CMS Proposes Rule on Emergency Preparedness Standards for Medicare and Medicaid Home Health and Hospice Facilities
Tuesday, January 7, 2014
by: VNAA Policy Team

Section: Public Policy and Advocacy




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On Dec. 27, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule to create consistent emergency preparedness requirements for most health care providers participating in Medicare and Medicaid. After reviewing the regulation, VNAA will distribute a summary of the regulations for members via listserv. VNAA will also submit comments to CMS regarding this rule. A special meeting of VNAA’s Public Policy Council will take place on Wednesday, Jan. 15 at 3:00 p.m. regarding the regulation. Click here to register for the call. Highlights of the proposed rule are as follows:

Home Health: For home health, CMS notes an expectation for agencies to work closely with hospitals and other providers to plan for disasters and emergency situations. CMS proposes HHAs have 1) individual emergency preparedness plans for each patient; 2) procedures to inform state and local emergency preparedness officials about patients in need of evacuation from their residences and 3) a method for providing information to all new patients and their families about the role the HHA would play in the event of an emergency. In the proposed rule, CMS also notes that an HHA should consider whether it would accept new referrals during a disaster or emergency situation and how it would care for new patients.

Hospice:For inpatient hospices, CMS would amend current requirements to resemble those of hospital emergency preparedness. For hospice care provided at home, CMS proposes an emergency plan be in place for managing the consequences of power failures, natural disasters and other emergencies that would affect the hospice’s ability to provide care. In addition, CMS proposes requiring a hospice periodically review and rehearse its emergency preparedness plan with hospice employees. CMS would also require all hospices, regardless of whether or not they operate their own inpatient facilities, to have policies and procedures to inform state and local officials about hospice patients in need of evacuation from their respective residences at any time due to an emergency situation, based on the patient’s medical and psychiatric condition and home environment.

Several recent disasters placed readiness for public health emergencies on the national agenda. The proposed rule would establish national emergency preparedness requirements to ensure that health care facilities adequately plan for disasters and coordinate with Federal, state, tribal, regional and local emergency preparedness systems to make sure that providers and suppliers are ready to meet the needs of patients during disasters and emergency situations.

CMS has identified four specific areas that are central to an effective system:

1.      Emergency plan-Based on a risk assessment, develop an emergency plan using an all-hazards approach focusing on capacities and capabilities.

2.      Policies and procedures-Develop and implement policies and procedures based on the plan and risk assessment.

3.      Communication plan-Develop and maintain a communication plan that complies with both Federal and State law. Patient care must be well coordinated within the facility, across health care providers and with State and local public health departments and emergency systems.

4.      Training and testing program-Develop and maintain training and testing programs, including initial and annual trainings, conducting drills and exercises or participate in an actual incident that tests the plan.
 
Home health agencies and hospices are among the 17 types of providers and suppliers that may have to comply with CMS’ proposed rule that would impose national emergency preparedness requirements on Medicare and Medicaid-participating providers and suppliers.

Read the proposed rule here. 
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