Guidance Issued on Emergency Preparedness Exercise Requirements

Situation Report | June 28, 2021  

The U.S. Centers for Medicare and Medicaid Services (CMS) has posted a State Survey Agency Directors letter entitled Guidance related to Emergency Preparedness-Exercise Exemption based on A Facility’s Activation of their Emergency Plan. 

The guidance amends a September 28, 2020 State Survey Agency Directors letter on exercise requirements (full-scale/functional drills and exercises) for inpatient providers/suppliers, and HCA will be examining how it may affect home health and hospice providers.  

CMS says it recognizes many facilities are still operating under disaster/emergency conditions during the public health emergency (i.e., under an activated emergency plan).

“The updated guidance only applies if a facility is still currently operating under its activated emergency plan,” CMS adds. “Facilities which have resumed normal operating status (not under their activated emergency plans) and were exempted from a full-scale exercise for its 2020 cycle, must conduct a full-scale exercise or an individual facility-based exercise for its next cycle.”

CMS adds the following for home health, home-based hospice and other outpatient providers: “The outpatient providers will continue to follow the guidance issued (September 28, 2020), as the facility was either exempt from the full-scale exercise in 2020 or in 2021, depending on its cycle of testing exercises. ”

HCA will be seeking further clarification regarding any specific updates for home care and hospice providers, especially as it relates to the timing of required emergency preparedness exercises in future cycles given the continued federal public health emergency.