1. Implications for providers and local emergency management
CMS Preparedness Rule
Implications for providers and local emergency management

2. “Know them before you need them” “Local Emergency Management may not speak 100% Local Healthcare and Local Healthcare may not speak 100% Local Emergency Management”

3. How does the rule affect local EM
Noting is “REQUIRED” (CMS only dictates requirements to funded facilities but…
Providers may reach out to you seeking
Technical Assistance (Best Practices)
Assistance with Hazard Identification (Regional HVA)
Plans and Policies (How do they work with you?)
Participation in Exercises & Trainings
Local Emergency Management is not compelled to participate with facilities
Facilities must document attempts to reach out to local EM. If localities don’t participate, providers have other options (e.g. Local Public Health/Healthcare Coalitions)
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

4. How does the rule affect local EM (Cont.)
Local Emergency Management is not required to certify plans. Consider a certification disclaimer such as these many not meet CMS certifications.
Expect increased outreach from Healthcare facilities in the forms of letters, s, and calls on the subject so they can document they attempted contact.
Home care agencies are required to provide local emergency management lists of persons who may be stuck in home after emergency. Rule does not dictate what local emergency management does with this information, just that the Home care agency should share it.
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

5. How does the rule affect local EM (Cont.)
Ruling has plenty of EM speak but Healthcare Administration may not typically know this lingo. Local Emergency Management may way to be proactive by approaching facilities and asking if they have questions about the exercise requirements. Larger facilities with corporate backing appear to be in better shape than smaller ones across the country.
Local Emergency Management should develop standard level of service/participation to requesting facilities
Standard One Page
Issuance will build relationship, clarify role, maintain a level of standardization.
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

6. Role of VDH Office of Licensure and Certification State Survey Agency
Responsible for Surveys
Will not provide resources/training
Local Health Departments
Expected to maintain relationships and communications with healthcare facilities in jurisdiction
Available for Technical Assistance
Partner with Regional Healthcare Coalitions
Situational Awareness of Healthcare Facilities (Hospitals, LTC, Dialysis) in jurisdiction.
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

7. Cost of Compliance CMS predictions $373 million in the first year
$25 million each year after
Government is not providing funding to assist with compliance
How did CMS arrive at these numbers? Took salaries of impacted employees x hours involved in compliance x number of facilities

8. Origins of the Rule
Rule has been in development since shortly after Hurricane Katrina in 2005 (Office of the Inspector General’s 2006 post Hurricane Katrina Report):
Healthcare emergency plans were not comprehensive
Insufficient collaboration between healthcare facilities and local emergency management
Inconsistent levels of preparedness
Inconsistent standards for preparedness
Breakdowns in patient care
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

9. Examples of problem areas:
One facility in Georgia had a facility transfer agreement with another facility and during Hurricane Matthew tried to evacuate and found their receiving facility had closed five years previously so they had to contact local emergency management to come up with another plan during the event.
Due to staff turnover people who write emergency operations plan may leave and without verification, updating, and exercising these plans can fall through the cracks.

10. CMS Final Rule Goals Address systemic gaps Establish consistency
Encourage coordination
During the development of this rule, CMS took into consideration the findings of the 2006 post Katrina report from the Office of the Inspector General, along with reports generated following other major public health emergencies – including 9/11, 2001 anthrax attacks, 2009 H1N1 pandemic, and Hurricane Sandy. Analysis of these reports informed the 3 overarching goals of the CMS preparedness regulation
1. Address systemic gaps - It was concluded that current emergency preparedness requirements are not comprehensive enough to address the complexities of the actual emergencies.
2. Establish consistency - Central to this approach is to develop and guide emergency preparedness and response within the framework of our national healthcare system.
3. Encourage coordination – Requirements also encourage providers and suppliers to coordinate their preparedness efforts within their own communities and states as well as across state lines, as necessary, to achieve their goals.

