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Date ArticleType
4/28/2017 Regulatory
Emergency Preparedness - Implementation by November 15, 2017

On September 16, 2016, the final rule on Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers was published (Federal Register Vol. 81, No.180). The rule affects 17 provider and supplier types eligible for participation in Medicare.  The rule became effective on November 15, 2016.  However, health care providers and suppliers affected by this rule have until November 15, 2017 to implement the new requirements of participation and be in full compliance.  Surveyors will begin evaluating the new requirements after November 15, 2017.  Providers and suppliers found out of compliance with the new requirements will be cited for non-compliance and must follow standard procedures for covering deficiencies.

The interpretive guidelines and survey procedures are under development now, but not yet available.  CMS has also noted that they are unable to answer most questions until interpretive guidelines and the new survey is released in the Spring or Summer of 2017.
On March 24, 2017 CMS sent S&C 17-21-ALL memorandum related to information to assist providers and suppliers in meeting the new training and testing requirements of the emergency preparedness requirements for Medicare & Medicaid participating providers and suppliers final rule.  The memorandum stated 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 raining and testing program by the implementation date. 

IHCA/INCAL have met with Terry Whitson, Assistant Commissioner, ISDH, Lee Christenson, ISDH Emergency Preparedness Division, Leading Age and Hope Association representatives on two occasions.   IHCA/INCAL also met with the directors of the 10 emergency preparedness districts to plan for coordinated events in each district to help facilities comply with the tabletop and community exercise requirements.  More information on coordination with the preparedness districts is being developed and hopefully will be released in May, with coordinated events potentially beginning in June and running through October.

We are working together for the LTC providers of Indiana to collaborate, pull resources to best determine how to plan and provide support, education and expertise to our members.  IHCA/INCAL will advise our members as we advance toward progress in this important initiative.  If you have questions, please feel free to contact ldavenport@ihca.org.