CMS finalizes rule to bolster emergency preparedness of certain facilities participating in Medicare and Medicaid

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The Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule became effective on November 15, 2016 with an implementation date of November 15, 2017.  This means that as of November 15, 2017, all affected providers and suppliers (which include FQHCs) must meet all of the applicable requirements of the rule.   The requirements include: develop an emergency/communication plan, conduct a hazard vulnerability analysis-including facility and community based, develop policy and procedures, conduct staff training  and testing of the emergency plan (FQHCs much conduct two exercises to test the emergency plan at least annually). 

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1. Participate in a full-scale exercise that is community-based or when a community based exercise is not accessible, an individual, facility-based.  

If the FQHC experiences an actual natural or manmade emergency that requires activation of the emergency plan, the FQHC is exempt from engaging in a community-based or individual, facility-based full-scale exercise for 1 year following the onset of the actual event.

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2. Conduct an additional exercise that may include, but is not limited to following:

A second full-scale exercise that is community-based or individual, facility-based, or a tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario and a set of problem statements, directed messages or prepared question designee to challenge an emergency plan.

 

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.

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CMS.GOV: https://www.cms.gov/newsroom/mediareleasedatabase/press-releases/2016-press-releases-items/2016-09-08.html

 

For questions or additional information, contact Janice Pirner (jpirner@mo-pca.org)                           

 

Additional Resources:

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• Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers:  https://www.federalregister.gov/documents/2016/09/16/2016-21404/medicare-and-medicaid-programs-emergency-preparedness-requirements-for-medicare-and-medicaid

 

• ASPR Technical Resources, Assistance Center, and Information Exchange (TRACIE): https://asprtracie.hhs.gov/cmsrule

 

• Surveyor Training in CMS Rule -- https://surveyortraining.cms.hhs.gov/pubs/ProviderTraining.aspx

 

• Crisis & Emergency Risk Communications by CDC:  https://emergency.cdc.gov/cerc/resources/index.asp

 

• FEMA Independent Study Program - https://training.fema.gov/is

 

• CMS After Action Report/Improvement Plan Template:  https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Templates-Checklists.html