8 Things to Know About CMS' Emergency Preparedness Rule

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Natural and man-made disasters have ravaged the United States, and the world, extensively during the past decade, and they have put hospitals' emergency preparedness to the test.

Natural events, including hurricanes and tornadoes, as well as preplanned attacks like those on Sept. 11, 2001, and the Boston marathon bombing, have led to enormous casualties. Hospitals and health systems have been on the frontlines to handle them all, but the federal government is looking to ensure all healthcare facilities are prepared to meet any possible future challenges.

Late last month, CMS proposed a rule on emergency preparedness planning for all providers and suppliers that accept Medicare and Medicaid funds. CMS praised hospital emergency preparedness operations plans, saying they have improved "significantly" since 2002 thanks to active senior leadership and sustained attention through hospital-based disaster coordinators. However, CMS wanted to establish new guidance because the agency believed the current emergency preparedness requirements for healthcare facilities were "not comprehensive enough to address the complexities of actual emergencies."

Here are eight of the main highlights.

1. There are four core elements CMS said are integral to a healthcare facility's emergency preparedness program: risk assessment/planning, policies and procedures, communication plan and training/testing. All providers accepting federal and state funds would have to establish a program and plan with these elements.

2. Hospitals and all other providers would have to use an "all-hazards" approach in their emergency preparedness. This means providers would have to adopt an approach that covers a "broad range of related emergencies."

3. Within risk assessment and planning, hospitals would have to reach several checkpoints. For example, hospitals would figure out what other nearby hospitals could be used as alternative care sites in cases of emergency or evacuation.

4. Within policies and procedures, CMS proposed requiring hospitals maintain a certain amount of food and drink ("subsistence") on hand for staff and patients, address alternative sources of energy, define how sewage and waste would be disposed and create a policy to track the location of staff and patients during and after an emergency — among many other proposed requirements.

5. Within communication planning, hospitals would have to identify names and contact information for all pertinent employees, physicians, other hospitals and volunteers. Hospitals would also have to establish a method for sharing information and medical data within the bounds of HIPAA.

6. CMS proposed hospitals review and update their emergency preparedness program at least once every year.

7. The proposed guidelines for general acute-care hospitals would also apply to critical access hospitals.

8. Ambulatory surgery centers would not be required to provide occupancy information in their communication plans. ASCs would also not be required to provide subsistence to staff and patients.

All comments are due to CMS by Feb. 25.

More Articles on Hospitals and Emergency Preparedness:
Energy Emergency: A Prescription for Sustained Access to Emergency Power and Energy Cost Reduction
Disaster Preparation 101: 3 Post-Blackout Lessons on the Anniversary of the Northeast Blackout
4 Actions to Deal With Spikes in Patient Volume During a Disaster

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