1. New CMS Emergency Preparedness Rule
Focus on Outpatient and Dialysis Providers

2. 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.

3. How will the CMS Rule be enforced?
November 15, 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

4. 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.

5. 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

11. 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

12. 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.

13. 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

14. HAZARD VULNERABILITY ANALYSIS “HVA”
Natural
Technological
Human
Hazardous Materials

15. 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

16. 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

17. 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!

18. 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

19. 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

20. EXERCISE PARTICIPATION AND COORDINATION
DOCUMENTATION OF
EXERCISE PARTICIPATION AND COORDINATION

21. News from CMS….

22. 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.

23. 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!

24. 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: certification/surveycertemergprep/emergency-prep- rule.html

25. 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.
Certification/SurveyCertificationGenInfo/Downloads/Surve y-and-Cert-Letter pdf
CMS Training and Testing Clarification Letter-- see link below.
Certification/SurveyCertificationGenInfo/Downloads/Surve y-and-Cert-Letter pdf