CMS Final Rule on Emergency Preparedness
Hinman Straub, legislative counsel for LeadingAge NY, has provided an analysis of the CMS Final Rule on Emergency Preparedness. LeadingAge NY staff has previously shared the rule with members, and the analysis by Hinman Straub offers some guidance for members to consider in relation to the new requirements. As the rule is extensive, CMS has indicated that affected providers will have one year (Nov. 16, 2017) to be in compliance with the requirements.
The key components of the new requirements are as follows:
- Risk Assessment and Planning: All providers are required to conduct a comprehensive risk assessment utilizing an "all-hazards" approach, focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or
- disasters. All providers are required to develop an emergency preparedness plan that addresses the emergency events identified in the risk assessment, to be reviewed and updated annually.
- Policies and Procedures: All providers are required to implement policies and procedures based on the emergency plan and risk assessment, to be reviewed and updated annually.
- Communication Plans: All providers are required to develop and maintain an emergency communication plan to ensure coordination of patient care within the facility, across healthcare providers, health departments, and emergency systems. The final rule also requires providers to establish HIPAA-compliant methods of sharing patient information and keeping medical records readily available during an emergency. The communication plan must be reviewed and updated annually.
- Training and Testing: All providers are required to develop and maintain an emergency preparedness training and testing program that includes initial training on all emergency preparedness policies and procedures developed as a result of this rule. All providers are required to conduct drills and exercises to test emergency plans annually.
Additionally, the Medicare Learning Network (MLN) Emergency Preparedness Requirements Call will take place on Wed., Oct. 5th from 1:30 to 3 pm ET.
To register or for more information, visit MLN Connects Event Registration. Space may be limited, so participants should register early.
The Emergency Preparedness Requirements final rule established national requirements for Medicare and Medicaid providers. During this call, there will be a discussion of the new requirements and the revisions in the final rule, as well as how to plan for both natural and manmade disasters, while coordinating with other emergency preparedness systems. A question and answer session will follow the presentation.
Agenda:
- Provisions of the final rule
- Enforcement process
- Overview of available technical assistance
Contact: Elliott Frost, efrost@leadingageny.org, 518-867-8832