In November 2017, Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers, went into effect requiring healthcare facilities to adequately plan for both natural and man-made disasters, and coordinate with federal, state, tribal, regional and local emergency preparedness systems in order to be reimbursed by Medicare or Medicaid. The CMS rule requires hospitals, critical access hospitals, ambulatory surgical centers, long-term care facilities, intermediate care facilities, and rural health clinics to have an emergency preparedness (EP) program that entails four critical segments:
- risk assessment and planning
- policies and procedures
- a communication plan
- training and testing
Although the rule requires risk assessment and planning, guidance on conducting, implementing, and revisiting a comprehensive risk assessment plan is lacking. To help address “the how” NFPA developed Using NFPA 1300 as a Tool to Comply with CMS Requirements for an Emergency Preparedness Program, a free resource for the healthcare industry. Three of the major steps outlined in NFPA 1300 Standard on Community Risk Assessment and Community Risk Reduction Plan Development directly correlate to the CMS EP rule (conducting a risk assessment, developing a CRR plan, and implementing and evaluating the plan).
CMS encourages healthcare providers and suppliers to review policies and emergency procedures on an annual basis. As part of this yearly review, healthcare authorities are encouraged to re-assess:
- food and water needs
- essential utilities, generators, and potential backup resources delivery challenges
- evacuation plans and sheltering in place
- tracking patients and staff; safety and security needs
- communications, resources and assets
- clinical support and staff roles
- exterior connections and communications
- new construction at or near a facility
- roads and bridges that could be closed; alternate routes for first responders
“The only thing that is constant is change; and with September being Emergency Preparedness Month it is a great opportunity for healthcare facilities to review protocol and see how they can update and improve their EP plans,” Rich Bielen, NFPA Principal Engineer and the author of the white paper said.
Using NFPA 1300 as a Tool to Comply with CMS Requirements for an Emergency Preparedness Program can be downloaded for free; the document can also be accessed on the ASPR TRACIE CMS Resource page. For additional resources for healthcare facilities, visit nfpa.org/cms.