Recent changes to the Centers for Medicare and Medicaid's (CMS) Emergency Preparedness Final Rule ease several emergency preparedness requirements for most healthcare settings, with the exception of long-term care facilities (LTCs).
Yet, the intent of the Rule in establishing criteria for healthcare providers and suppliers to better prepare for and respond to natural and man-made disasters remains the same.
"Given the increasing frequency and intensity of natural and man-made disasters, hospitals and healthcare providers are taking a more proactive approach to emergency preparedness to safeguard patient care and human resources, maintain business continuity, and protect physical resources―preparedness measures continually emphasized by the Rule," said Eric Chetwynd, General Manager of Healthcare Solutions at Everbridge.
The four key elements of the CMS Emergency Preparedness Rule are highlighted below, along with the new requirements for inpatient and outpatient provider and supplier types that will go into effect November 29, 2019, per the Omnibus Burden Reduction (Conditions of Participation) Final Rule.
Risk Assessment and Emergency Planning
CMS continues to emphasize the importance of building a plan that's based on an all-hazards risk assessment to ensure healthcare providers are ready to respond to a full spectrum of emergencies and disasters.
In addition, per the Omnibus Reduction Final Rule, CMS has modified the following:
- Inpatient and outpatient facilities are required to conduct a biennial review of their emergency programs instead of an annual review. However, long term facilities are still required to review their emergency program annually.
- Emergency plans are no longer required to include documentation of efforts to contact local, tribal, regional, state and federal emergency preparedness officials and a facility’s participation in collaborative and cooperative planning efforts.
- Assessment and development of an integrated all-hazards plan should include emerging infectious disease (EID) threats such as Ebola and Zika Virus.
Policies and Procedures
A core tenant of the rule that hasn't changed, requires the development of policies and procedures that are based on an all-hazards risk assessment and support the emergency plan as well as the communications plan. This is intended to help healthcare providers identify gaps and realistically develop a response that best leverages staff and resources.
- These policies will ensure a system to track all on-duty staff and sheltered patients/clients during and after a crisis event.
- Strategies should align with the risk assessment to ensure the continuation of care.
Robust Communication Plans
How hospitals and healthcare providers communicate during an emergency―from contacting all staff and patients and coordinating care to collaborating with emergency personnel and state and local health officials―will define the immediate and long-term impact on a hospital and the surrounding community and patients it serves.
Per the Rule, facilities should continue to develop and maintain an emergency communication plan to coordinate patient care within the facility, across healthcare providers and with state and local public health departments and emergency management systems. This includes:
- Assurances that even during tenuous times, there’s a method of sharing information and medical documentation between providers in accordance with HIPAA and all pertinent rules.
- Attention should be given to patient care/occupancy throughout the facility(s) and with any transportation of patients.
Training and Testing
CMS continues to emphasize the following as part of their training and testing efforts to ensure a coordinated, collaborative response:
- Develop and maintain a training and testing program for all new and existing employees.
- All employees must demonstrate knowledge of emergency procedures, evacuation routes/location, and patient instructions.
- Coordinate drills with local, tribal, regional, state, or federal emergency preparedness officials to ensure an integrated approach during a disaster or emergency.
In addition, the following updates have been made to the training and testing requirement per the Omnibus Reduction Final Rule.
- The training requirement is lessened from annual to biennial for providers and suppliers with the exception of LTCs, which are still required to provide annual training.
- Inpatient providers/suppliers may choose the type of emergency preparedness test they conduct – either a community-based full-scale test, or a facility-based test. These facilities must administer two emergency preparedness tests per year.
- Outpatient providers/suppliers may test for emergency preparedness once, rather than twice, a year.
"On a daily basis, hospitals are focused on delivering the best care, regardless of the circumstance," said Chetwynd. "Conducting a risk assessment and ensuring that plans and procedures are reinforced by a strong communications strategy, training and practice drills, are core to compliance but also to ensuring the best response and recovery should a disaster occur."
To ensure you have the best response and are CMS-ready, access Everbridge's New CMS Emergency Preparedness Guide.