Center for Medicare & Medicaid Services(CMS) Emergency Preparedness Final Rule

Cristian Gonzalez Regional Learning Specialist Region 8 Public Health Emergency Preparedness and Response Benton-Franklin Health District

Who is Region 8 Public Health?

Region 8 PHEPR Region 8 Public Health Emergency Preparedness and Response serves as a primary resource to local health jurisdictions and healthcare systems in planning and preparing for, responding to, and recovery from public health emergencies in Benton, Franklin, Walla Walla, and Yakima Counties.

What we do Region 8 Healthcare Coalition Lead and Response Agency Plan Development and Maintenance Training and Education Resource Tracking and Coordination Exercise Design, Development, Facilitation, and Evaluation And More “as assigned”

CMS Emergency Preparedness Final RULE

CMS Emergency Preparedness Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. Published September 16, 2016 Applies to all 17 Medicare and Medicaid provider and supplier types. Rule must be implemented November 15, 2017

Goal for the rule Address systemic gaps Establish consistency Encourage coordination

Four Provisions for All Provider Types Emergency Preparedness Program Risk Assessment and Planning Policies and Procedures Communication Plan Training and Testing 8

Who is affected Inpatient Outpatient Critical Access Hospitals Hospices Hospitals Intermediate care facilities for individuals with intellectual disabilities (ICF/IID) Long term care Psychiatric Residential Treatment Facilities Religious Nonmedical Health Care Institutions Transplant Centers Ambulatory Surgical Centers Clinics-Rehab, Public Health agencies as providers of Outpatient Physical Therapy and Speech Language pathology services Community Mental Health Centers Comprehensive Outpatient Rehabilitation Facilities End-Stage Renal Disease Facilities Home Health Hospices Organ procurement Organizations Programs of All Inclusive Care for the Elderly Rural Health Clinics and Federally Qualified Health Centers

Conditions of Participation Conditions of Participation (CoPs) and Conditions for Coverage (CfCs) are health and safety regulations which must be met by Medicare and Medicaid- participating providers and suppliers. Note: Each separately certified facility must meet the CoP on it’s own. Upon survey each facility is required to be able to demonstrate how they have met the requirements.

All-Hazards Approach: An all-hazards approach is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters, including internal emergencies ,a man-made emergency, or natural disaster. 7

Risk Assessment and Planning-Emergency Plan Develop an emergency plan based on a risk assessment. Perform risk assessment using an “all-hazards” approach, focusing on capacities and capabilities. Update emergency plan at least annually. 9

Policies and Procedures Develop and implement policies and procedures based on the emergency plan and risk assessment. Policies and procedures must address a range of issues including subsistence needs, evacuation plans, procedures for sheltering in place, tracking patients and staff during an emergency. Review and update policies and procedures at least annually. 10

Communication Plan Develop a communication plan that complies with both Federal and State laws. Coordinate patient care within the facility, across health care providers, and with state and local public health departments and emergency management systems. Review and update plan annually. 11

Training and Testing Program Develop and maintain training and testing programs, including initial training in policies and procedures. Demonstrate knowledge of emergency procedures and provide training at least annually. Conduct drills and exercises to test the emergency plan. 12

Training & Testing Program Definitions Facility-Based: The emergency preparedness program is specific to the facility. Facility-based includes, but is not limited to, hazards specific to a facility based on the geographic location; Patient/Resident/Client population; facility type and potential surrounding community assets Community definition is broad: includes planning with traditional partners such as EMS, other healthcare facilities, public health, healthcare coalitions and emergency management agencies. 17

Training & Testing Program Types Table-top Exercise (TTX): Can be used to assess plans, policies, and procedures. Drill: Test a single operation of function. Functional Exercise: Test and evaluate capabilities, functions, plans, and staffs of ICS. Full-Scale Exercise: Involve both functional and Tactical Ops/“boots on the ground” response. 18

Training & Testing Program

Training & Testing Requirements Facilities are expected to meet all Training and Testing Requirements by the implementation date (11/15/17). Participation in a full-scale exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based exercise. Conduct an additional exercise that may include, but is not limited to the following: A second full-scale exercise that is individual, facility-based. A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan. 20

Final Rule- Requirements Vary by Provider Type Outpatient providers are not required to have policies and procedures for the provision of subsistence needs. Home health agencies and hospices required to inform officials of patients in need of evacuation. Environmental Policies and Requirements- Temperature Controls, Emergency and Standby Power Systems depending on your provider type. 14

CMS Rule and HPP: Opportunities for Engaging Community Partners HPP anticipates that health care entities that have not previously engaged in community preparedness will seek to do so through participation in HCCs. HCCs will function as an accessible source of preparedness and response best practices as newly engaged provider types adapt to the new requirements.

HCC EP assistance Request Obtaining copies of the coalition or regionally conducted hazard vulnerability analysis or risk assessments (or to be included in future assessments). Identifying examples of plans, policies, and procedures that are frequently used or accepted by other entities within those coalitions. Engaging in training and exercises conducted by coalitions or coalition members. Providing basic information on emergency preparedness and healthcare system preparedness.

HCC Technical Assistance Developing emergency plans. Developing standard policies and procedures. Developing a communication plan that integrates with the HCC’s communications policies and procedures.  Plan for and conduct education, trainings, and exercises at the regional/HCC level, but not facility level. The HCC should carefully consider whether equipment costs directly support the cooperative agreement capabilities and coordination of patient care.

Resources Interpretive Guidelines (IG) State Operations Manual https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Downloads/Advanced-Copy-SOM-Appendix-Z-EP-IGs.pdfCMS Website CMS Emergency Preparedness Rule www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html ASPR TRACIE- Technical Resources ASPR TRACIE https://asprtracie.hhs.gov/ bParati- Healthcare and Medical Readiness Resources bParati bparati.com/Healthcare-Emergency-Preparedness-Risk-Assessment-and-Planning-Resources?mc_cid=c25600bcb5&mc_eid=9ffb2ca056 Region 8 PHEPR Healthcare Coalition

CMS: Wrapping it Up What happens next? Intent of the Rule: Establish National Emergency Preparedness Requirements Under development for over 2 years Key Date: November 17, 2017 Implementation Requires implementation of four component standards: Risk Assessment and Emergency Planning Policies and Procedures Communications Plan Training and Testing Program The Rule applies 17 different Provider and Supplier types: Inpatient and Outpatient ASPR TRACIE is regularly updating CMS Resources at your Fingertips Interpretive Guidelines (IG): State Operations Manual Health Care Coalitions: Local MVR (Most Valuable Resource) Engaging new partners and providing coordination and organization within Region 8 There is no funding being provided to groups and facilities impacted by the rule to assist in compliance. What happens next?

Compliance Facilities are expected to be in compliance with the requirements by 11/15/2017. In the event facilities are non-compliant, the same general enforcement procedures will occur as is currently in place for any other conditions or requirements cited for non-compliance. Training for surveyors has been underway and survey has been released for reference. 18

Questions? Cristian Gonzalez Regional Learning Specialist WA Region 8 Public Health Emergency Preparedness and Response 7102 W. Okanogan Place Kennewick, WA 99336 p:509.460.4532   f.509.460.4535 C.509.820.8817   http://www.bfhd.wa.gov/bio/bio.php     cristiang@bfhd.wa.gov

Thank you