CMS’ Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers regulation has been in effect since November 15, 2017 and outlines four core elements:
- Annual Risk Assessment
- Communication Plan
- Emergency Preparedness Policies and Procedures
- Training and Testing
These regulations are applicable to all 17 CMS provider types, including nursing homes. They also provide a firm foundation for any emergency preparedness program, including assisted living facilities.
The Annual Risk Assessment is the supporting element for any Emergency Preparedness Program that guides and influences the development of the other four elements. Also known as a Hazard Vulnerability Analysis (HVA), it is a systematic approach to recognizing hazards that may affect the ability to care for residents. Required to be completed or updated annually, the HVA helps a facility identify community/geographic area hazards or risks that are then analyzed to prioritize planning, mitigation, response, and recovery activities. Utilizing and incorporating interdisciplinary teams, stakeholders, and community partners (local Emergency Management, etc.), the facility can assess and prioritize the hazards that exist and subsequently develop mitigation and preparedness plans for the facility. The results influence many facets including:
- What emergency response plans should be in place for known hazards?
- What infrastructure improvements, equipment purchases, training, or collaboration with partners can be done to mitigate hazards?
- What should the exercise / drill planning focus be for the year?
AHCA/NCAL and Jensen Hughes have developed the
AHCA/NCAL HVA tool (instructions for use
here). Built on a foundation of established risk probability and assessments, the tool is specifically designed for the nursing home and assisted living environment, and specifically addresses CMS requirements.