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CMS Emergency Preparedness Rule Impacts Home Health Organizations

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Does your home health organization have an emergency plan in place? Do you and your staff know how to keep open lines of communication and coordinate care during a natural disaster? The Centers for Medicare and Medicaid Services (CMS) recently finalized a rule that will make sure you do.

The Emergency Preparedness Rule goes into effect November 16, 2016 and will be implemented November 16, 2017. In a September press release, CMS stated that the rule is an effort “to establish consistent emergency preparedness requirements for health care providers participating in Medicare and Medicaid, increase patient safety during emergencies, and establish a more coordinated response to natural and man-made disasters.”

The rule comes on the heels of Hurricane Matthew and this past summer’s catastrophic floods in Louisiana. CMS expressed concern that previous emergency preparedness requirements “did not address the need for (1) communication to coordinate with other systems of care within cities or states; (2) contingency planning; and (3) training of personnel.” The new rule, however, will “ensure that facilities are adequately prepared to meet the needs of their patients during disasters and emergency situations.”

CMS Deputy Administrator and Chief Medical Officer Patrick Conway commented “Preparation, planning, and one comprehensive approach for emergency preparedness is key. One life lost is too many.”

Requirements of the Emergency Preparedness Rule

The rule requires providers across seventeen settings, including home health, to meet the following four provisions:

  1. Completion of a risk assessment and subsequent development of an emergency plan that covers a full spectrum of emergencies or disasters
  2. Development and implementation of policies and procedures that support the risk assessment and emergency plan
  3. Creation of a communication plan that complies with both Federal and State laws and ensures coordination of patient care “within the facility, across providers, and with State and local health departments and emergency systems.”
  4. Development and implementation of training and testing programs for all staff including annual trainings, drills, and exercises that test the emergency plan

In the Frequently Asked Questions document that accompanies the Emergency Preparedness Rule, CMS notes that all providers must be in compliance with the rule to be able to participate in Medicare and Medicaid programs, and that no exceptions will be made. Care organizations that don’t comply will risk losing their Medicare and Medicaid reimbursements.

How the Emergency Preparedness Rule Impacts Home Health

Emily Lord, Executive Director of Healthcare Ready, expressed her concern about the rule placing additional strain on “home health care agencies, hospice providers, and other long-term care services providers, as these are settings have not typically had preparedness plans in place.” Indeed, many home health organizations are already running on minimal staff, funding, and resources – and adding another regulatory burden to the to-do list could put stretch some organizations to the limit.

With just one year to complete the risk assessment, develop and implement emergency and communication plans, and effectively train staff on policies and procedures, home health organizations certainly have their work cut out for them. And CMS isn’t providing any in-field support; CMS has stated that it “does not expect to develop training specifically for providers and suppliers” – although it is developing guides that will assist in implementing the rule. The guides are expected to be available in early 2017.

In the meantime, home health organizations should work to improve internal efficiency and leverage resources wherever possible to free up the manpower needed to start meeting the requirements of the Emergency Preparedness Rule.

Learn how to back-up your phone system with ubeRNurse’s disaster recovery features. Finding after-hours support is easier and more cost effective than you think. Learn how AfterHours Triage can extend your services without extending your staff: contact us or call 888-260-8460.

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