The Department of Health and Human Services released the anticipated update to the national preparedness requirements for Medicare and Medicaid participating providers and suppliers on September 16, 2016. The goals of the new requirements are to assist all groups to increase patients’ safety during emergencies and ensure more coordinated response to natural and man-made disasters with federal, state and local emergency preparedness systems.
Evaluation of CMS Emergency Preparedness Regulations
HHS found that the past requirements for disaster preparedness fell short in ensuring agencies were prepared to help and product clients during emergencies. The new rule expands to include 17 types of providers and suppliers. The new requirements “establish a comprehensive, consistent, flexible and dynamic regulatory approach to emergency management and response.” The agency also acknowledges that each provider is part of a larger community and therefore encourages participation and coordination within communities, the state and across state lines if appropriate.
Three Essential Elements for Healthcare Services in an Emergency
The final rule identifies three essential elements it deems necessary to maintain healthcare services in an emergency.
- Safeguarding human resources
- Maintaining business continuity
- Protecting physical resources
In many ways, this approach tracks what other agencies and sectors are looking at when it comes to emergency preparedness and an “all hazards” approach.
Four Pillars of the Emergency Preparedness Program
To adequately plan for and address these three elements they identify four pillars of an emergency preparedness program.
- Risk assessment and emergency planning based on an “all-hazards” approach. This approach assists the facility in identifying those hazards that are of greatest risk to occur and those that create the greatest impact for the clients the facility serves.
- Implement Policies and procedures to support the risk assessment and emergency plan.
- Establish a communication plan for appropriate and necessary persons in case of an emergency.
- Implement training and testing programs, including but not limited to drills and exercises. Initial and ongoing training are the best way to ensure that the staff is ready to respond if an emergency should occur.
Emergency Preparedness Requirements
Facilities will need to meet the new requirements beginning in November 2017. During the ensuing months, all facilities should be reviewing the Final Rule in depth, evaluating their current plans based on the new requirements and working toward closing any deficits identified.