CMS Announces New Emergency Preparedness Requirements for Healthcare Organizations

By Katie Dwyer, MSPH, NACCHO Director

istock_000015594328medium1Earlier this month marked National Primary Care Week (October 3-7, 2016). This annual observance focuses on improving access and equity for all Americans, including those most medically vulnerable, usually using Medicare or Medicaid to cover their health needs.

When considering national preparedness requirements for recipients of these programs, the Centers for Medicare and Medicaid Services (CMS) recently released a final rule establishing preparedness requirements for Medicare and Medicaid providers and suppliers. Overall, the rule requires that adherence to the below listed standards, which must be implemented by November 2017:

  • Perform an all-hazards risk assessment and establish an emergency plan for the facility;
  • Develop and implement policies and procedures to execute the emergency plan;
  • Develop and maintain a communications plan to support continuity of operations and on-going patient care;
  • Train staff in emergency preparedness policies and procedures; and conduct drills and exercises to test emergency plans.

General Overview
CMS hosted a national call on October 5, 2016 to discuss the final rule and share information about technical assistance available to relevant stakeholders. A copy of the slides and a recording of the webinar are available here.

The rule applies to 17 categories of providers and suppliers, including public health agencies such as local health departments (LHDs) that provide clinical and health services (e.g. clinics, community mental health centers, outpatient physical therapy services). Even if an LHD does not provide clinical services, the agency may still have a role in implementing the requirements of the rule. For example, LHDs may provide guidance or partner with healthcare organizations to perform risk assessments, develop emergency plans, train staff, and conduct drills and exercises. Additionally, as more facilities seek to understand and implement the provisions of the rule, they may turn to LHDs and their local healthcare coalition for guidance, tools, and resources.

Available and Upcoming Resources
Although CMS will not provide additional funding to healthcare facilities to implement the requirements of the new emergency preparedness rule, other resources are available to LHDs and their healthcare partners. CMS will develop interpretive guidelines and training, expected to be released in early 2017, to assist providers and surveyors implement the requirements of the new regulation.

Further, the Assistant Secretary for Preparedness and Response (ASPR) will offer technical resources (e.g., tools, templates), technical assistance, and opportunities for peer-to-peer information exchange through the TRACIE program. NACCHO also has a publically accessible toolkit with a variety of vetted preparedness resources from health departments and partners, including example exercises and templates, communications plans, risk and hazard assessments, and training plans.

Healthcare coalitions, many of which receive federal funding through ASPR’s Hospital Preparedness Program, provide a structure for health departments and healthcare organizations to engage and leverage collective resources, expertise, and experience to implement the rule. Healthcare coalitions should engage healthcare entities not previously involved in community preparedness activities (e.g., risk assessments, planning, training, exercising) and serve as a source of information and best practices as providers seek to implement the new requirements. Conversely, healthcare coalitions will benefit from the engagement of additional provider types to achieve greater financial sustainability and produce more comprehensive preparedness and response plans. For more information about healthcare coalitions, visit the Hospital Preparedness Program website, or listen to a NACCHO-hosted webinar on healthcare coalition governance and sustainability.

NACCHO Wants the Local Perspective
NACCHO encourages LHDs to share their plan and how NACCHO can help their agency to engage with healthcare organizations their communities to implement these requirements. Please email comments, insight, examples or questions on which tools, resources, or technical assistance would be effective and helpful to carry out this rule from the local perspective.


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