Do the Proposed Changes to Training Make Sense?

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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 training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected role. (ii) Provide emergency preparedness training at least annually. (iii) Maintain documentation of the training. (iv) Demonstrate staff knowledge of emergency procedures.
The proposed regulations change “annually” to “every two years” and add this proviso:
(v) If the emergency preparedness policies and procedures are significantly updated, the
hospital must conduct training on the updated policies and procedures.
We have always found the training requirement to be overly vague, and this provision does not clarify it further. We understand that it would be difficult to dictate, and more difficult to enforce, required training expressed in a number of hours per person per subject per year. However, evacuation, shelter-in-place, incident command, and other preparedness subjects are as foreign to the floor nursing staffs as they are to the administrators and facilities managers to whom handed the responsibility for compliance. They need more training and more exercises to master the life-saving skills that matter in an emergency.
We recently surveyed healthcare providers and found that only 25% had more than two hours of training on violence prevention and response in the past 12 months. Another 64% had less, while 11% had none at all. Yet violence is a top risk in most healthcare facilities.
We would support a reduction in the training requirement IF an increase in exercises accompanied it because that would allow a facility to demonstrate competence in these skills, which is far more useful to patients and staff than merely documenting training hours. But, as you will read in the next section, CMS seeks to lighten the exercise requirements as well.
Leave your comments on the federal register and let us know what you think!

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