Emergency Preparedness: CMS S&C Memo

The Centers for Medicare & Medicaid Services (CMS) Issued S&C 17-21-ALL to provide information to assist providers and suppliers in meeting the Training and Testing requirements of the new Emergency Preparedness Final Rule that was published on September 16, 2016 (81 FR 63860) and became effective on November 15, 2016.

The S&C letter can be found at:

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-21.pdf

CMS has noted that:

Many providers and suppliers have asked whether they will be expected to have completed the “exercises” per the training and testing requirements in each standard (d) of the Final Rule, by the implementation date. Because the Final Rule has an implementation date of November 15, 2017, one year following the effective date, providers and suppliers are expected to meet the requirements of the training and testing program by the implementation date.

Providers should not wait for the release of the interpretive guidance to begin planning emergency exercises; providers and suppliers that are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance. Also, CMS understands that a full-scale, community-based exercise may not always be possible for some providers and suppliers. In such cases, CMS expects those who have been unable to complete a full-scale exercise by November 15, 2017 to complete an individual facility-based exercise and document the circumstances as to why a full-scale, community-based exercise was not completed.

CMS has developed a website with resources on the final rule. Resources can be found at:

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-21.pdf

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html