom line,” she says.

CMS’ rule, “Emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers,” makes clear that agencies must take an all hazards approach toward preparedness, Citarella says.

The rule states that the following things are required in emergency plans:
• Chemical
• Biological
• Natural
• Radiological
• Explosion/trauma

Citarella also recommends the following items should be listed in agencies emergency plans:
• Cybersecurity
• Active shooter
• Civil unrest

Prepare for the emergency prep rule by doing the following:
• Understand your exercise options
• Contact your local health department
• Produce a plan that provides action following your exercise
• Request additional guidance from CMS

For the full article, please see the April 17, 2017 Home Health Line Edition.

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