On Dec. 27, the Centers for Medicare & Medicaid Services (CMS) proposed new regulations requiring virtually every type of Medicare and Medicaid participating provider (other than individual practitioners) to develop and implement comprehensive emergency preparedness programs as part of the Conditions of Participation (COP). To learn more about the proposed rule and how it will affect hospices, please register for VNAA’s Hospice roundtable call on Friday, Feb. 21 at noon EST. During this call, VNAA will answer member questions about the proposed rule and collect any input from members to consider in filing comments. Click here to register for the call.

Electronic comments are due no later than 5 p.m. on Feb. 25, 2014 to http://www.regulations.gov.

The proposed rules require:

• An “all risks” assessment;
• A comprehensive plan to address those risks along with periodic plan updates;
• Policies and procedures to implement that plan;
• Ongoing training of all staff;
• Communications plans and systems to maintain contact with staff and patients; and
• Training and staff drills to implement and test the plan.

CMS developed this proposed rule by identifying the new conditions required for hospitals and then applying very similar rules with some subtractions or additions for each provider type. There are separate rules laid out for home health agencies and rules for hospices in the proposed rule, as well as additional rules for hospices with inpatient facilities. The proposed rule suggests that to understand the rule fully, one should both familiarize oneself with the regulations specific for your provider type, but also be familiar with all explanatory material for the hospital COPs. The rules also make clear that any contractors employed by providers are subject to the provider’s emergency plan. For more on the regulation, please see VNAA’s summary here. VNAA will file comments on the rule no later than 5 p.m. on Feb. 25 to http://www.regulations.gov.