11. CMS Key Focus Areas Safeguarding Human Resources
“people are our most important assets”
Maintaining Business Continuity
Healthcare facilities are critical to community resilience”
Protecting Physical Resources
Infrastructure must be operational to function”

12. Rule is in effect and clock is ticking.
Timeline
Rule became effective November 16, 2016
Rule requirements must be implemented by providers by November 15, 2017
In the event facilities are non-compliant, the same general enforcement procedures will occur as is current in any other conditions or requirements cited for non-compliance.
Rule is in effect and clock is ticking.
The new disaster Rule is in response to the Office of the Inspector General’s 2006 post Hurricane Katrina report. The OIG review examined the experiences of selected nursing homes in five Gulf Coast States during hurricanes on the completeness of their emergency preparedness plans:
94% met Federal standards for emergency plans
80% had sufficient emergency training
However, despite having a plan and training, 100% of the sampled SNF experienced disaster problems whether they evacuated or sheltered in place. Some of the issues from the OIG report: contracts were not honored, lengthy travel times, host facilities that were unavailable or inadequately prepared, inadequate staff, insufficient food and water, administrators and staff often did not follow their emergency plan, emergency plans often lacked provisions, and lack of collaboration between State & local emergency entities. CMS concluded that the current regulatory requirements were not comprehensive enough, so the new requirements will mandate certain preparedness standards. Further, emphasis is placed on preparedness planning (rather than response to a disaster) and one comprehensive approach across the continuum of health care providers to ensure coordination and communication.

13. Who does this rule apply to?
Rule applies to 17 provider and supplier types who wish to participate in Medicare and Medicaid. To get specific complete list of local facilities go through Healthcare Coalition.
The threshold question in determining whether or not this CMS rule applies to a facility is:
Does a facility have to comply with other Conditions of Participation? If YES, the rule applies.
Compliance is determined by survey

14. Survey Procedures – Example for E-0004
•Verify the facility has an emergency preparedness plan by asking to see a copy of the plan. • Ask facility leadership to identify the hazards (e.g. natural, man-made, facility, geographic, etc.) that were identified in the facility’s risk assessment and how the risk assessment was conducted. • Review the plan to verify it contains all of the required elements • Verify that the plan is reviewed and updated annually by looking for documentation of the date of the review and updates that were made to the plan based on the review

15. Full List of Providers (chart)

16. Full List of Providers (text only)
Hospitals
Religious Nonmedical Health Care Institutions
Ambulatory Surgical Centers
Hospices
Psychiatric Resident Treatment Facilities
All-Inclusive Care for Elderly
Transplant Centers
Long-Term Care Facilities
Intermediate Care Facilities for Individuals with Intellectual Disabilities
Home Health Agencies
Comprehensive Outpatient Rehabilitation Facilities
Critical Access Hospitals
Clinics, Rehabilitation, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services.
Community Mental health Centers
Organ Procurement Organizations
Rural Health Clinics and Federally Qualified Health Centers.
End-State Renal Disease Facilities

17. Four Requirements for All Provider Types
Risk Assessment and Planning
Policies and Procedures
Communication Plan
Training and Testing
Emergency Preparedness Program
The providers/suppliers listed in the previous slide are required to meet four core elements with specific requirements adjusted based on the individual characteristics of each provider and supplier.
Risk Assessment and Planning – develop an “all hazards” emergency plan based on a risk assessment
Policies and Procedures – Develop and implement policies and procedures based on the emergency plan and risk assessment
Communication Plan – Develop and maintain an emergency preparedness communication plan that complies with federal, state, and local laws. One key feature is that patient care must be coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management systems.
Training and Testing – Facility staff will have to demonstrate knowledge of emergency procedures and provide training at least annually. Facilities must also conduct drills and exercises to test the emergency plan.

18. Risk Assessment and Planning
Perform risk assessment using an “all-hazards” approach focusing on capacities and capabilities. Different than NFPA 99 (fire/life safety risk assessment)
Risk assessment to address:
Care-related emergencies
Equipment and Power failures
Interruption in Communications, including cyber attacks
Loss of all/portion of facility
Loss of all/portion of supplies
CMS has encouraged the Kaiser Permanente HVA tool for Healthcare
The first element, risk assessment and planning. Each provider is required to develop an emergency plan based on a risk assessment. The risk assessment must be documented and use an all-hazards approach. Providers are expected to consider business functions that should continue, risks that the provider is likely to confront, contingencies, the location of the provider, and also to determine whether arrangement with other providers is necessary to ensure continuity of care. The emergency plan must also include strategies to address events identified in the risk assessment, plans for evacuating or sheltering in place, and also arrangements for working with other providers in the area. The plan must address the patient population, continuity of operations, succession planning, and operations. So, for example, with addressing operations, we would expect a facility to address the number of beds that they have available, the level of care that the facility provides, and the availability of staff and supplies during an emergency. With regard to succession planning, we would expect the provider to address issues such as lines of authority and also to ensure that the plan can be implemented promptly and efficiently. And then, finally, there must be a process for cooperation and collaboration with local, regional, State, or Federal emergency preparedness officials to ensure an integrated approach. In response to public comments received after the initial draft, a change was made to allow a provider that is part of a health care system consisting of multiple separately certified health care facilities to have one unified and integrated emergency preparedness program. This exception would apply to DaVita and Fresenius, for example. The integrated emergency plan, as well as the required policies and procedures, must be developed in a manner that takes into account each separately certified facility’s unique circumstances, patient populations, and services offered. In addition, a risk assessment must be conducted for each separately certified facility in the system. It should be noted that each separately certified facility must meet the previously defined Conditions of Participation on its own. So integrated health systems are encouraged to leverage resources and to develop plans at the corporate level, but those plans must address the specific and unique nature of each separately certified facility within the system.

