Updated on 06/08/2022

CMS Issues Addition Guidance on Emergency Preparedness Testing

The Quality, Safety & Oversight (QSO) Group at the Centers for Medicare & Medicaid Services (CMS) has issued a revised QSO -20-41-All memo to provide additional guidance and clarifications on the emergency preparedness standard for testing requirements due to the ongoing COVID-19 public health emergency (PHE).

If a provider experiences an actual natural or man-made emergency that requires activation of their emergency plan, inpatient and outpatient providers will be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event. In light of the PHE, CMS is clarifying the testing exercise requirements to ensure that surveyors, providers, and suppliers are aware of the exemption available based on the activation of their emergency plans.

The updated guidance only applies if a facility is still currently operating under its activated emergency plan or reactivated its emergency plan for COVID-19 in 2021 or 2022. Facilities which have resumed normal operating status (not under their activated emergency plans) are required to conduct their testing exercises based on the regulatory requirements for their specific provider or supplier type. The guidance provides clarifications on testing exemptions for those providers/suppliers who continue to operate under their activated emergency plan and those which may have reactivated their emergency plans for COVID-19. The guidance will also apply for any subsequent 12-month cycles in the future, in the event facilities continue to operate under their activated emergency plans for COVID-19 response activities.

For outpatient providers, which include home health and hospice agencies, if the facility claimed the full-scale exercise exemption in 2020 based on its activated emergency plan for COVID-19 response and has since resumed normal operating status, the outpatient provider/supplier is expected to complete its required full-scale exercise in 2022, unless it has reactivated its emergency plan for an actual emergency during its 12-month cycle for 2022. If the facility claimed the full-scale exercise exemption in 2021 based on its activated emergency plan for COVID-19 response and has since resumed normal operating status, the outpatient provider/supplier is expected to complete its required full-scale exercise in 2024.

In the memo, CMS provides an additional  scenario where an exemption for a full scale or facility-based functional exercise applies.

Scenario #4

Facility Z conducted a table-top exercise in June 2019 (based on its annual cycle). It is scheduled to conduct a full-scale exercise in June 2020. In March 2020, Facility Z activates its emergency preparedness program due to the COVID-19 PHE. The facility conducts its required exercise of choice in June 2021. As of March 2022, the facility continued to operate under an activated emergency plan. When must the facility conduct its next required full-scale exercise? What is the exemption based on the requirements?

Answer: The facility is exempt from the June 2020 scheduled full-scale exercise for that “annual year” and is required to complete an exercise of choice in June 2021, and a following full-scale exercise in June 2022. It is exempt from its next required full-scale or individual facility-based exercise which would have been in June 2020. However, since the facility is continuing to operate under its activated emergency plan in early 2022, the facility is exempt from the fullscale exercise in June 2022.

 

Article published by NAHC on June 8, 2022
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