HELPERS in Central iowa and colleagues--CMS providers and suppliers are reminded of this update (Appendix Z). Clarifications in it include inclusion of Emerging Infectious Diseases language in core planning and HVA considerations, generator-related specifics, and additional clarifications from the original Final Rule.
The Center for Medicaid and Medicare Services (CMS) released revisions
to Appendix Z for the Emergency Preparedness Rule. The revision does
not change any requirements to the rule, but adds clarification.
CMS 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.
Additionally, 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)
If a facility risk assessment determines the best way to maintain
temperatures, emergency lighting, fire detection and extinguishing
systems and sewage and waste disposal would be through the use of a
portable and mobile generator, rather than a permanent generator, then
the LSC provisions such as generator testing, maintenance, etc. outlined
under the National Fire Protection Association (NFPA) guidelines
requirements would not be applicable, except for NFPA 70 – National
Electrical Code. However, the revisions, as the provisions under
emergency preparedness themselves, do not take away existing
requirements under LSC, physical environment or any other Conditions of
Participation that a provider type is subject to (for example to
maintain safe and comfortable temperatures).
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