19. Risk Assessment and Planning Cont.)
Develop an emergency plan based on the risk assessment.
Key elements:
Integrated approach – shows capacity to address a broad range of emergencies (not every disaster can be identified).
Addresses both Sheltering-in-Place / Evacuation
Continuity-of-care/Business Continuity (Mutual Aid)
Collaboration with local/regional/state Emergency Management agencies
Plan must be reviewed, updated, and signed annually by facility.
The first element, risk assessment and planning. Each provider is required to develop an emergency plan based on a risk assessment. The risk assessment must be documented and use an all-hazards approach. Providers are expected to consider business functions that should continue, risks that the provider is likely to confront, contingencies, the location of the provider, and also to determine whether arrangement with other providers is necessary to ensure continuity of care. The emergency plan must also include strategies to address events identified in the risk assessment, plans for evacuating or sheltering in place, and also arrangements for working with other providers in the area. The plan must address the patient population, continuity of operations, succession planning, and operations. So, for example, with addressing operations, we would expect a facility to address the number of beds that they have available, the level of care that the facility provides, and the availability of staff and supplies during an emergency. With regard to succession planning, we would expect the provider to address issues such as lines of authority and also to ensure that the plan can be implemented promptly and efficiently. And then, finally, there must be a process for cooperation and collaboration with local, regional, State, or Federal emergency preparedness officials to ensure an integrated approach. In response to public comments received after the initial draft, a change was made to allow a provider that is part of a health care system consisting of multiple separately certified health care facilities to have one unified and integrated emergency preparedness program. This exception would apply to DaVita and Fresenius, for example. The integrated emergency plan, as well as the required policies and procedures, must be developed in a manner that takes into account each separately certified facility’s unique circumstances, patient populations, and services offered. In addition, a risk assessment must be conducted for each separately certified facility in the system. It should be noted that each separately certified facility must meet the previously defined Conditions of Participation on its own. So integrated health systems are encouraged to leverage resources and to develop plans at the corporate level, but those plans must address the specific and unique nature of each separately certified facility within the system.

20. 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, alternate power sources, medical record preservation, sheltering/evacuation, roles and responsibilities, mutual aid, evacuation plans, procedures for sheltering in place, and tracking patients and staff during an emergency
Policies and procedures must be reviewed at least annually by facility.
Policies and procedures. Each provider must develop and implement policies and procedures based on the emergency plan and the risk assessment. The policies and procedures must address a myriad of topics, and I’ll highlight some of them here. There is a full list in the regulation. The policies must address the provision of subsistence needs, alternate energy sources, sewage and waste disposal, procedures for evacuating or sheltering in place. There must be a system to track the location of staff and patients. There must be safe evacuation considerations, such as care and treatment needs, transportation ID, and evacuation location. The policies must address a means to shelter in place, taking into consideration the ability of a building, for example, to survive a disaster and proactive steps that can be taken prior to an emergency. There must be a system to preserve medical documentation that ensures confidentiality in compliance with HIPAA. There should be procedures for the use of volunteers and the role of State and Federal health officials and then, also, arrangements with other providers to receive patients in the event of limitation or cessation of operations (i.e. transfer agreements) as well as the method for sharing medical documentation with a receiving provider.

