Release of Guidelines gives ‘green light’ for agencies to proceed with Emergency Plans

Has your home health agency been waiting on Interpretive Guidelines for new Medicare Conditions of Participation before beginning work on an Emergency Preparedness Program?

Then it’s time to roll up your sleeves and dive into identifying the specific hazardous situations your agency could face, develop emergency communication strategies for emergency conditions, and create the training and testing procedures which must be in place by November.

Interpretive Guidelines have been released by the Centers for Medicare and Medicaid Services (CMS), specifying what Surveyors will look for after Nov. 15 as they try to determine how well agencies have prepared to address the needs of homebound patients in the event of manmade or natural disasters.

“There were no real surprises in the Interpretive Guidelines,” said Home Health Solutions owner J’non Griffin. “These guidelines simply confirm what Surveyors will be looking at when they evaluate agency Emergency Preparedness Programs.”

The real impact of the release of the Interpretive Guidelines is that agencies may now believe they have a “green light” to go forward with work on their plans, J’non said.

“Even though CMS has encouraged agencies to avoid waiting on the release of the Guidelines to get started on their Emergency Plans or risk being cited for non-compliance in November, some agencies felt that until the Guidelines were in place, there was no real sense of urgency,” she said.

“Now we are just five months away, and there’s no more time left to delay,” J’non said.

She said it will take some time for agencies to effectively coordinate efforts with strategic community partners to plan and stage the community-wide disaster drill which is an important part of the CoPs requirement.

What Surveyors will look for

Based on the newly-released Guidelines, here’s what agencies can expect, during Survey:

  • Surveyors will review records to look for some specific items, including evidence that the agency has met a new Condition of Participation requiring an individual emergency plan for each patient as part of the comprehensive assessment.
  • They’ll look for documentation showing that agency personnel discussed emergency procedures with patients and caregivers.
  • Agencies will need written policies and procedures detailing how emergencies will be handled.
  • Surveyors will be especially interested in seeing written procedures for how agencies will inform state and local officials about patients who may need evacuation from their residences.
  •  It is also like that Surveyors will interview agency leaders and/or staff members to determine how knowledgeable they are about procedures to be followed in an emergency situation.

 HHS can help!

Our 12-step Emergency Preparedness Plan Assembly Kit makes compliance easy for your agency. We break down the complicated process into easy-to-follow steps, show you what a completed Plan should look like, and provide more than 30 forms and tools designed to capture all the information you’ll need to put together your own plan – even the training materials and evaluation forms to meet the testing/training requirement.

Our Kit provides the full written policies and procedures your agency will be required to have — and now that the Interpretive Guidelines have been released, we are adding tips on what Surveyors will want to see.

Click here to visit The Solutions Shop, our online store, and order the Kit today!