Several emergency preparedness experts shared their concerns regarding providers’ ability to meet compliance with emergency preparedness (EP) requirements during a May 17 interview with Modern Healthcare’s Steven Ross Johnson. The Centers for Medicare & Medicaid Services (CMS) published the final rule on September 16, 2016, mandating that facilities—including skilled nursing facilities, nursing homes, home health agencies, and hospice facilities—meet the new requirements by November 15 of this year.
In Johnson’s interview, experts share their belief that “providers who already meet the Standards of Care for Disaster Preparedness and Response set by the Joint Commission should be well-positioned to meet the new CMS regulations.” However, in a call with CMS on Thursday, April 27, 2017, the agency was unable to provide an answer regarding whether the Joint Commission’s standards for emergency preparedness would be considered compliant with CMS’ EP standards, pending the publication of the EP final rule’s Interpretive Guidelines.
Johnson’s interview includes thoughts from Nancy Foster, vice president of quality and patient safety for the American Hospital Association: “I think hospitals themselves feel like they’re in better shape in terms of coming into compliance because of that leg up. But long-term care and hospice facilities, as well as ambulatory surgical sites, home health agencies and dialysis centers, would face ‘a much heavier lift.’”
CMS has said these guidelines will be published in the spring of 2017, but they have yet to be seen. The agency has repeatedly warned providers, however, not to wait until their publication to start creating their EP programs.
Another worry for smaller long-term care facilities is cost. The CMS has estimated that the total cost for providers to be in compliance could be more than $370 million in the first year, and $370 million for each year after that.
In CMS’ April call, the agency confirmed that providers must meet the following requirements by the November deadline in order to continue receiving Medicare/Medicaid funding:
- All of the EP staff training requirements
- Participation in a full-scale exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based exercise.
- Conduct an additional exercise that may include, but is not limited to the following:
- A second full-scale exercise that is individual, facility-based.
- A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
Experts interviewed in Johnson’s article further warn providers that it seems unlikely CMS will extend the EP requirements deadline.