21. Communication Plan
Facilities must develop a Communication Plan that includes:
Names/Contact info for stakeholders (physicians, hospitals, state and local emergency management officials)
Means for communicating (primary and alternate) with stakeholders
Methods for sharing medical records and patient information.
Process for sharing logistical information regarding occupancy and the ability to provide assistance to other facilities (must adhere to HIPPA requirements.
The third provision is the development and maintenance of a communication plan that complies with both Federal and State laws. The plan must include names and contact information for physicians, other hospitals or like-facilities, volunteers, State and local emergency preparedness officials. It must include primary and alternate
means of communicating with staff and emergency management agencies such as cell phones or satellite systems. For example, the long term care facilities utilize the MedComm radio system. There must be a method to share medical records and patient information, including general location and condition. There also must be a method to share information regarding occupancy, the needs of the provider, and the health care facility’s ability to provide assistance to other health care entities in the community that may be experiencing some difficulty during the emergency. The goal of the communication plan requirement is to ensure that patient care is coordinated within the facility, across health care providers, and with State and local public health departments and emergency management systems. The communication plan must be reviewed and updated annually.

22. Communication Plan (Cont.)
Communication Plan will ensure that patient care is coordinated:
Internally
Across health care providers
With state, regional and local public health departments (ESF-8)
With emergency management agencies
Communication Plan must be reviewed at least annually by facility.
The third provision is the development and maintenance of a communication plan that complies with both Federal and State laws. The plan must include names and contact information for physicians, other hospitals or like-facilities, volunteers, State and local emergency preparedness officials. It must include primary and alternate
means of communicating with staff and emergency management agencies such as cell phones or satellite systems. For example, the long term care facilities utilize the MedComm radio system. There must be a method to share medical records and patient information, including general location and condition. There also must be a method to share information regarding occupancy, the needs of the provider, and the health care facility’s ability to provide assistance to other health care entities in the community that may be experiencing some difficulty during the emergency. The goal of the communication plan requirement is to ensure that patient care is coordinated within the facility, across health care providers, and with State and local public health departments and emergency management systems. The communication plan must be reviewed and updated annually.

23. Training and Testing Program
Develop and maintain training and testing programs, including initial training in policies and procedures.
Training programs must include:
Initial training in emergency preparedness for:
New and existing staff
Individuals providing services under arrangements
Volunteers consistent with their expected roles
Documentation of training activities (who, what, when, where, how)
Provide annual training for staff
In the final provision, the regulation requires providers to develop and maintain a training and testing program. This program must include both training in emergency procedures and participation in exercises to test the emergency plan at least annually. Providers are required to conduct two exercises annually -- one community-based full-scale exercise and one additional exercise of their choice. In the event that a provider experiences an actual emergency that tests their plan, they would be exempt from the requirement for a community-based full-scale exercise for 1 year following the emergency event. Our main focus is on the requirement for sufficient testing of the emergency plans to gather valuable information that can be used to analyze a facility’s emergency procedures and revise them as necessary, rather than focus on the term used to describe the actual testing exercise because industry terms will continue to evolve and can change over time. For purposes of the requirement for a community-based full-scale exercise, we expect facilities to simulate an anticipated a response to an emergency involving their actual operations and the community. This would involve the creation of scenarios, the engagement and education of personnel, and mock victims/patients. In addition, this would include the involvement of other providers, suppliers, and community emergency response agencies. Collaboration and engagement with community partners should be conducted not only to meet this requirement but for the purposes of determining each partner’s role and capabilities in an emergency situation. The intention of this requirement is to not only assess the feasibility of a provider’s emergency plan through testing, but also to encourage providers to become engaged in their community and promote a more coordinated response within the facility, across health care providers, and with State and local public health departments and emergency systems. Therefore, facilities who are normally excluded from community disaster planning or smaller facilities without close ties to emergency responders and community agencies are encouraged to reach out and gain awareness of the emergency resources and events within their community. Furthermore, we understand that participation in a community-based full-scale exercise may not always be feasible or readily accessible. Therefore, if a community-based full-scale exercise is not feasible, the requirement does give providers the flexibility to conduct a testing exercise that is based on the individual facility – functional exercise. This individual facility-based exercise must be sufficient enough to maintain knowledge and skills and adequately test the emergency plan.

