The Centers for Medicare & Medicaid Services (CMS) recently sent a memorandum, dated February 1, 2019, to State Survey Agency Directors outlining several revisions and additions effective immediately to Appendix Z of the State Operations Manual as related to compliance with the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers in effect since November 15, 2017. While we encourage members to review the entire memorandum, we have outlined the major changes in the table below.

Requirement Area/Tag # Relevance
Definitions The definition of “all hazards approach” has been expanded to include emerging infectious disease (EID) threats such as Influenza, Ebola, and Zika.
E-0004, Develop and Maintain Emergency Preparedness Program EIDs have been added to the list of disasters that facilities should consider and develop for in their emergency plans.
E-0015, Subsistence Needs, including Alternative Energy Sources CMS clarifies that while facilities, based on their risk assessment, must determine the most appropriate alternate energy sources to maintain temperatures in order to protect patient health and safety, and other critical functions, facilities are not required to upgrade their alternate energy source or electrical systems. CMS emphasizes that when developing alternate energy source plans, facilities must be in compliance with local and state laws, and applicable life safety requirements.

CMS further clarifies that facilities are not required to heat and cool the entire building evenly, but must ensure safe temperatures are maintained in patient care areas and other critical operational areas.

CMS also provides additional information on the use of mobile generators, and expectations about sewage or waste management.

CMS urges long-term care facilities, critical access hospitals, and hospitals to also refer to Tag E0041 for related information about emergency and standby power systems (see below).

E-0018, Policies and Procedures-Tracking Systems for Evacuation CMS emphasizes that facilities are required to follow all state and local mandates, including mandatory evacuation orders.
E-0037, Emergency Preparedness Training Program CMS acknowledges that because health care workers may work in multiple facilities, attending facility-specific emergency preparedness training at each may not be feasible. Therefore, CMS allows for the sharing of training documentation containing all required information to such individuals. Sharing of these materials must be tracked similarly to tracking of completion of training.
E-0041, Emergency Power CMS provides additional information about the use of portable or mobile generators, with an emphasis on requirements under NFPA 110.

Information on CMS’s rule is available in the Emergency Preparedness section.