Medicare and Medicaid Programs: Emergency Preparedness Requirements

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The following article provides information about the Centers for Medicare &
Medicaid Services (CMS) final rule regarding emergency preparedness.

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Elizabeth E. Hogue, Esq.

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Fax: (877) 871-9739

Twitter: @HogueHomecare

Medicare and Medicaid Programs: Emergency Preparedness Requirements

The Centers for Medicare and Medicaid Services (CMS) has issued final rules
regarding emergency preparedness. The final rule will be published in the
Federal Register on September 16, 2016, and will be effective on November
15, 2016. Providers are not, however, required to comply until November 15,
2017. The four core elements of all providers' emergency preparedness
programs that must focus on continuity of operations, not recovery of
operations, must include the following:

Risk assessment and emergency planning

Providers are required to perform a risk assessment that uses an
"all-hazards" approach prior to developing and implementing emergency plans.
An all-hazards approach is an integrated approach to emergency preparedness
planning that focuses on capacities and capabilities that are critical to
preparedness for a full spectrum of emergencies or disasters. Risk
assessment must be used to identify essential components of emergency plans
specific to providers' and suppliers' geographic locations. Examples
include equipment and power failures, interruptions in communications,
including cyber-attacks, and interruptions in the normal supply of
essentials, such as water and food.

Policies and procedures

Providers and suppliers must develop and implement policies and procedures
that support the successful execution of emergency plans and that address
risks identified in risk assessments.

Communication plans

Providers and suppliers must development and maintain emergency preparedness
communication plans that comply with federal and state laws. Communication
plans must include systems to contact appropriate staff, patients' treating
physicians and other necessary persons in a timely manner to ensure
continuation of patient care in a safe and effective manner.

Training and testing

Providers and suppliers must also develop and maintain an emergency
preparedness training and testing program. At a minimum, training and
testing programs must include training for new and existing staff in
emergency preparedness procedures as well as annual refresher trainings.
Staff must demonstrate knowledge of emergency procedures during annual
training sessions. Providers and suppliers must also conduct drills and
exercises to test emergency plans in order to identify gaps and areas for

These requirements will be mandated for suppliers through Conditions of
Participation (CoPs) and conditions for coverage (CfCs), if applicable. CMS
will also issue interpretive guidelines to assist providers to comply.

Here we go again! Yet another set of new regulations with which providers
and suppliers must comply. Although compliance is not required for more
than a year, now is surely the time to get started.

CCopyright, 2016. Elizabeth E. Hogue, Esq. All rights reserved.

No portion of this material may be reproduced in any form without the
advance written permission of the author.
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