This blog post is based on a recent webinar with James Paturas, Director of Yale New Haven Health System Center for Emergency Preparedness and Disaster Response (YNHHS-CEPDR).
The November 15, 2017 deadline is behind us, and now organizations are wondering—when will CMS show up for a site visit?
The one-year gap between the 2016 publication of the Final Emergency Preparedness Rule and the 2017 deadline gave hospitals and health care facilities time to ensure compliance with the new regulations. Now that the deadline has passed, participating healthcare providers and suppliers are waiting to find out whether or not their plans meet the new standards.
Paturas explains that CMS and YNHHS-CEPDR provide resources that are still available to help organizations prepare for upcoming site visits and check for organizational compliance with the new regulations.
Reference the Online Resources CMS Provides
“You really need to read the entire final rule and the FAQs released by CMS,” Paturas stresses. “Reading through the FAQs was extremely beneficial to our organization because it provided a realistic interpretation of the rule.” Along with the published final rule and FAQs, the CMS Survey and Certification Group (SCG) website has extensive resources that provide guidance for surveyors, providers, and suppliers.
Additionally, Paturas points out that the ASPR TRACIE website is a robust resource that provides technical assistance to any eligible provider. HHS defines ASPR TRACIE as, “A healthcare emergency preparedness information gateway that ensures that all stakeholders have access to information and resources to improve preparedness, response, recovery, and mitigation efforts.”
Use the YNHHS-CEPDR Crosswalk to Review Plans
YNHHS-CEPDR developed a crosswalk to guide their user community and their organization in meeting the new CMS standards. The crosswalk serves as a visual representation of the association between the CMS Emergency Preparedness Final Rule Conditions of Participation and existing regulatory and accreditation standards.
The crosswalk was created in collaboration with a number of national subject matter experts who took great effort to ensure that the mapped Conditions of Participation and accreditation standards matched as closely as possible. It is organized by facility type and includes emergency and disaster related program, policy, communication, training, and exercise elements of regulatory and accreditation standards.
“Our crosswalk looks at the CMS rule, the Joint Commission, and other accreditation processes,” Paturas explains. “We use the crosswalk within our own plans, which has been very helpful during assessments and regulatory visits because it allows us to show how and where we have met each standard within the body of the plan.”
Paturas emphasizes that the crosswalk should be used only as a resource for reviewing and updating healthcare emergency preparedness plans and does not replace existing federal, local, or association guidance. “We hope that if an organization begins with the crosswalk, they will be able to immediately identify the gaps. It may take some work to fill those gaps, but our hope is that the time and energy spent will be focused on those areas that are most important and will bring organizations into compliance.”
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