Further Info on Updated CMS Emergency Preparedness Guidance

Situation Report | April 5, 2021

Following up on last week’s Situation Report, HCA has further information on the recent federal Updated Guidance for Emergency Preparedness-Appendix Z of the State Operations Manual.

The revisions result from the U.S. Centers for Medicare and Medicaid Services (CMS) issuing two final rules effective November 29, 2019 which revised the emergency preparedness requirements for all providers and suppliers.

Additionally, in February 2019, CMS added “emerging infectious diseases” to the definition of an all-hazards approach in Appendix Z.    

A cursory review shows that the updated guidance adds definitions for terms like “functional exercise, mock disaster drill, and workshop” and clarifies training and exercise requirements. It also:

  • Adds a section on emerging infectious diseases.
  • Includes the availability of personal protective equipment (PPE) and transportation options under contingency planning.
  • Strengthens requirements for risk assessments.
  • Provides details on a process to engage state and local emergency planning officials in collaborative planning for an integrated emergency response, including working with such officials to coordinate the reporting of staff or patients who cannot be contacted.
  • Explains how home health agencies (HHAs) will ensure the appropriate discipline/staff perform the required initial and comprehensive assessments when access to residences may be hindered due to an emergency.
  • Requires HHAs to have policies which address their ability to respond to a surge in patients.
  • Provides specific clarifications for hospices that address the use of hospice employees in an emergency and the hospices’ potential surge needs.

HCA will be reviewing the guidance and deciding if we need to conduct any education on the changes.