Practice Makes Perfect: Disaster Training Requirements & Recommendations

Practice continues to makes perfect. Now that communities nationwide are gradually adjusting to a “new normal,” there is no better time to practice your disaster plan as part of your facility’s disaster preparedness training.

CMS Emergency Preparedness Rule for Medicare and Medicaid participating providers was revised in 2016 with training and testing as one of four Conditions of Participation (CoP). The CMS Rule applies to 17 different inpatient and outpatient provider types, but is an ideal best practice for any residential facility plan. This past April, CMS released updated emergency preparedness guidance. In the revised guidance, CMS provides burden reduction rule to 2019 emergency preparedness revisions and requirements.

Changes include (but are not limited to):

• Emergency plan: Eliminating the requirement that the emergency plan include documentation of efforts to contact local, tribal, regional, state, and federal emergency preparedness officials and a facility’s participation in collaborative and cooperative planning efforts.
• Training: Decreasing the training requirement from annually to every two years. Nursing homes will still be required to provide annual training.
• Testing (for inpatient providers/suppliers): Increasing the flexibility for the testing requirement so that one of the two annually-required testing exercises may be an exercise of the facility’s choice
• Testing (for outpatient providers/suppliers): Decreasing the requirement for facilities to conduct testing exercises from two exercises to one exercise annually.

While full scale training exercises are no longer required per the 2021 burden reduction rule, conducting comprehensive trainings annually will identify gaps in your plan and confirm 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
• 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 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.