CMS: Don’t Put off Newly Required Emergency Exercises

Medical facilities still have the better part of a year before the new emergency preparedness rule is implemented this fall, but they should not wait any longer to begin complying, CMS warned Friday in a memo to state survey agencies.

For hospitals, that means taking part in two exercises—including one that is “full-scale” and, preferably, a collaborative community effort—by the November 15 deadline.

“We realize that some providers and suppliers are waiting for the release of the interpretive guidance to begin planning these exercises, but that is not necessary nor is it advised,” David R. Wright, director of the CMS Center for Clinical Standards and Quality’s Survey and Certification Group, wrote in the memo, SC-17-21.

Failure to complete the exercise on time will result in a citation for noncompliance, Wright wrote. If a “full-scale, community-based exercise” is not possible, he added, then an individual facility should conduct an exercise on its own and document the circumstances that prevented a larger, more cooperative drill.

Each of the 17 categories of providers and suppliers subject to the new rule has its own set of emergency preparedness standards. That’s because the rule anticipates that each facility will have a role to play in an emergency situation, as CMS officials wrote in the Federal Register, discussing benefits of the final rule.

“Because we live under the threat of mass casualties occurring at anytime and anywhere with consequences that may be different than the day-to-day occurrences, the healthcare system must be prepared to respond to these events by working as a team or community system,” they wrote.

That level of mid-crisis cooperation requires a lot of pre-planning, which is why it is vital to practice not just as an individual facility but as a broader community, said Marge McFarlane, PhD, MT (ASCP), CHSP, CHFM, CJCP, HEM, MEP, CHEP, an independent safety consultant and principal of Superior Performance LLC in Eau Claire, Wisconsin.

“Everybody needs to be on the same page with the most current information, which is very difficult to do in the heat of battle,” McFarlane said during a recent HCPro webinar.

In a separate memo on Friday, SC-17-22, Wright wrote that CMS had been receiving numerous requests to explain the emergency preparedness requirements. That prompted CMS to offer another session through the Medicare Learning Network.

The hour-long session, which will discuss the rule’s training and testing requirements, is scheduled for Thursday, April 27, at 2:30 p.m. EDT. To register, visit https://blh.ier.intercall.com/.

More information is available at the CMS emergency preparedness rule webpage.