CMS clarifies the Emergency Preparedness Final Rule
4/27/17 Update - CMS clarified that the effective date of the final rule is 11/15/16, and the implementation date is November 15, 2017.


This means that providers are expected to have completed the following by 11/15/17:

  • All of the staff training requirements;
  • Participation in a full-scale exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based exercise;  
  • Conduct an additional exercise that may include, but is not limited to the following:  
    • A second full-scale exercise that is individual, facility-based.  
    • A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.

Non-compliance will result in survey deficiencies via the established survey process.

CMS is still working on developing the Interpretive Guidelines for the emergency preparedness CoP (418.113)  and advised providers on the call not to wait for their distribution to become compliant with all requirements. 

Find a link to the full CMS slide set from the webinar below