The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule in Federal Register that establishes national emergency preparedness requirements for Medicare and Medicaid providers and suppliers to ensure that they adequately plan for both natural and man-made disasters.
The proposed rule addresses emergency preparedness requirements that 17 provider and supplier types must meet in order to participate in the Medicare and Medicaid programs. Home health and hospice provides are among the provider types that will have emergency preparedness requirements included in their conditions of participation.
CMS recognizes the variations that exist among the different provider and supplier types and takes those differences into account, while also providing generally consistency in emergency preparedness requirements. CMS proposes that emergency preparedness for all designated provider and supplier types will include the following four core elements:
- Risk assessment and planning;
- Policies and procedures;
- Communication plan; and
- Training and testing
The proposed rule includes a table of requirements based on the standard elements in the regulation for each of the 17 providers and suppliers. The table includes both additional requirements and exemptions and can be used to provide guidance in planning emergency preparedness programs and disaster planning.
Currently, the CoPs for home health agencies and hospices do not have requirements for emergency preparedness plans, except for inpatient hospices. The three accrediting organizations for home health and hospice, The Joint Commission (TJC), The Community
Health Accreditation Program (CHAP),and the Accreditation Commission for Health Care, Inc. (ACHC) all have some emergency preparedness planning requirements. However, according to CMS, none of these accrediting organizations completely address all of the proposed requirements. Home health and hospice providers should conduct a thorough analysis of their emergency preparedness plans to determine gaps and obtain an accurate burden estimate related to implementing the propose requirements.
Comments on the proposed rule are due February 25, 2014
To view the proposed rule click here.