Skilled nursing facilities (SNFs) and all other providers who are reimbursed by the Centers for Medicare and Medicaid Services (CMS) will be required to comply with new emergency preparedness regulations by November 15, 2017. The rules, approved in late 2016, include far more than having an emergency plan written down and stored on a bookshelf.
Evaluating providers for compliance will become part of the survey process, and any non-compliance must be rectified like any other deficiency, noted the Oct. 28, 2016 CMS announcement.
These significant changes in emergency preparedness regulations for CMS-regulated healthcare facilities have been a long time in coming. The highlights of the new regulations can be broken down into four specific areas of compliance that includes the following:
- Development of an Emergency Plan based on a risk analysis assessment using an all-hazards approach
- Policies and procedures
- Communication plan
- Training and testing
For the purposes of this article, I will focus on these elements of the new regulations as they pertain to SNFs. For additional clarification, CMS has developed a comprehensive table that further explains the requirements for each of the 17 provider types affected by these regulations.
The emergency plan
The new regulations will require SNFs to develop and maintain an emergency plan that is based on a risk analysis utilizing an all-hazards approach to identify potential risks and perils that can impact a facility both internally and externally. The purpose of the risk assessment is to establish an integrated system for emergency planning that not only focuses on the hazards that can affect the operation of the facility but also assesses capacities and capabilities. In other words, creating an emergency plan that focuses only on obvious or location-centric threats like tornadoes, hurricanes and earthquakes won’t be good enough.
Good emergency and disaster planning concepts should focus on all of the potential threats and perils that can impact an operation, not just the common ones. By conducting a Hazard Vulnerability Assessment (HVA), a facility can reasonably identify the types of events it needs to prepare for and incorporate these contingencies into its emergency plan. Several online HVA tools are available in the disaster planning sections of many state nursing home associations’ websites, including this one hosted by the California Association of Health Facilities (CAHF).