Emergency Preparedness Requirements (Testing Exemption Due to Actual Emergency)

Emergency Preparedness Requirements (Testing Exemption Due to Actual Emergency)

CMS updated emergency preparedness requirements in 2019 and released guidance in September 2020 reiterating that providers who activate their emergency plans in response to an actual natural or man-made emergency were exempt from completing their next regularly required full-scale community based or individual facility-based exercise. Remembering that outpatient providers (e.g. PACE, home health) are required to conduct one testing exercise per year and inpatient providers (inpatient hospice, nursing homes, ICF/IIDs) are required to conduct 2 testing exercises per year, with testing exercises for both provider types alternating between full-scale functional exercises and exercises of choice (mock drill, table-top exercise, workshop). If a provider activated the emergency plan in March 2020 due to the COVID-19 public health emergency, the provider is/was exempt from the next required full-scale functional exercise and would proceed with the exercise of choice on the regular schedule.

As we approach the 1-year anniversary of the public health emergency declaration and enter year 2 of the PHE, LeadingAge asked CMS: will providers who continue to operate under the emergency plan once again be exempt from the full-scale exercise? The answer is no, there will not be a second exemption for a continuous emergency.

Here’s an example:

  • A nursing home was planning to complete a full-scale functional exercise in June 2020.
  • The nursing home activated the emergency plan in April 2020 in response to COVID-19.
  • The nursing home was exempt from completing the full-scale functional exercise in 2020 and completed required exercise of choice in 2020.
  • Though the nursing home continues to operate under the emergency plan, the nursing home must complete the full-scale functional exercise in 2021 in addition to the required exercise of choice.

 

Questions?

Contact:

Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services
c: 425-231-4804

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