A few weeks ago, the Centers for Medicare and Medicaid (CMS) Quality, Safety, and Oversight Group (QSO) issued a Memo to State Survey Agencies titled “Emergency Preparedness Programs – Updates to Appendix Z of the State Operations Manual (SOM)”. Appendix Z is the interpretive guideline for surveyors of all healthcare types in implementing the emergency preparedness Conditions of Participation (COP) that took effect in 2017. This memo describes how CMS has changed its guidance to surveyors on how to survey/enforce specific parts of the Emergency Preparedness Programs at various facilities. Specifically noted were the issues surrounding adding and addressing of Emerging Infectious Diseases to the definition of “All Hazards” and clarifications regarding the use and testing of portable electrical 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.
CMS has also made the change to the Home Health Agency citations from 482.22 to reflect the regulatory citation 484.102. For questions regarding the Emergency Preparedness Rule, please contact SCGEmergencyPrep@cms.hhs.gov.