Don't overlook these important EP changes during the holiday hustle and bustle
It’s been a hectic month for the nation’s home care providers.
This year, in addition to the holidays, the post-Thanksgiving focus has been on last-minute preparations for Medicare’s new payment model, the Patient-Driven Groupings Model (PDGM) taking effect Jan. 1.
In all the hustle and bustle, providers may have overlooked a couple of other important regulatory changes which CMS implemented, including changes to Emergency Preparedness Plans which took effect on Nov. 29.
Both home health and hospice agencies are impacted by the changes CMS has made to Conditions of Participation requirements for agencies to have in place a full Emergency Preparedness Plan.
“Agencies are still required to have in place a fully developed emergency preparedness plan that includes a process for cooperation with local, tribal, regional, state and federal emergency preparedness officials, with efforts to maintain an integrated response during a disaster or emergency situation,” said J’non Griffin, president and owner of Home Health Solutions. “But certain aspects of that requirement look a little different since Nov. 29.”
4 Emergency Preparedness changes
Here’s a look at four important changes: 1. Documentation: Several documentation requirements have changed. CMS removed a requirement for agencies to document their efforts to contact local, tribal, regional, state and federal emergency preparedness officials. CMS also removed a requirement for agencies to show their facility’s participation in collaborative efforts.
2. Review of the program: CMS revised the requirement for providers to review their emergency preparedness program annually, making the review necessary every two years instead. The biennial review must include a review of the emergency plan, policies and procedures, communication plan, and training and testing program.
"But, if a real-life disaster occurs, CMS expects that providers will update their program as needed to make any corrections or improvements," J'non said.
3. Training: CMS revised the training requirement from annually to every two years after the provider has conducted initial training. Additional training will be required when the emergency plan is significantly updated. 4. Testing: CMS revised and clarified emergency preparedness testing requirements in the following ways: - Inpatient hospice units must conduct two testing exercises annually. One could be a full-scale community-based exercise, an individual facility-based functional exercise, a drill, or a tabletop workshop that includes a group discussion led by a facilitator.
- Outpatient providers such as home health agencies or home-based hospices must conduct one testing exercise each year. This should be a community-based, full-scale exercise. However, CMS recognizes that some providers may not be able to conduct a community-based, full-scale exercise each year. If a community exercise is not available, the home health or hospice agency may conduct an individual facility-based functional exercise every other year. In the years the individual facility-based functional exercises are not conducted, the agency should conduct testing of the agency's choice: a drill, or a tabletop exercise or workshop that includes a group discussion led by a facilitator.
Real-life emergencies When home health or hospice agencies experience real-life natural or man-made emergencies that require activation of their emergency plan, inpatient and outpatient providers will be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event. CMS considers an organization’s communication plan part of their emergency plan, according to J'non. Coordination with other community emergency preparedness officials (for example, emergency management and public health) are also considered part of the emergency plan. "These elements, along with the completion of a corrective action plan, are all part of the activation of the emergency plan," she said.
Helpful explanations J'non offers these helpful definitions and explanations of the differences between a full-sclae exercise and a functional exercise: A full-scale exercise: CMS considers this to be a multi-agency, multijurisdictional, multi-discipline exercise involving joint field offices and emergency operation centers, for example. There will also be ‘‘boots on the ground’’ responses, J'non said, such as firefighters decontaminating mock victims. CMS expects organizations to engage in such comprehensive exercises with coordination across the public health system and local geographic area, if possible.
A functional exercise: CMS uses this term to describe the examination of coordination, command, and control between various multiagency coordination centers (for example, emergency operation center, joint field office, etc.). A functional exercise does not involve any ‘‘boots on the ground’’ (that is, first responders or emergency officials responding to an incident in real time).