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Tip #2: Full-scale exercise exemption
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Of all the new Emergency Preparedness requirements expects home health agencies to meet by November, the community-wide disaster drill (full-scale exercise) is the most intimidating and labor-intensive for many agencies.

The community-wide drill is one of two exercises CMS expects home health agencies to stage each year. The second exercise may be a tabletop version, in which the emergency situation is plotted out via paper-only, with participants seated around a discussion table and “talking out” the procedures.

But the community-wide drill is a full-scale exercise requiring agencies to work with other agencies in their communities such as first responders, emergency management officials, hospitals, clinics, assisted living facilities and others to stage a mock crisis, and conduct a detailed evaluation afterward of how well things went, identifying areas for improvement.

The drill is a major undertaking, requiring much planning and coordination.
Did you know, however, that your agency may be exempt from the community-wide drill until next year if you experienced a crisis which required activation of your Emergency Plan? Many agencies in Florida, Texas, Louisiana, South Carolina and Georgia as well as agencies in the Virgin Islands and Puerto Rico were required to activate emergency procedures during this fall’s spate of damaging hurricanes.
Wildfires in California are currently threatening areas served by home health agencies.

If your agency is located in one of these affected areas – or if you are located in a different area of the country where you experienced a crisis such as tornadic activity, flooding, a blizzard or any other emergency which required your agency to activate emergency procedures – you appear to be exempt from staging a community-wide disaster drill before Nov. 16.

Documentation of the activation of your emergency procedures will be required, as well as a thorough evaluation afterward.

Note that you will still need to have conducted a tabletop exercise by the deadline in order to be compliant.

Here is what CMS says on its web site about this exemption:

NOTICE ON TRAINING & EXERCISES: If a facility activates their emergency plan due to a disaster, the facility is exempt from one full-scale/individual based exercise for that year. However, the secondary requirement for a table-top exercise or exercise of choice still applies. Facilities must demonstrate completion of two exercises per annual year.

You can read for yourself what CMS says about the full-scale exercise at:
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html