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Safe & Ready

Unprepared for disaster? That could be even more costly than you think

Disaster preparedness takes practice.

Disaster preparedness takes practice.

By Michael Boardman, CEO, Readiness Associates, and Traci Curtis, Executive Director, Survey Operations, CIHQ

Healthcare organizations that fail to comply with the Centers for Medicare and Medicaid Services (CMS) Emergency Preparedness Final Rule not only put patients, staff and visitors at risk, they also face financial ramifications that could include thousands of dollars in fines or even termination of their Medicare provider agreements.

The potential penalties demonstrate just how seriously CMS takes non-compliance with the Emergency Preparedness rule, which went into effect on November, 16, 2016, to ensure that healthcare facilities are ready to respond to, and recover from, a wide range of natural and man-caused disasters.

Patient health and safety in care facility settings participating in Medicare is a top priority for the Centers for Medicare & Medicaid Services. Provisions in the Social Security Act (the Act) list the types of providers and suppliers that may participate in Medicare and Medicaid and the requirements that each provider and supplier must meet to be eligible for Medicare and Medicaid participation. The act also authorizes the establishment of other requirements as necessary to protect the health and safety of patients, including the Conditions for Participation (CoPs) for providers, Conditions for Coverage (CfCs) for suppliers, and requirements for long-term care facilities. These CoPs and CfCs are intended to protect public health and safety and empower patients and doctors to make informed decisions about the quality of their healthcare facility. 

The Emergency Preparedness rule established new requirements for providers and suppliers to meet.

“The emergency preparedness requirements are treated in the same manner as all other conditions and standards, meaning the enforcement process for non-compliance is the same,” according to Appendix Z of the State Operations Manual by CMS. 

“Facilities which remain non-compliant with the requirements could face termination of their Medicare provider agreement. Generally, if non-compliance is identified, facilities have an opportunity to correct the deficiency through a Plan of Correction approved by CMS to remove the deficiency.”