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This article was originally published on April 13, 2017. We will continue to update this article to keep you informed on the latest concerning Home Care & Hospice Emergency Preparedness.
UPDATE – July 7, 2017
Since the release of this article, the interpretive guidelines for emergency preparedness have been released.
CMS has issued a new Appendix to the Medicare State Operations Manual (SOM) specifically for emergency preparedness. This is Appendix Z of the SOM and it provides the interpretive guidelines for the Emergency Preparedness (EP) requirements that must be implemented by November 16, 2017.
The emergency preparedness requirements are focused on three key essentials necessary for maintaining access to healthcare during disasters or emergencies:
- safeguarding human resources
- maintaining business continuity
- protecting physical resources
The provider must use an all-hazard approach for EP planning.
Appendix Z provides significant details on guidelines and strategies for compliance across four core elements that CMS believes are central to an effective and comprehensive framework of emergency preparedness for the various Medicare and Medicaid participating providers and suppliers:
- Risk assessment and emergency planning:
- Policies and procedures
- Communication plan
- Training and testing
Below you will find a brief explanation of these four elements published in our original article. With the release of the interpretive guidance, providers should now carefully read the Appendix and begin meeting the finer details of the requirements. Specifically, the interpretive guidelines lay out the expectations for what should be included in a provider’s policies and procedures, what is expected in a communication plan and how some of the training and testing should be accomplished. There are requirements for what should be documented for EP and what information should be shared by home health and hospice providers with others in the community, what arrangements should be made for patients that may need care, staff in the field, etc. Additionally, there are specific requirements detailed for hospice inpatient units.
Appendix Z uses “E” tags to identify the individual standards surveyors will be reviewing for compliance with the EP Condition of Participation. These tags are in addition to the “G” tags home health agencies are reviewed under in determining compliance with the Medicare home health conditions of participation and the “L” tags used for hospice agencies during survey.
HPS has created a detailed table for Home Health and Hospice providers to assist our Alliance members in managing the EP information.
Alliance members can access these tables by clicking here. If you would like to access these tables and receive concrete clinical, billing, and operational information from one unprecedented source click here to signup for the HPS Alliance.
Emergency Preparedness Requirements
The Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule became effective on November 15, 2016, with an implementation date of November 15, 2017. All home health and hospice providers must meet the requirements of the rule by this date. A new condition of participation will be added for home health providers at §484.22(d) and for hospice providers at §418.113(d)(2) with provider being assessed as part of the Medicare certification/recertification survey process.
While most providers are aware of the fact that there are new requirements to comply with as of November 15, 2017, many providers have yet to begin work on their emergency preparedness plan. Those organization not accredited by one of the three accrediting organizations (AO) – Accreditation Commission for Health Care (ACHC), Community Health Accreditation Partner (CHAP), The Joint Commission (JC) – likely have a significant amount of work to complete between now and November 15.
There are four required elements to the emergency preparedness program home health and hospice providers must meet.
1. Risk assessment and planning – agencies will need to perform a risk assessment that uses an “all-hazards” approach prior to establishing an emergency plan. The “all-hazards” risk assessment will be used to identify the essential components to be integrated into the facility emergency plan. An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters. This approach is specific to the location of the organization and considers the particular types of hazards most likely to occur in their areas. These may include but are not limited to:
- care-related emergencies;
- equipment and power failures;
- interruptions in communications, including cyber-attacks;
- loss of a portion or all of a facility; and,
- interruptions in the normal supply of essentials, such as water and food.
2. Policies and procedures – agencies will need to develop and implement policies and procedures that support the successful execution of the emergency plan and risks identified during the risk assessment process
3. Communication plan – agencies will need to develop and maintain an emergency preparedness communication plan that complies with both federal and state law. Patient care must be well-coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management agencies and systems to protect patient health and safety in the event of a disaster.
4. Training and testing – agencies will need to develop and maintain an emergency preparedness training and testing program. A well-organized, effective training program must include initial training for new and existing staff in emergency preparedness policies and procedures as well as annual refresher training. The organization must offer annual emergency preparedness training so that staff can demonstrate knowledge of emergency procedures. The organization must also conduct drills and exercises to test the emergency plan to identify gaps and areas for improvement.
Recently, CMS released a memo from the Survey and Certification Group to remind all providers that they must meet all requirements of the emergency preparedness rules by the implementation date of November 15, 2017, and to assist providers in meeting these requirements. Specifically, many providers have asked whether they will be expected to have completed the “exercises” per the training and testing requirements. The answer is YES! Providers should not wait for the interpretive guidance of the new emergency preparedness condition of participation to be released. Providers must act NOW!
CMS is using this recent memo to provide some resources to providers in meeting these training and testing requirements. Providers should be aware that CMS is expecting that they seek out and participate in a full-scale, community-based exercise with their local and/or state emergency agencies and health care coalitions and to have completed a tabletop exercise by the implementation date. A link to a listing of coalitions, state-by-state, is provided in the memo and via links in the Resources section below. CMS does understand that providers and coalitions may not have the resources necessary for a full-scale exercise. In such cases, CMS expects those who have been unable to complete a full-scale exercise by November 15, 2017, to complete an individual facility-based exercise and document the circumstances as to why a full-scale, community-based exercise was not completed. The documentation should include what emergency agencies and or health care coalitions the provider or supplier contacted to partner in a full-scale community exercise and the specific reason(s) why a full-scale exercise was not possible.
Again, those organizations meeting the standards of the AOs are meeting the requirements of the new emergency preparedness condition of participation. However, now is a good time for these providers to review their emergency preparedness plan against CMS’ requirements. Home health and hospice providers are not required to be accredited, and there are many resources available to these providers for developing their emergency preparedness plans. We have listed some of these resources below for your convenience.
Please contact us with your questions.
- This site has many updated resources in the Downloads section of the page including a link to Health Care Coalitions and sample forms.
- The two main areas that providers will be interested in are Threat and Hazard Identification and Risk Assessment and Comprehensive Preparedness Guide for Developing and Maintaining Emergency Operations Plans.
- Another resourceful document is the Homeland Security Exercise and Evaluation Program (HSEEP) document.
- This is the HHS Healthcare Emergency Preparedness Information Gateway and has many resources providers will find valuable including the CMS Emergency Preparedness Resources at Your Fingertips document.
Your state and national home health and hospice provider associations are also great resources as many are holding webinars and workshops on the topic of emergency preparedness.