If your healthcare facility is like others across the country, the clock is ticking. And, ticking fast. In less than 60 days – November 15, 2017 – you must comply with the Congress-approved CMS Emergency Preparedness Rule (Centers for Medicare and Medicaid, Federal regulations at 42 C.F.R. §§422.503 and 423.504). That is, if you want to continue receiving Medicare and Medicaid funding, or face other costly consequences. Read on to learn more about how the rule affects you, and some tips for achieving compliance in short order.
As a reminder, the ruling’s purpose is “to establish consistent emergency preparedness requirements for healthcare providers participating in Medicare and Medicaid, increase patient safety during emergencies, and establish a more coordinated response to natural and man-made disasters.” It covers a broad range of facilities, including hospitals, hospices, transplant centers, home health agencies, and Religious Nonmedical Health Care Institutions (RNHCIs). All must must meet the following four common and well-known industry best practice standards:
- 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.
- Policies and procedures: Develop and implement policies and procedures based on the plan and risk assessment.
- Communication plan: Develop and maintain a communication plan that complies with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems.
- Training and testing program: Develop and maintain training and testing programs, including initial and annual trainings, and conduct drills and exercises or participate in an actual incident that tests the plan.
Time is short.
An extension for CMS rule compliance does not appear likely. In fact, it seems even less so given the tragic death of eight long-term-care patients in a Hollywood, Florida facility following Hurricane Irma. This particular case, highly publicized by CNN,