September is National Preparedness Month and CMS is Getting Involved By Establishing New Emergency Preparedness Requirements for Medicare and Medicaid Health Care Providers.
The Centers for Medicare & Medicaid
Services (CMS) has issued a final rule to establish consistent emergency
preparedness requirements for health care providers participating in Medicare
and Medicaid, stating that the regulation will increase patients’ safety during
emergencies and ensure more coordinated response to natural and manmade
disasters.
“Over the past several years, and
most recently in Louisiana, a number of natural and manmade disasters have put
the health and safety of Medicare and Medicaid beneficiaries – and the public
at large – at risk. These new requirements will require certain participating
providers and suppliers to plan for disasters and coordinate with federal,
state tribal, regional, and local emergency preparedness systems to ensure that
facilities are adequately prepared to meet the needs of their patients during
disasters and emergency situations,” the agency’s Sept. 8 news release stated.
“Situations like the recent flooding
in Baton Rouge, Louisiana, remind us that in the event of an emergency, the
first priority of health care providers and suppliers is to protect the health
and safety of their patients,” said CMS Deputy Administrator and Chief Medical
Officer Dr. Patrick Conway, M.D., MSc. “Preparation, planning, and one
comprehensive approach for emergency preparedness is key. One life lost is one
too many.”
“As people with medical needs are cared for in increasingly diverse settings, disaster preparedness is not only a responsibility of hospitals, but of many other providers and suppliers of health care services. Whether it’s trauma care or long-term nursing care or a home health service, patients’ needs for health care don’t stop when disasters strike; in fact, their needs often increase in the immediate aftermath of a disaster,” added Dr. Nicole Lurie, HHS’ assistant secretary for preparedness and response. “All parts of the health care system must be able to keep providing care through a disaster, both to save lives and to ensure that people can continue to function in their usual setting. Disasters tend to stress the entire health care system, and that’s not good for anyone.”
“As people with medical needs are cared for in increasingly diverse settings, disaster preparedness is not only a responsibility of hospitals, but of many other providers and suppliers of health care services. Whether it’s trauma care or long-term nursing care or a home health service, patients’ needs for health care don’t stop when disasters strike; in fact, their needs often increase in the immediate aftermath of a disaster,” added Dr. Nicole Lurie, HHS’ assistant secretary for preparedness and response. “All parts of the health care system must be able to keep providing care through a disaster, both to save lives and to ensure that people can continue to function in their usual setting. Disasters tend to stress the entire health care system, and that’s not good for anyone.”
CMS reports that it reviewed current
Medicare emergency preparedness regulations for providers and suppliers and
concluded the regulatory requirements were not comprehensive enough to address
the complexities of emergency preparedness; they did not address the need for
communication to coordinate with other systems of care within cities or states;
contingency planning; or training of personnel. So the final rule requires
Medicare and Medicaid participating providers and suppliers to meet these four
industry best practices:
1.Emergency plan: Based on a risk
assessment, develop an emergency plan using an all-hazards approach focusing on
capacities and capabilities that are critical to preparedness for a full
spectrum of emergencies or disasters specific to the location of a provider or
supplier.
2.Policies and procedures: Develop and
implement policies and procedures based on the plan and risk assessment.
3.Communication plan: Develop and maintain
a communication plan that complies with both federal and state laws.
4.Training and testing program:
Develop and maintain training and testing programs, including initial and
annual training, and conduct drills and exercises or participate in an actual
incident that tests the plan.
CMS said these standards are
adjusted to reflect the characteristics of each type of provider and supplier.
For example, outpatient providers and suppliers such as ambulatory surgical
centers and end-stage renal disease facilities won’t be required to have
policies and procedures for provision of subsistence needs; hospitals, critical
access hospitals, and long-term care facilities will be required to install and
maintain emergency and standby power systems based on their emergency plan.
In response to comments, CMS removed
the requirement for additional hours of generator testing, added flexibility to
choose the type of exercise a facility conducts for its second annual testing
requirement, and decided to allow a separately certified facility within a
health care system to take part in that system’s unified emergency preparedness
program.
The regulations will take effect on
November 15, 2016. Healthcare providers
and suppliers affected by the rule must comply and implement all regulations
one year after the effective date. More specific information about the
Emergency Preparedness Rule can be found here.
Providers/Suppliers Facilities Impacted by the Emergency Preparedness Rule:
1. Hospitals
2. Religious Nonmedical Health Care Institutions (RNHCIs)
3. Ambulatory Surgical Centers (ASCs)
4. Hospices
5. Psychiatric Residential Treatment Facilities (PRTFs)
6. All-Inclusive Care for the Elderly (PACE)
7. Transplant Centers
8. Long-Term Care (LTC) Facilities
9. Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)
10. Home Health Agencies (HHAs)
11. Comprehensive Outpatient Rehabilitation Facilities (CORFs)
12. Critical Access Hospitals (CAHs)
13. Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services
14. Community Mental Health Centers (CMHCs)
15. Organ Procurement Organizations (OPOs)
16. Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
17. End-Stage Renal Disease (ESRD) Facilities
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