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CMS Proposed Emergency Preparedness Rule

Posted on January 27, 2016 at 5:15 PM

On December 27, 2013, the Center for Medicare/Medicaid Services published a proposed rule that strengthens emergency preparedness regulations for 17 different healthcare provider types to include hospitals and long term care facilities. The changes have been proposed as the existing CMS regulations pertaining to emergency preparedness have been found to be lacking in sufficient depth to ensure healthcare facilities are actually prepared when disaster strikes. This rule is rumored to be released as a “final rule” with unknown modifications in the first quarter of 2016.

The proposed rule is based on the four foundations of risk assessment and planning, policy and procedure, communication planning, and training and testing. For those facilities who are Joint Commission accredited, the changes (save a few) should not be terribly burdensome, but those who are going from the old CMS requirements to the revised ones, will have quite a bit of work to do.

The challenge will be to build an effective emergency preparedness program, rather than to just check off a few requirements and call it good. Building a program takes time and energy and most importantly focus, direction, and teamwork. Emergency preparedness is a “team sport”, not to be undertaken by one person, but as a team; a team of the leadership in the facility who all have a part to play if preparedness is to be achieved.

Some tips for those who would be starting at square two (you all have at least some sort of plan to start with);

1. Create an emergency preparedness team comprised of your leadership who is led by, or at least accountable to, the facility administrator. Meet every two weeks. Pass out parts of the plan to be worked on and brought back to the committee for review and approval. Stay focused and motivated. It could take a year to get this thing done.

2. Don’t recreate the wheel. There have been lots of smart people working on templates and tools for the last many years. A few internet searches and you can find some great work out there. Fill in the blanks and add to as necessary. Your plan does not have to be long to be effective, just make sure they key points are there and your plan is workable and effective.

3. Join your local or regional healthcare coalition. They are your partners in crime. Folks that you need to have relationships with at the local and regional level. They are your conduit to resources when you need them, communication systems, information during events, and a way to satisfy your community exercise requirement. Healthcare coalitions are forming partnerships now and would love for you to be a part of that.

Preparedness is not a sprint, it is a marathon. If it were easy, everyone would have accomplished it. It is a challenge in our already busy worlds and schedules, but when the time comes and you need your plan, it will certainly be worth every bit of time and effort invested.


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