CMS Updates Emergency Preparedness Guidance

The Centers for Medicare and Medicaid Services (CMS) has issued memorandum QSO-21-15-ALL providing updated guidance (Appendix Z) for all providers covered by the Emergency Preparedness requirements.

In February 2019, CMS added “emerging infectious diseases” (EIDs) to the definition of all-hazards approach in Appendix Z, as CMS determined that it was critical for facilities to include planning for infectious diseases within their emergency preparedness program. In light of events such as the Ebola virus and Zika, CMS believes that facilities should consider preparedness and infection prevention within their all-hazards approach, which covers both natural and man-made disasters.

CMS is expanding the Emergency Preparedness Interpretive Guidelines to further expand on best practices, lessons learned, and planning considerations for EIDs in light of the COVID-19 Public Health Emergency (PHE).

CMS has updated the guidance to reflect some of the following changes:

• Expanded surveyor guidance to ensure that Life Safety Code and health surveyors communicate/collaborate surrounding potential deficiencies for alternate source energy.
• Added new definitions based on Burden Reduction Final Rule expansion of acceptable testing exercises.
• Clarified expectations surrounding documentation of emergency program.
• Added additional guidance/considerations for EID planning stages to include personal protective equipment (PPE).
• Added additional guidance on risk assessment considerations to include EIDs.
• Included planning considerations for surge and staffing.
• Expanded guidance for surge planning to include recommendations for natural disaster surge planning and EID surge planning.
• Included recommendations during PHEs for facilities to monitor Centers for Disease Control and Prevention (CDC) and other public health agencies, which may issue event-specific guidance and recommendations to health care workers.
• Clarified existing guidance surrounding use of portable generators and maintaining temperature controls.
• Added additional planning considerations for hospices during EID outbreaks.
• Expanded guidance and added clarifications related to alternate care sites and 1135 Waivers.
• Expanded guidance and best practices related to reporting of facility needs, facility’s ability to provide assistance, and occupancy reporting.
• Revised guidance related to training and testing program, as Burden Reduction Rule extensively changed these requirements, especially for outpatient providers.
• Provided clarifications related to testing exercise exemptions when a provider/supplier experiences an actual emergency event.

Contact: Elliott Frost, efrost@leadingageny.org, 518-441-8761