Details from the CMS Emergency Preparedness Requirements Call
October 19, 2016 02:54 PM
On October 5 the Centers for Medicare and Medicaid Services (CMS) held a telephone call to discuss the new requirements and revisions of the final rule on Emergency Preparedness. The phone call also covered how to plan for both natural and man-made disasters, while coordinating with other emergency preparedness systems.
As reported by NAHC, on September 8 the Centers for Medicare and Medicaid Services (CMS) finalized a rule creating emergency preparedness requirements for health care providers participating in Medicare and Medicaid. The rule, Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers, aims to improve patient safety and establish coordinated responses to natural and man-made disasters. The rule requires all 17 provider and supplier types to plan for disasters and coordinate with federal, state, regional, tribal and local emergency preparedness systems.
While we encourage you to read or listen to the entire transcript, NAHC would like to draw your attention to a couple of points in the call.
Firstly, the Survey and Certification Group is in the process of developing the interpretive guidelines. The surveyors will use the interpretive guidelines and survey procedures in State Operations Manual (SOM), and the interpretive guidelines will assist in the implementation of the new regulation. CMS anticipates the interpretive guidelines will be complete by the spring of 2017. Unlike other Conditions of Participation, which, at times, are changes or added to existing appendices within the SOM, we are creating a whole new appendix and a whole new set of tags for surveyors for these requirements.
Facilities will have one year to come into compliance with the requirements and if, after one year, a survey finds non-compliance, the same general process of enforcement will occur as when other conditions of non-compliance are found, such as termination of the provider agreement.
CMS has refaced their emergency preparedness website to include some information related to the regulation, which they will continuously update with resources, such as provider checklists, sample plans, and example forms.
CMS does not specify exactly how a facility should have emergency plans documented and in what order. Upon being surveyed, a facility must be able to demonstrate that the plans exist and where they are located. The burden of proof is always with the provider.
On the issue of how these regulations will be monitored for compliance, CMS notes that each provider and supplier will be surveyed for compliance with the requirements as currently carried out with any other existing CoPs. CMS does not require the facility’s plans be approved by State or local emergency officials, though the regulation does require coordination with State and local emergency officials, depending on the provider type. It is within the discretion of the provider if they want their emergency preparedness plans to be approved by State/local officials.
Providers have one year to implement these requirements and there will be no waivers for the requirements for compliance. The same process for termination as any of the other CoPs will be followed.
You can read the full transcript of the call right here.
The new emergency preparedness rule is 600 pages long and the penalties for non-compliance, as noted above, are considerable. What home care and hospice providers need is detailed information on exactly what must be done and when it must be done in order to comply with the new rule. Fortunately, NAHC has you covered. We will be holding a pre-conference workshop to address all your concerns and answer your questions about the new emergency preparedness guidelines.
The pre-conference workshop is very reasonably priced at $250 for members and $350 for non-members. That’s not much compared to the potential cost of non-compliance with the new rule.
More information about the pre-conference workshop may be found here.
To register for the event go here.
Pre Conference Workshop
Sunday, October 23, 2016, 8 a.m. to noon (This pre-conference is 4 hours long and includes breakfast)
The NEW Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers
This interactive workshop, which places special emphasis on home-based care (including home health and hospice home and inpatient care) will assist agencies in understanding and executing the four major components of the regulation, which are:
Developing an Emergency Plan (ALL HAZARDS APPROACH): Providers must develop an emergency plan using an all-hazards approach focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies and disasters.
Establishing Organizational Policies and Procedures: Providers must develop and implement policies and procedures based on the emergency plan and risk assessment.
Developing and Maintaining a Communication Plan: Providers must develop and maintain a communication plan that complies with both federal and state law. Patient care must be well-coordinated within the facility, across health care providers and with state and local public health departments and emergency systems.
Conduct a Training and Testing Program: Providers must develop and maintain training and testing programs, including initial and annual trainings, and conduct drills and exercises or participate in an actual incident that tests the plan.
OBJECTIVES: At the conclusion of the session attendees will be able to:
Conduct a risk assessment (hazard vulnerability assessment)
Describe home health and hospice providers’ role in local healthcare coalitions
Secure a GETS/WPS card for communication during an event
Define surge capacity , patient classification, and patient transportation levels
Identify key areas of the organizational disaster plan that require revision or enhancement
SPECIAL NOTE: PACE programs are welcome to attend as this session is applicable to PACE as well.
Faculty: Barbara B. Citarella MS, RN, President, RBC Limited Healthcare & Management Consultants, Staatsburg, NY
Barbara Citarella is the CEO, President, and founder of the award winning national company RBC Limited, a healthcare and management company specializing in healthcare operations including home care and hospice. She has worked extensively with agencies in the areas of infection control, disaster preparedness, corporate compliance, accreditation, strategic planning and leadership.
Citarella was part of the Department of Homeland Security’s (DHS) committee to rewrite the DHS/FEMA Disaster Preparedness Guidelines for People with Special Needs. She also was recently appointed as the Chairperson of the National Ebola Taskforce. Barbara has served as a subject matter expert panel member on the pandemic flu for the CDC, AMA and AHRQ. She was a contributing member to the AHRQ’s document on “Home Health Care and the Pandemic Flu” released in 2008. She participated in the CDC Pandemic Workshop for Primary Practitioners and Long Term Care. She was a member of APIC’s (Association of Practitioners in Infection Control) Emergency Disaster Planning committee.
Citarella is internationally recognized for her expertise in disaster preparedness and infection control and has been appointed to several committees and panels of the Institute of Medicine of the National Academies. Citarella was appointed to serve as Co-Chairperson for the National Association’s Hurricane Katrina Task Force. She was the lead on the first national research project ever conducted on the home care and hospice industry’s response to the H1N1 Pandemic. Results were published 2011 in the American Journal of Infection Control, a peer reviewed journal.
Citarella is a professional registered nurse with a master’s degree in science, which she obtained from Pace University in New York where she served on the University’s Professional Advisory Board for the Lienhard School of Nursing. She is a founding member of the Mu Epsilon Chapter of Sigma Theta Tau, the International Honor Society of Nursing.