Now that the November 15, 2017 deadline for compliance with the CMS Emergency Preparedness Rule has passed, what’s next? Will surveyors come knocking at your healthcare facility’s door? Could your organization soon lose its Medicare and/or Medicaid funding if it does not meet the ruling’s basic requirements for an Emergency Plan, Policies and Procedures, Communications, and Training and Testing?

The short answer is yes. The long answer is also yes. These things could happen, but probably not right away.

It seems unlikely that CMS will be sending surveyors out into the field to check for compliance with the Congress-approved ruling specifically. Surveys will most likely take place during the normal survey cycle, which, as Medicare- and Medicaid-funded providers know, varies based on the type of facility. As such, CMS’ visit (and their questions about adherence) should come as no surprise, and may not come in the near term.

Neither should the growing need for an all-hazards, community-based approach to emergency preparedness.