CMS updates SOM Appendix Z – Emergency Preparedness

The Centers for Medicare & Medicaid Services (CMS) released updates to Appendix Z of the State Operations Manual which covers the Emergency Preparedness Requirements for healthcare providers. The EPP requirements were effective November 15, 2017. The updates to Appendix Z include changes to the “all-hazards approach” definition, clarifications related to alternate source power and emergency standby systems and updated Home Health Agency (HHA) citations.

Updates to the All-Hazards Approach Requirement

CMS has updated the definition of “all-hazards approach” in Appendix Z. The definition now includes an additional requirement —  “Planning for an all-hazards approach should also include emerging infection disease (EID) threats. Examples of EIDs include Influenza, Ebola, Zika Virus and others.” The regulation at E0004 Develop and Maintain EPP Program has been revised to include language related to the facility’s emergency preparedness program and consideration of particular hazards, including EIDs. The information states that EIDs may require modifications to facility protocols in order to protect the health and safety of patients, such as through the use of isolation and use of personal protective equipment. (You can view information on precautions and PPE in this week’s CMSCG Ftag of the Week – F880 Infection Prevention and Control (Part 2) which will be published on Friday 2/8/19).

Updates to Alternate Source Power/Emergency Standby Systems

The regulatory language at E0015 Subsistence needs for staff and patients has also been revised in the updated Appendix Z. The regulation states that based on its individual risk assessment, each facility is responsible for determining the most appropriate alternate energy sources to maintain temperatures, to ensure the safe and sanitary storage of provisions, emergency lighting, fire detection and extinguishing, alarm systems and sewage/waste disposal. What has been added is a statement that facilities are not required to upgrade their alternate energy source or electrical systems, but may choose to do so after reviewing their risk assessments and seeing that upgrades would be “prudent.”

Regarding heating and cooling of the facility in emergencies, additional language has also been added about maintaining safe temperatures and how if the facility cannot meet temperature needs, it should have a relocation/evacuation plan in place. The plan should be put into action “in a timely manner” to prevent residents from unsafe temperatures.

Additionally, it is noted that if a facility’s risk assessment has determined that the best way to maintain these systems is through the use of a portable/mobile generator rather than a permanent generator, LSC provisions applicable under NFPA guidelines would not be applicable with the exception of NFPA 70 – National Electrical Code. (The full requirements for NFPA 70 re: portable/mobile generators are included in the updated Appendix Z). There is also information related to this topic added under E0041 Hospital CAH and LTC Emergency Power.

View CMS QSO Memo, “Emergency Preparedness – Updates to Appendix Z of the State Operations Manual (SOM)” (Ref: 19-06-ALL).

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