CMS Preparedness Deadline: Four Easy Ways to Start Preparing
With a new year, comes new changes to the emergency preparedness world. With the date of compliance for the new CMS Rule being November 2017, it’s time to get serious about it. Here are our tips to help get your organization compliant (and better prepared).
Make a list of the things that can go wrong. In the emergency preparedness world, we call this a Hazard Vulnerability Assessment (HVA). Basically, you’re looking or anything that could go wrong based on your environment, your geographic location, or your organization’s history. For example, if you are in a coastal climate, you’ll want to make sure that flooding and coastal storms are on your lists. Your regional Healthcare Coalition and local Emergency Manager have conducted HVAs and can share their list; you need to add your own concerns about your facility – fire, computer breach, workplace violence, etc. The HVA must be updated annually.
Compile your emergency procedures. When was the last time you updated your procedures? Spend some time gathering everything together, making a note of what is missing and what you know needs to be added. Each threat you identified in your HVA needs a procedure. Annual reviews are required, and after every emergency that requires using the plan, make notes to improve it. You also need an overarching plan that identifies who is in charge, and who can make what decisions in an emergency (for example, to evacuate during a prolonged power outage). And you need a communications plan, so you can contact patients, family, staff, medical personnel, and partner organizations. Plans must be updated annually.
Offer training to your employees regularly. You are doing this already, right? Be sure to document the emergency training that you offer each new employee and that which you deliver annually. Make sure you have good notes and records of those who have taken courses and those who need to. As a good rule of thumb, everyone in a leadership should have the basics of Incident Command System down. These can be completed online or taught in person by the Crisis Prevention & Response team. Have you activated your plan in the last year? If so, a good After-Action Report from that activation might help you meet your full-scale exercise requirement. Compile all the notes from that activation, and you’ll be able to improve your current plan and prove that you’ve used your plan. As the CMS Rule states, each organization must, “develop and maintain training and testing programs, including initial and annual trainings, and conduct drills and exercises or participate in an actual incident that tests the plan.” (42 CFR § 416.54 (d))
Crisis Response & Prevention can help you with any or all of these steps. Get started today, November 16th will be here before you know it. Contact us for more information.
Related Articles: CMS Rules for Healthcare Providers
Incident Command structure should always be “just right” for the incident. It’s a modular system, not all-or-nothing!
by Rick Christ Current CMS Emergency Preparedness Conditions of Participation require an annual review of your emergency preparedness plan. Under the proposed rule, the plan “must be evaluated and updated at least every 2 years.” Not in the rule, but in...
by Rick Christ Currently, almost every provider type is required to participate in two exercises per year. One “should be” a “community full-scale exercise” while the other can be a tabletop. The original version of the current exercise standards was...
by Rick Christ Currently, the typical CMS regulation says this about the training requirement: The training and testing program must be reviewed and updated at least annually. (1) Training program. The hospital must do all of the following:(i) Initial...
by Rick Christ Barely ten months into the enforcement period of the Emergency Preparedness Conditions of Participation, the Centers for Medicare and Medicaid Services (CMS) is proposing some rule changes that would “reform Medicare regulations that are...
CMS Compliance Products & Services
Remember, we will NEVER share your email address or SPAM you.
You may unsubscribe at any time.