Home Health

CMS updates emergency preparedness survey guidance and pandemic best practices

CMS released updated guidance for surveyors related to emergency preparedness requirements on Friday, March 26, incorporating changes to the rules in recent years and lessons learned from the pandemic.

The “Updated Guidance for Emergency Preparedness – Appendix Z of the State Operations Manual” detailed changes made through the Burden Reduction Rule (84 FR 51732) in September 2019.

An overview from CMS noted the regulatory changes in the rule included:

  • Emergency program: Decreasing the requirements for providers to conduct an annual review of their emergency program to a biennial review.
  • Emergency plan: Eliminating the requirement that the emergency plan include documentation of efforts to contact local, tribal, regional, state, and federal emergency preparedness officials and a facility’s participation in collaborative and cooperative planning efforts.
  • Training Requirement: Decreasing the training requirement from annually to every two years.
  • Testing Requirement: For outpatient providers, decreasing the requirement for facilities to conduct two testing exercises to one testing exercise annually.

Added guidance on infectious diseases

The update also includes expanded “interpretive guidance” regarding best practices on emerging infectious diseases (EIDs).CMS notes some of the new guidance surrounding EIDs is considered recommendations, not requirements.

According to CMS, the updated guidance:

  • Clarified expectations surrounding documentation of the emergency program.
  • Added guidance/considerations for EID planning to include personal protective equipment (PPE).
  • Added guidance on risk assessment considerations, to include EIDs.
  • Included planning considerations for potential patient surges and staffing needs.
  • Expanded guidance for surge planning due to natural disasters and EIDs.
  • Included recommendations during PHE’s for facilities to monitor Centers for Disease Control and Prevention (CDC) and other public health agencies, which may issue event-specific guidance and recommendations to healthcare workers.
  • Added planning considerations for hospices during EIDs outbreaks.
  • Expanded guidance and added clarifications related to alternate care sites and 1135 Waivers.
  • Expanded guidance on the identification and use of best practices related to reporting of facility needs, the facility’s ability to provide assistance and occupancy reporting.
  • Revised guidance related to training and testing program as the Burden Reduction Rule extensively changed these requirements, especially for outpatient providers.
  • Clarified testing exercise exemptions when a provider/supplier experiences an actual emergency event.