CMS Releases Information to Assist Providers and Suppliers in Meeting the New Training and Testing Requirements of the Emergency Preparedness Requirements

PUBLISHED: Apr 3, 2017
Relevant to: Ambulatory Care, Behavioral Health, Clinical Lab, Home Health, Hospice, Hospitals, Long Term Care, Medical Office

The Centers for Medicare and Medicaid Services has issued a memorandum with information intended to assist providers and suppliers in meeting the new training and testing requirements within the Emergency Preparedness Requirements final rule that was published on September 16, 2016 and which became effective on November 15, 2016. According to the final rule, all affected providers and suppliers must meet all of the applicable requirements of the rule by the implementation date of November 15, 2017.

In the memorandum, CMS clarifies the providers and suppliers have are expected to have completed the “exercises” per the training and testing requirements in each standard (d) of the Final Rule, by the implementation date of November 15, 2017.

Further, according to CMS, providers and suppliers should:

  • Seek out and to participate in a full-scale, community-based exercise with their local and/or state emergency agencies and health care coalitions and to have completed a tabletop exercise by the implementation date.
  • Note 1: Providers and suppliers are not advised to wait for the release of the interpretive guidance to begin planning these exercises.
  • Note 2: Providers and suppliers that are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance.
  • CMS understands that it may not be feasible for all agencies and coalitions to engage with all providers and suppliers and that a full-scale, community-based exercise may not always be possible for some providers and suppliers. In these instances CMS expects those who have been unable to complete a full-scale exercise by November 15, 2017 to complete an individual facility-based exercise and document the circumstances as to why a full-scale, community-based exercise was not completed. 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.

In order to further assist providers and suppliers in meeting the requirements of the new Final Rule, CMS has developed a website that contains various resources such as checklists, links to emergency preparedness agencies, planning templates and many other valuable resources. The website also provides a State-by-State listing of Health Care Coalitions. The information can be found at the link provided below.

The Emergency Preparedness requirements apply to all 17 provider and supplier types. Each provider and supplier will have its own set of Emergency Preparedness regulations incorporated into its set of conditions or requirements for certification. Over the next several weeks StayAlert! will provide reviews of key aspects of the rule for various provider types.

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