New CMS Emergency Preparedness Rule Focus on Outpatient and Dialysis Providers

What is the new CMS Rule? Purpose: To establish national emergency preparedness requirements, consistent across provider and supplier types. Outlines emergency preparedness Conditions of Participation (CoPs) & Conditions for Coverage (CfCs) CoPs and CfCs are health and safety standards all participating providers must meet to receive certificate of compliance Applies to 17 provider and supplier types Different emergency preparedness regulations for each provider type Bottom line: Providers and Suppliers that wish to participate in Medicare and Medicaid – i.e. the nation’s largest insurer – must demonstrate they meet new emergency preparedness requirements in rule.

How will the CMS Rule be enforced? November 15, 2017- surveying for compliance begins Same enforcement process as with any other health and safety standard in the Condition of Participation or Conditions for Coverage. * These new regulations are a condition or requirement of participation in Medicare/Medicaid *Title XVIII of the Social Security Act

Auditing and enforcement How will rule be audited? Compliance monitoring Use IGs and State Operations Manual State Survey Agencies (SSAs) Accreditation Organizations (AOs) CMS Regional Offices (ROs) Checklists for surveyors and State Agencies, as well as for impacted providers and suppliers are in development. SCG developing web-based training for surveyors and providers and suppliers . Consequence for not complying? Same process for other CoPs and CfCs  termination of agreement with Medicare & Medicaid.

Four core elements of CMS rule Emergency Plan Based on a risk assessment Use an all- hazards approach to risk assessment Update plan annually Policies & Procedures Develop based on risk assessment and emergency plan Must address: subsistence of staff and patients, evacuation, sheltering in place, tracking patients and staff Review/Update annually Communications Plan Complies with Federal and State laws Coordinate patient care within facility, across providers, and with state and local public health and emergency management Annual update Training & Exercise Program Develop training program, including initial training on policies & procedures Train annually Conduct drills and exercises: Full-Scale community based exercise annually and additional exercise for some facility types

FQHCs Annual Hazard Vulnerability Assessment Annual Full Scale exercise that is community based Additional Exercise- Tabletop Safe evacuation from the facility Train volunteers and those under service contracts - annually Means for providing information about the general condition and location of patients under facilities care Communication plan Staff Name & contact information for volunteers Integrated Healthcare System

Dialysis Annual Hazard Vulnerability Assessment Annual Full Scale exercise that is community based Additional Exercise- Tabletop Policies to address: Shelter in Place Evacuation Patient orientation- emergency preparedness training Staff demonstrate knowledge of informing patients include: What to do, where to go, whom to contact, how to disconnect themselves from dialysis machine, patient care staff maintains current CPR etc.

Develop Emergency Plan, Policies, and Procedures Conduct a facility specific hazard assessment or “HVA” Community specific hazards in area (flood, earthquake) Facility hazards (utilities, cyber attacks) Develop policies and procedures that address the identified risks/hazards Review and update policies and procedures annually

HAZARD VULNERABILITY ANALYSIS “HVA” Natural Technological Human Hazardous Materials

Real alerts or events are recorded on one tab of the Excel sheet Real alerts or events are recorded on one tab of the Excel sheet. Results of all real and assessed risk information roll up into a “top 10” final report

Annual Exercise requirements Conduct one FULL SCALE EXERCISE annually Participate in a community based exercise Actual events count but you MUST DOCUMENT Conduct an additional exercise of the facility’s choice - can be a tabletop exercise Bottom line: More staff time will be needed to conduct an annual full-scale exercise

What is a Full Scale Exercise Staff participation to demonstrate knowledge of emergency procedures Activating plans Moving people and equipment We will help you understand how to do a full-scale exercise!

Real Life Event Can be used instead of Exercise If your facility experiences an actual natural or man- made emergency or disaster that requires activation of the emergency plan Annual requirement for testing is not measured by calendar year but will be measured from the date of the last actual emergency event or the date the exercise/testing took place

Documentation: Make it count Exercise or real event must be documented Remember to include: After Action Report /Improvement Plan Photos Sign-in Sheets Forms used during exercise or event Updates to your emergency plan Letter from county’s Disaster Healthcare Coalition

EXERCISE PARTICIPATION AND COORDINATION DOCUMENTATION OF EXERCISE PARTICIPATION AND COORDINATION

News from CMS….

Additional Exercise- Tabletop Tabletop exercise includes a group discussion led by a facilitator Uses a narrated, clinically relevant emergency scenario Participants answer questions based on a scenario and your emergency plan Earthquake, active shooter, internal fire/flood, evacuation, etc.

How can we help you? Meet exercise requirements- Full-scale and tabletop exercise November disaster exercise Attend Coalition meetings! Learn how to do your HVA- Today April 20th And other topics throughout the year Ask us to review your facility’s emergency plan Resources for tabletops, plan development and more!

How do I learn more about the requirements? Participate in Webinars/Attend trainings Participate in Santa Barbara’s Disaster Healthcare Coalition Read the FAQ’s on CMS webpage: https://www.cms.gov/medicare/provider-enrollment-and- certification/surveycertemergprep/emergency-prep- rule.html

How do I learn more about the cms requirements? REGISTER TODAY for the CMS MLN Webinar on Thursday, April 27, 2017 Time: 2:30-3:30 PM EST .  The  focus  of the webinar is on Training and Testing Requirements.  Click link below for details about the webinar and to register today, seats  are limited. https://www.cms.gov/Medicare/Provider-Enrollment-and- Certification/SurveyCertificationGenInfo/Downloads/Surve y-and-Cert-Letter-17-22.pdf   CMS Training and Testing Clarification Letter-- see link below. https://www.cms.gov/Medicare/Provider-Enrollment-and- Certification/SurveyCertificationGenInfo/Downloads/Surve y-and-Cert-Letter-17-21.pdf