24. Training and Testing Program (Cont.)
Testing/Exercise programs must include:
Annual exercises to test emergency planning:
Community-based Full-Scale exercise
If not possible, conduct individual facility-based
Exemption from this requirement One year exemption if facility experiences actual or man-made emergencies that require emergency plan activation.
In the final provision, the regulation requires providers to develop and maintain a training and testing program. This program must include both training in emergency procedures and participation in exercises to test the emergency plan at least annually. Providers are required to conduct two exercises annually -- one community-based full-scale exercise and one additional exercise of their choice. In the event that a provider experiences an actual emergency that tests their plan, they would be exempt from the requirement for a community-based full-scale exercise for 1 year following the emergency event. Our main focus is on the requirement for sufficient testing of the emergency plans to gather valuable information that can be used to analyze a facility’s emergency procedures and revise them as necessary, rather than focus on the term used to describe the actual testing exercise because industry terms will continue to evolve and can change over time. For purposes of the requirement for a community-based full-scale exercise, we expect facilities to simulate an anticipated a response to an emergency involving their actual operations and the community. This would involve the creation of scenarios, the engagement and education of personnel, and mock victims/patients. In addition, this would include the involvement of other providers, suppliers, and community emergency response agencies. Collaboration and engagement with community partners should be conducted not only to meet this requirement but for the purposes of determining each partner’s role and capabilities in an emergency situation. The intention of this requirement is to not only assess the feasibility of a provider’s emergency plan through testing, but also to encourage providers to become engaged in their community and promote a more coordinated response within the facility, across health care providers, and with State and local public health departments and emergency systems. Therefore, facilities who are normally excluded from community disaster planning or smaller facilities without close ties to emergency responders and community agencies are encouraged to reach out and gain awareness of the emergency resources and events within their community. Furthermore, we understand that participation in a community-based full-scale exercise may not always be feasible or readily accessible. Therefore, if a community-based full-scale exercise is not feasible, the requirement does give providers the flexibility to conduct a testing exercise that is based on the individual facility – functional exercise. This individual facility-based exercise must be sufficient enough to maintain knowledge and skills and adequately test the emergency plan.

25. Training and Testing Program (Cont.)
Testing/Exercise programs must include (cont.):
An additional annual exercise of the facility’s choice:
Full-scale, tabletop, etc.
Recommends, but does not require HSEEP
Affords flexibility to determine which exercise methods is most beneficial to specific needs
The intention of these requirements are to:
Assess emergency plans, policies, and procedures
Encourage community engagement (providers & supplies encourage to seek out community players for exercises)
In the final provision, the regulation requires providers to develop and maintain a training and testing program. This program must include both training in emergency procedures and participation in exercises to test the emergency plan at least annually. Providers are required to conduct two exercises annually -- one community-based full-scale exercise and one additional exercise of their choice. In the event that a provider experiences an actual emergency that tests their plan, they would be exempt from the requirement for a community-based full-scale exercise for 1 year following the emergency event. Our main focus is on the requirement for sufficient testing of the emergency plans to gather valuable information that can be used to analyze a facility’s emergency procedures and revise them as necessary, rather than focus on the term used to describe the actual testing exercise because industry terms will continue to evolve and can change over time. For purposes of the requirement for a community-based full-scale exercise, we expect facilities to simulate an anticipated a response to an emergency involving their actual operations and the community. This would involve the creation of scenarios, the engagement and education of personnel, and mock victims/patients. In addition, this would include the involvement of other providers, suppliers, and community emergency response agencies. Collaboration and engagement with community partners should be conducted not only to meet this requirement but for the purposes of determining each partner’s role and capabilities in an emergency situation. The intention of this requirement is to not only assess the feasibility of a provider’s emergency plan through testing, but also to encourage providers to become engaged in their community and promote a more coordinated response within the facility, across health care providers, and with State and local public health departments and emergency systems. Therefore, facilities who are normally excluded from community disaster planning or smaller facilities without close ties to emergency responders and community agencies are encouraged to reach out and gain awareness of the emergency resources and events within their community. Furthermore, we understand that participation in a community-based full-scale exercise may not always be feasible or readily accessible. Therefore, if a community-based full-scale exercise is not feasible, the requirement does give providers the flexibility to conduct a testing exercise that is based on the individual facility – functional exercise. This individual facility-based exercise must be sufficient enough to maintain knowledge and skills and adequately test the emergency plan.

26. Link to the Final Rule (186 Pages)
References:
CMS Preparedness Final Rule Presentation, Kathy Hatter, 6/17
CMS Preparedness Final Rule Presentation, Jordan Zarone, 6/6/17.
CMS Preparedness VDH Presentation to Emergency Management, Patrick Ashley, 7/13/17

27. Northwest Region Healthcare Coalition Contact Information
Ron Clinedinst, CHEC-III NW Region Healthcare Coordinator Office Cell Janine Owens NW Region Healthcare Coordination Center Manager Office/Cell Becki Chester Medically Vulnerable Populations Coordinator Office/Cell