TO: LTC Facilities
FROM: Brian Purtell, WHCA/WiCAL Director of Legal Services
RE: Emergency Preparedness Rule
In 2014, CMS issued its proposed emergency preparedness rule, which will establish national emergency preparedness requirements for Medicare- and Medicaid-participating providers and suppliers to ensure that they adequately plan for both natural and man-made disasters, and coordinate with federal, state, tribal, regional, and local emergency preparedness systems.
While the proposed rule made headlines when issued, attention has waned over the past two years. However,things are about to heat up again as the rule is working its way through the rule-making process and is currently scheduled to be released in final form at the end of this year.
WHCA/WiCAL is offering a program that will provide participants with a significant leg-up on meeting the expected requirements of the soon-to-be-final rule. Participation in this program will allow facilities to thoughtfully and proactively take steps now toward the pending heightened expectations in the area of emergency preparedness.
The pending rule identifies four core elements that are central to an effective and comprehensive framework of emergency preparedness:
- Risk Assessment and Planning – The proposed rule would require that prior to establishing an emergency plan, a risk assessment be performed using an ”all-hazards” approach.
- Policies and Procedures – We are proposing that facilities be required to develop and implement policies and procedures based on the emergency plan and risk assessment.
- Communication Plan – This proposed rule would require a facility to develop and maintain an emergency preparedness communication plan that complies with both federal and state law.
- Training and Testing – We are proposing that a facility develop and maintain an emergency preparedness training and testing program.
The WHCA/WiCAL program “Making IT Happen” is designed to be consistent with the core elements that we can expect to be contained in the final rule. In line with the philosophy of preparedness, members should take proactive steps now so that you are fully prepared to meet the heightened expectations upon issuance of the final rule. Given the importance of dedicated efforts, which are best conducted in a thoughtful process, beginning action now will allow facilities to seamlessly and timely meet the expected requirements in this area.
This program is intended to provide you with the necessary information, tools, and resources to allow for your facility to not have to rush compliance efforts, thus providing greater efficiency and effectiveness in your efforts. Simply, taking proactive steps now will save you time and energy in the coming months, while also preparing your facility for the unexpected.