This is the fourth of six updates in a Simione series on the NEW Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoPs) for Home Health. Home health agencies must take steps now to ensure compliance with these important requirements by the implementation date of July 13, 2017.
The final rule, Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers (CMS-3178-F), establishes national emergency preparedness requirements for Medicare- and Medicaid-participating providers and suppliers to ensure adequate emergency plans are developed and in place to address natural and manmade disasters. These plans must also coordinate with federal, state, tribal, regional and local emergency preparedness systems.
Historically, these regulations were developed based on prior disasters such as Hurricane Katrina. Multiple gaps were identified following this and other major disasters having a negative impact on health care recipients. Shortfalls were identified related to communication and coordination with other systems of care for local jurisdictions, contingency planning, and training of personnel.
The components of this final rule have been incorporated into the Home Health CoPs and will be found at CFR 484.201. Home health agencies must prepare for these new requirements by developing an Emergency Preparedness program and plan to ensure their patients, caregivers and staff needs are met in the safest manner possible in the event of a disaster.
An emergency plan, in the most basic sense, is a guiding document that outlines in detail the systems and protocols that an organization has in place to:
- ensure the safety of staff and patients
- operate within the larger emergency management system, and
- maintain continuity of services to patients during and after an emergency