Tuesday, February 5, 2019

CMS Emergency Preparedness Update

Erin Prendergast and Dana Halvorson

The Centers for Medicare and Medicaid Services (CMS) recently sent a memo to state survey agency directors regarding an update to Appendix Z of the State Operations Manual (SOM) to add emerging infectious diseases to the definition of all-hazards approach.  In the memo, CMS also responds to questions about alternate source power and emergency standby systems under the Emergency Preparedness Final Rule.  Since the release of the Interpretive Guidelines for Emergency Preparedness in 2017, stakeholders and providers have asked for additional clarifications related to portable/mobile generators.  CMS has added guidance under Tag E0015- Alternate Source Power as well as clarifications under Tag E0042- Emergency Standby Power Systems. Facilities should use the most appropriate energy source or electrical system based on their review of their individual facility's all-hazards risks assessment and as required by existing regulations or state requirements.  Regardless of the alternate sources of energy a facility chooses to utilize, it must be in accordance with local and state laws, manufacturer requirements, as well as applicable Life Safety Code (LSC) requirements.

The revisions, as the provisions under emergency preparedness themselves, do not take away existing requirements under LSC, physical environment or any other Requirements/Conditions of Participation that a provider type is subject to.  If you have any questions relating to this, please contact AHCA’s Erin Prendergast for SNF focuses and AHCA’s Dana Halvorson for ICF/IID related questions.

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