Guidance Issued on Emergency Preparedness Testing Exercises 

Situation Report | October 5, 2020

The U.S. Centers for Medicare and Medicaid Services (CMS) has issued guidance to State Survey Agency Directors clarifying the exemption from required emergency preparedness testing exercises during or after an actual emergency, in which a provider has activated its emergency plans, including the current public health emergency (PHE).

Agencies that activated their emergency plans during the PHE are, therefore, exempt from the next required full-scale community-based or individual, facility-based functional exercise, as required under 2019 federal emergency preparedness changes for home care, hospice and other providers.

Facilities, however, must be able to demonstrate, through written documentation, that they activated their program due to the emergency.

Furthermore, agencies may need to conduct an exercise of choice following the current PHE if they were required to conduct such an exercise this year and did not already do so. Facilities may choose to conduct a table-top exercise (TTX) which could assess the facility’s response to COVID-19. This may include, but is not limited to, discussions surrounding availability of personal protective equipment (PPE); isolation and quarantine areas for screening patients; or any other activities implemented during the activation of the emergency plan.

Please read the full guidance for further background on the 2019 federal changes to the emergency preparedness requirements, including a required timetable for review of emergency preparedness plans and training, as well as documentation efforts.

HCA will be reaching out to the state Department of Health to learn how the 2019 and most recent federal changes affect their policies for state providers.