The Real world CMS
Emergency Preparedness Rule
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The Real World CMS Emergency Preparedness Rule – 10 degrees and dropping By Scott Aronson
It is 9:30pm on a Saturday in January – temperature is 17 degrees. The area has experienced a power outage due to a substation failing. Your emergency power has not activated and only battery back-up lighting is working. The fire department arrives first and informs you that power will be out for a minimum of 6-8 hours. A technician arrives and identifies that there is no easy fix to the switchgear. The City Emergency Manager and DPH communicate to the Nursing Supervisor that you will need to evacuate your building if you can’t get the generator to work. It is too dangerous to the residents to remain with temperatures dropping quickly and no short-term primary or back-up power options.
Could this happen to you? Even hardened structures like the Atlanta Airport (busiest in the world) were down for almost a full day without commercial power and emergency power (December 17, 2017). Think about the effects: resident evacuation and tracking; continuous communications with families, staff, the media, and receiving facilities; and building recovery with the potential for internal flooding due to pipes freezing.
Due to isolated issues like this and larger area-wide disasters, the Centers for Medicare & Medicaid Services (CMS) implemented the “Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers”. The regulation required full compliance by November 15, 2017. This is the single largest change to the emergency preparedness requirements in long-term care in our recent history.
The Emergency Preparedness Program (EPP) includes four (4) core elements. The emphasis is to ensure adequate planning for both natural, man-made and technological disasters (loss of utility systems, etc.), and coordination with local, regional, state and federal agencies (community partners). The 4 elements include: 1 Annual Risk Assessment & Emergency Planning (all-hazards approach/Hazard Vulnerability Assessment) 2 Communication Plan 3 Policies and Procedures specific to the outcome of your risk assessments Continued on Page 2
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wow, I certainly feel as though I am a bit delayed in writing this. Unfortunately, when I think of the reasons why it is certainly not due to writers’ block! In fact, there is too much “mandatory reading” . By mandatory, I mean articles and CMS documents that are necessary in order for us to continue to thrive both in survey and payment regulations. Now that November 28th is past, I will take the time to reflect and observe but also to celebrate the holidays with our residents and staff. Training and education on industry changes are just as important as celebration and traditions are to our residents. we must remember that.
Please let us know what we can do to help better serve you with resources and information in this time of healthcare reform.
4 Training of all staff and leadership with testing of the plan via disaster exercises twice annually.
what really needs to be done? Every facility should be completing a thorough Hazard Vulnerability Assessment (HVA). You are unable to be prepared for a disaster if unsure of your level of readiness. Use the community partners to assist in this process by first looking internally at how prepared you are for a myriad of disasters and then establishing mitigation plans. It