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Judith Shuck

Judith Shuck

CMS Updates the Emergency Preparedness Rule

CMS updates its Emergency Preparedness Rule Changes to the rule touch on infectious disease and emergency standby power systems
Reference: https://www.hfmmagazine.com/articles/3563-cms-updates-its-emergency-preparedness-rule

Discussion: CMS is adding “emerging infectious diseases” to the current definition of all-hazards approach. After review, CMS determined it was critical for facilities to include planning for infectious diseases within their emergency preparedness program. In light of events such as the Ebola Virus and Zika, we believe that facilities should consider preparedness and infection prevention within their all-hazards approach, which covers both natural and man-made disasters.

Additionally, since the release of the Interpretive Guidelines for Emergency Preparedness in 2017, stakeholders and providers have asked for additional clarifications related to portable/mobile 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.

If a facility risk assessment determines the best way to maintain temperatures, emergency lighting, fire detection and extinguishing systems and sewage and waste disposal would be through the use of a portable and mobile generator, rather than a permanent generator, then the LSC provisions such as generator testing, maintenance, etc. outlined under the National Fire Protection Association (NFPA) guidelines requirements would not be applicable, except for NFPA 70 - National Electrical Code.

However, the revisions, as the provisions under emergency preparedness themselves, do not take away existing requirements under LSC, physical environment or any other Conditions of Participation that a provider type is subject to (for example to maintain safe and comfortable temperatures). Finally, in addition to minor technical edits, CMS has also made the change to the HHA citations from 482.22 to reflect the regulatory citation 484.102.
Contact: For questions regarding the Emergency Preparedness Rule, please contact This email address is being protected from spambots. You need JavaScript enabled to view it..

Effective Date: Immediately. The information provided in this memorandum should be communicated with all survey and certification staff, their managers and the State/Regional Office training coordinators within 30 days of this memorandum.

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The Eastern Virginia Healthcare Coalition (EVHC) is supported by the several work groups. A work group is an ad hoc group of subject-matter experts that work together to achieve specific goals. The groups are domain-specific and focus on discussion or activity around a specific area subject area. We currenlty have a Communciations Work Group, Exercise and Training Work Group and a Regional Healthcare Coordination Center work group. The purpose of each work group is specified in the work group charter.  The charter for each of our work groups can be downloaded using the link below. 

If you are interested in serving on one of these work group please contact the EVHC Program Manager via e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it. or call (757) 963-0632.

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