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Voices & Views

Aug 12
CMS Clarifies Emergency Preparedness Rule from February 2019

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) requirements.

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).

With the brutal winter this year in Wisconsin, is your facility ready for an emergency? Please click HERE to view the registration for our “Emergency Preparedness: Plan It, Test It, Be READY” webinar series to help you and your facility prepare for emergencies.


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