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Proposed Post-Acute Provider Rule Recap – Burden Reduction

The Centers for Medicare & Medicaid Services (CMS) published a proposed rule in the Federal Register on September 20, 2018, “Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency and Burden Reduction” which includes proposals for multiple provider types. CMS states that the proposed rule would reduce burden on healthcare providers and allow them to focus more on patients, part of the Agency’s “Patients Over Paperwork” initiative.

A brief recap of one of the key proposals impacting post-acute and long-term care providers includes:

Emergency Preparedness for Providers and Suppliers

  • Proposed change to Annual Review of Emergency Preparedness Program requirements – CMS has proposed to change the annual review of the EPP to occur every two years versus the annual review that is required now. The caveats are that facilities would still be expected to update their policies & procedures to ensure that they have best practices in place and that the EPP is updated more frequently if there is a real-life emergency or training exercise where lessons learned from the incident would require the plan to be updated.
  • Proposed change to Documentation of Cooperation Efforts requirements – CMS has proposed to eliminate the documentation requirement related to facilities’ efforts to contact emergency management officials (local, state, federal, etc.) and to eliminate the documentation requirement related to facility participation in collaborative/cooperative training initiatives. While the documentation requirements in these areas would be eliminated, facilities would still be expected to have a process in place for how this cooperation will occur.
  • Proposed change to Annual Emergency Preparedness Training Program requirement – CMS has proposed that facilities would be required to provide training every two years after the initial training on their Emergency Preparedness programs instead of annually as the regulations requires currently. However, facilities would be required to provide additional training if significant plans to their EPPs were made.
  • Proposed change to Annual Emergency Preparedness Testing requirement – CMS has proposed to expand the types of exercises for inpatient providers to fulfill the testing requirements while providing more flexibility.

CMSCG will be providing updates specific to provider types in the next few days, so check back on the blog shortly for more info. View the proposed rule in the September 20, 2018 Federal Register.

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