Centers for Medicare and Medicaid Services
The CMS Emergency Preparedness Rule establishes national emergency preparedness requirements for Medicare and Medicaid-participating providers and suppliers to adequately prepare for both natural and man-made disasters. The requirements are focused on three key essentials necessary for maintaining access to healthcare during disasters or emergencies: safeguarding human resources, maintaining business continuity, and protecting physical resources.
Any healthcare facility that receives funding through the Centers for Medicare and Medicaid Services is required to participate in emergency preparedness activities to continue participation in the program. The overarching goal of the rule is to enable all providers and suppliers wherever they are located to better anticipate and plan for needs, rapidly respond as a facility, as well as integrate with local public health and emergency management agencies and healthcare coalitions’ response activities and rapidly recover following the disaster.
The CMS Rule applies to 17 different inpatient and outpatient provider and supplier types. Because federal requirements change depending on the facility type, there are a number of additional pages to assist facilities in emergency planning.
The facility's emergency preparedness program must contain the following four elements:
- Risk Assessment and Planning
- Hazard Vulnerability Assessment
- Emergency Operations Plan
- Policies and Procedures
- Communication Plan
- Training and Testing
All elements must be updated and reviewed at least annually.
More information about each of these elements is found in facility-specific pages, but an overview is provided below.
Providers and suppliers are required to perform a risk assessment that uses an "all-hazards" approach prior to establishing an emergency plan. The all-hazards risk assessment will be used to identify the essential components to be integrated into the facility emergency plan. Assistance with risk assessments can be found in Step 1: Assess Vulnerability.
Policies and Procedures
Each facility must develop and implement policies and procedures that are based on the emergency plan and risk assessment. It wouldn't make sense for a facility to develop a procedure for tsunamis if they are not in an area that could be effected by a tsunami. Policies and procedures must also address a range of issues, including subsistence needs, evacuation plans, procedures for sheltering in place, and tracking patients and staff during an emergency. This would be a great opportunity to include quality improvement staff and ethics committees in emergency planning functions.
A facility's Communication Plan must comply with both federal and state law. Patient care must be well-coordinated within the facility, across healthcare providers, and with state and local public health departments and emergency management agencies and systems to protect patient health and safety in the event of a disaster.
It is critical that facilities have a system to contact appropriate staff, patients' treating physicians, and others in a timely manner to ensure continuation of patient care functions throughout the facilities and to ensure that these functions are carried out in a safe and effective manner.
Training and Testing
A well-organized, effective training program must include initial training for new and existing staff in emergency preparedness policies and procedures as well as annual refresher training.
The facility may offer annual emergency preparedness training so that staff can demonstrate knowledge of emergency procedures. The facility is also required to conduct drills and exercises to test the facility's emergency plan to identify gaps and areas for improvement.
View the Compliant Exercising fact sheet for guidance on training and testing requirements and exercise terminology.
Contact us if your facility needs assistance with training and testing.
Navigating this Toolkit
Select your facility type to navigate to your specific program requirements or click on the page using the navigation bar.
Licensed Health Care Facilities in New Hampshire
Even if your organization is not required to meet CMS Emergency Preparedness Rule requirements, you may be required to meet emergency planning requirements set by the NH DHHS Bureau of Health Facilities Administration. Licenses and certified healthcare facilities in the State of New Hampshire must follow the Certified Administrative Rules according to their healthcare facility license type. If your facility is required to meet both NH Healthcare Licensing and CMS Emergency Planning requirements, it is essential to meet the higher standard of both processes. Finally, your organization may also be required to meet emergency planning standards set by your Accrediting Agency which can create even more stringent benchmarks.
Healthcare facilities that are Accredited also should ensure that their emergency preparedness program and training and testing standards are in compliance with Accreditation requirements. Yale New Haven Health System, Center for Emergency Preparedness and Disaster Response has developed a crosswalk between CMS regulations and Accrediting Organization standards, in addition to NFPA 1600 and NFPA 99 codes.
Healthcare facilities should adhere to the highest standards for training, planning, and testing applicable to their organization.
A number of resources have been developed to assist providers to interpret and implement emergency preparedness programs and meet quality standards. Many tools and checklists have been developed for each of the 17 impacted provider types. These resources can often be found on the Assistant Secretary for Preparedness and Response Technical Resources Assistance Center and Information Exchange (ASPR TRACIE). Visit https://asprtracie.hhs.gov/cmsrule.
Greater Nashua Healthcare Emergency Response Coalition
The Greater Nashua Healthcare Emergency Response Coalition (HERC) is a collaborative of public health and healthcare organizations, including public and private sector response partners who collaborate to increase the capacity of the Greater Nashua Public Health Region to efficiently and effectively prepare for, respond to, and recover from emergencies and disasters that will impact the region's healthcare infrastructure.
The Greater Nashua HERC has often been referred to as the model for healthcare coalitions for emergency preparedness and response in the State of New Hampshire and continues to provide technical assistance to organizations in need of exercise design and evaluation support, emergency planning, and continuity planning. It also provides healthcare, public health, and emergency services with a forum to collaborate on special projects, coordinate training and exercise opportunities, and share best practices and lessons learned.
Please contact the Public Health Emergency Preparedness Coordinator for more information or to get involved.