The Centers for Medicare & Medicaid Services (CMS) recently issued information on training and testing requirements under its final rule establishing new emergency preparedness requirements for Medicare and Medicaid-participating health care facilities. While there are 17 providers and suppliers* that are impacted by the CMS Emergency Preparedness Rule, the requirements vary somewhat by type of provider.

CMS has provided a quick reference table for inpatient and outpatient providers which summarizes the content requirements for the emergency plan, policies and procedures (P&P), communication plan, training and testing, and additional requirements, as applicable. The table is not an exhaustive list of the requirements outlined in the Final Rule published on September 16, 2016 in the Federal Register, but can be utilized as a template for ensuring essential elements are being addressed in the various plans and educational programs. Note that there were some technical corrections to the Final Rule published on November 16; however, the effective date for implementation remains as November 15, 2017. The CMS webpage provides other resources such as a transfer agreement and a link to resources available at ASPRTRACIE.

One requirement that is causing angst for many organizations concerns the completion of training and testing exercises. Providers have some flexibility in choosing the type of exercise it conducts for its second annual testing requirement, but providers may have some questions about the initial training or about whether participation in a system unified emergency preparedness program is permitted. Be sure to review the frequently asked questions and definitions on the CMS website.

Many providers have expressed to Compass that they are waiting for the release of the interpretive guidance to begin planning these exercises; however, CMS has indicated that organizations who have not completed these exercises, or any other requirements of the Final Rule, will be cited for non-compliance if this is discovered during their survey.

CMS will host a provider call on the final rule and its training and testing requirements, on April 27 at 2:30 pm ET/1:30 CT/12:30 MT/11:30 am PT. For details on the provider call and to register, go to MLN Connects. Space is limited, so be sure to register early.

*Facilities Impacted by the Emergency Preparedness Rule

  1. Hospitals
  2. Religious Nonmedical Health Care Institutions (RNHCIs)
  3. Ambulatory Surgical Centers (ASCs)
  4. Hospices
  5. Psychiatric Residential Treatment Facilities (PRTFs)
  6. All-Inclusive Care for the Elderly (PACE)
  7. Transplant Centers
  8. Long-Term Care (LTC) Facilities
  9. Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)
  10. Home Health Agencies (HHAs)
  11. Comprehensive Outpatient Rehabilitation Facilities (CORFs)
  12. Critical Access Hospitals (CAHs)
  13. Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services
  14. Community Mental Health Centers (CMHCs)
  15. Organ Procurement Organizations (OPOs)
  16. Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
  17. End-Stage Renal Disease (ESRD) Facilities

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