September is National Preparedness Month, a time when healthcare organizations and individuals alike are reminded of the vital importance of being prepared for any emergency or disaster that may occur. This month is significant as it brings attention to the need for healthcare providers to ensure that they have effective emergency response plans and protocols in place. These plans should not only address natural disasters such as hurricanes and wildfires but also prepare for unexpected events such as pandemics or other crises.
The consequences of not having a solid emergency response plan in place created a significant impact during the COVID-19 pandemic. For healthcare organizations, National Preparedness Month is an opportunity to review and update their emergency plans while proactively taking steps to ensure that their staff and patients receive the necessary support, care, and protection in the event of an emergency. Has your facility completed the CMS Emergency Preparedness Rule requirements that may be required this year?
CMS Emergency Preparedness Rule
CMS Emergency Preparedness Rule for Medicare and Medicaid Participating Providers was last revised in 2019. The CMS Rule applies to 17 different inpatient and outpatient provider types but is an ideal best practice for any residential facility plan. This guidance requires that:
- Emergency plan: Most facilities are to conduct a biennial review of their emergency programs; long-term care (LTC) facilities are to review their emergency programs on an annual basis.
- Training: Most facilities must complete training for emergency procedures every two years; nursing homes are required to provide annual training.
- Testing (for inpatient providers/suppliers): Two annual emergency program testing exercises are required, though one may be an exercise of the facility’s choice.
- Testing (for outpatient providers/suppliers): Facilities must conduct one emergency program testing exercise annually.
While full-scale disaster training exercises are no longer required per the 2021 burden reduction rule, conducting comprehensive disaster training annually will identify gaps in your plan and confirm the capabilities and capacities of your current system. All healthcare communities are venerable to disasters and will benefit from a well-designed plan.
Components of a comprehensive training program should include:
- Individualized hazard vulnerability assessment
- Unique policies and procedures based on a campus’ most-likely hazards
- Internal communication plan
- Review and update plan annually
- Disaster training for all new and existing staff, highlighting individual roles
- Plan for training annually
- Plan to document training
To practice, consider participating in a full-scale disaster training drill with your local healthcare coalition (HCC)*, an annual Shake-Out drill, or a table-top exercise with Food and Nutrition Service. The cornerstone of any great plan is practice, and there are many resources to help bolster your facility’s disaster plan (links below).
Remember — practice makes perfect!
Meals for All’s Registered Dietitians are also available to discuss how you can better prepare your facility during these uncertain times. Request a consultation today, and be prepared!
Additional Training Resources:
- Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Requirements by Provider Type
- CMS Online Training for Emergency Preparedness (PDF)
- Are You Ready? CMS Emergency Preparedness Rule Exercises and Drills
- CMS Emergency Preparedness Rule Toolkits
- Assistant Secretary for Preparedness and Response Technical Resources, Assistance Center, and Information Exchange (ASPR TRACIE)
- ASPR TRACIE Exercise Program
- ASPR TRACIE Recovery Planning
- Healthcare Facility Emergency Operations Plan “Criteria Checklist”
- California Association of Health Facilities’ Disaster Preparedness Program (CAHF-DPP)
- CAHF Training Videos & Webinar
- CMS Training Resources: Quality, Safety and Education Portal
*Health Care Coalitions (HCCs) are interdisciplinary regional networks which support multiple provider types to prepare for disasters and respond to emergencies. HCCs have resources from medical equipment and supplies, to communication systems, to training and education for health care personnel. Click here to find a regional HCC at Public Health Emergency HPP Near You.
By Jo Miller, MPH, RDN, Vice President of Nutrition at Meals for All, Inc.