The release of the much anticipated CMS Emergency Preparedness Rule generated many questions for healthcare providers and facility administrators who are now tasked with making adjustments to ensure compliance with the rule. In order to obtain more insight on the new regulations, we invited three industry experts to join us for a live chat, including Jackie Gatz, VP of Grant Management and Safety at Missouri Hospital Association, Bill Mangieri, Field Project Officer AT Department of Health and Human Services, and Doug Havron, VP of Health Preparedness at Intermedix.
During the hour-long chat, the panelists answered participant’s questions and address implementation concerns about the new CMS requirements. From that conversation, we have identified the top five takeaways outlined below.
- Meeting Basic Rule Requirements:
Doug Havron gave great advice on how to meet the basic rule requirements without duplicating efforts, stating, “What we would prefer to do is link back to our Emergency Preparedness Plan to the current policies and procedures that are in place. The best way to go about this from our experience is that you would link your policies and procedures to your emergency plans. This allows flexibility.”
- Being Prepared for Full-Scale Exercises:
When addressing a question about table-top exercises, Jackie Gatz emphasized the importance of full-scale exercises: “The rule requires two annual exercises. The first is a full-scale exercise and the second for inpatient providers. They have the option to conduct a second exercise annually of their choice. This can be a table-top exercise or another full-scale exercise. The only thing I would add further is that it is very important to document real-world events where the plan was put into action because that can provide exemption from a full-scale exercise requirement. Documentation of real-world events is critical.”
- Relying on Healthcare Coalition Resources:
With 480 healthcare coalitions and over 26,000 facilities that participate in them, Bill Mangieri spoke to the importance of using the resources available, “There is no requirement to participate in the healthcare coalition but I would highly encourage it to all providers, especially the ones who have not had to meet any of the requirements for emergency preparedness in the past. These organizations have developed an impressive and sophisticated strategy and structure that a new provider with no experience in healthcare emergency preparedness could plug and play into these existing healthcare coalitions.”
- Integrated health plans:
Instead of reinventing the wheel Doug Havron advised, “The rule specifically talks about integrated health plans, so if you are part of an integrated health plan or system you are required to have a couple of different activities, you are required to ensure the activities of your hazard venerability analysis and your emergency plan for example are completed at the facility type or at local level of responsibility.”
- Properly Documenting Information:
Ensuring continuity of operations was and is a huge foundational element for the Final Rule. Jackie Gatz addressed the focus on doing so with proper documentation, informing that “There is quite a bit of focus on medical documentation during and following the use of volunteers and staffing. As I reference that continuity of services that includes arrangements with other hospitals and providers, should operations cease at your organization to ensure that continuity of care can be provided to the patient population.”
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