CMS Memo to State Survey Directors

The March 24th memo to State Survey Directors details how a provider or supplier covered by the final rule can comply with the final rule’s exercise requirements even if the provider or supplier is unable to participate in the requisite full-scale, community-based exercise. In such circumstances, it is acceptable for the provider or suppler to complete an individual, facility-based exercise and include documentation that participation in a full-scale, community-based exercise did not occur. The memo clarifies that all providers and suppliers covered by the final rule are expected to be in compliance with all the final rule’s aspects by the effective date of November 15, 2017.

GNYHA Activities

GNYHA is developing draft recommendations related to compliance with specific aspects of the final rule’s training and testing components. GNYHA will seek member input on these draft recommendations. Once finalized, the recommendations will be sent to members and appropriate staff at the New York State Department of Health, which is the State survey agency for CMS. GNYHA also plans to convene a workgroup to discuss approaches to compliance within various health care settings.