State Survey Agency (SA) and Regional Office (RO) surveyors are now fully trained and ready to ask the tough questions during your healthcare organization’s regular CMS  (Centers for Medicare and Medicaid Services) survey cycle. For nursing homes, it’s every year; for hospitals, it’s every three. Yours may be somewhere in between.

So, will your facility pass the looming survey for compliance with CMS’ Emergency Preparedness (EP) Rule? Good question. The November 15 deadline for adhering to the Congress-approved ruling has come and gone, but some organizations—namely those that are smaller and more specialized—might still be struggling to comply. And, somewhat justifiably.

Of the 17 types of healthcare providers named in the CMS EP Rule, home health agencies (HHAs), rural health clinics (RHCs) and other facilities may find they do not have the resources, time, budget or emergency preparedness expertise to understand (or implement) emergency plans that adequately support the four elements of the requirement.

Per CMS, these elements are:

  • Risk Assessment, Emergency Operations and Continuity Planning (Include but not limited to):
    • Vulnerability to hazards likely in a geographic area
    • Care-related emergencies
    • Equipment and power failures
    • Interruption in communications, including cyber attacks
    • Loss of all/portion of facility, supplies, workforce
    • Disruption of normal operating procedures
    • Plan is to be reviewed and updated at least annually
  • Communications Plan
    • System to contact staff, including patients’ physicians, other necessary persons
    • Well-coordinated within the facility, across health care providers, and with state and local public health departments and emergency management agencies.
  • Policies and Procedures
    • Complies with Federal and State laws
    • Supports emergency operations efforts and continuity of operations
  • Training, Testing and Plan Maintenance
    • Demonstrates capabilities through scenario-based exercises
    • Methods for identifying areas of improvement and taking corrective actions
    • Maintain plan and at a minimum update annually

Fortunately, CMS-compliant online emergency planning software like that provided by BOLDplanning