CMS issues new EP survey guidance

New interpretive guidelines focus on infectious disease and 2019 changes to emergency preparedness programs

When CMS required home health agencies to put together emergency preparedness plans leading up to the implementation of new Conditions of Participation, no one could have predicted that a worldwide pandemic was less than two years away.

But Covid-19 was exactly the type of public health emergency CMS had in mind when it implemented new Conditions of Participation in 2018 requiring home health agencies to step up their infection control measures and put in place a detailed emergency plan.

"At that point, we were looking primarily at infectious outbreaks such as influenza, and making certain agencies had in place the right policies and procedures for effectively dealing with an outbreak," said J'non Griffin, President of Home Health Solutions - A Simione Coding Company.

Griffin spent much of 2018 and 2019 helping agencies across the country develop their emergency preparedness plans, and remembers cautioning agencies to be sure to include the risk of outbreaks such as Zika virus and Ebola when developing their required hazards and vulnerabilities risk assessments.

"CMS specifically added emerging infectious diseases to its definition of 'all-hazards approach' in 2019," Griffin said.

Last year agencies added Covid-19 to the list of infectious agents which must be addressed by infection control policies and procedure and included as part of emergency preparedness. "But it was very much a learn-as-you-go process for agencies, since Covid-19 was a new coronavirus and we didn't know much about it," Griffin said. "Due to the enormity of the public health risk, getting it right was paramount."

Infection control quickly became a Survey focus, and agencies scrambled to make certain their infection control measures were on par with CDC guidelines.

New guidance issued

Now CMS is catching up to the events of the past year, and providing new survey guidance on handling infectious diseases.

On Friday, it issued the “Updated Guidance for Emergency Preparedness – Appendix Z of the State Operations Manual. The update includes expanded interpretive guidance on best practices for handling emerging infectious diseases.

"Some of the new guidance is more recommendation than requirement at this point," Griffin said. "But it does provide direction for agencies."

The updated guidance also addresses changes made to emergency preparedness requirements in September 2019, which reduced the required frequency of emergency plan review, testing and training. Editor's note: This article first appeared in the weekly e-newsletter published each week by Home Health Solutions - A Simione Coding Company. If you'd like to subscribe to the free e-newsletter to get industry news, insight and analysis in your inbox each Monday, click here.