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Posted Jun 25, 20213 min Read
On June 21, 2021, the federal Centers for Medicare & Medicaid Services (CMS) issued a revised QSO 20-41, which provides guidance on an exemption for long-term care facilities that have activated their emergency preparedness plan from conducting the next required full-scale exercise, not the exercise of choice, based on the facility’s 12-month exercise cycle. The exercise cycle is determined by the facility (i.e., calendar year, fiscal year, or another 12- month timeframe). A similar exemption was issued in 2020 via the original QSO 20-41.
In summary:
Long-term care facilities will still need to conduct an exercise of choice if they have not already done so this year. For example, long-term care facilities could conduct a table-top exercise that assesses the facility’s response to COVID-19, including discussions surrounding the availability of PPE, quarantining procedures, and/or any other activities implemented during the activation of the emergency plan. The following After Action Report should be utilized to conduct such exercises, although the template may be modified depending on the exercise conducted.
After the exercise of choice is completed, best practices indicate the following next steps:
As a general reminder, on September 30, 2019, CMS published the “Medicare and Medicaid Programs; Regulatory Provisions To Promote Program Efficiency, Transparency, and Burden Reduction; Fire Safety Requirements for Certain Dialysis Facilities; Hospital and Critical Access Hospital Changes To Promote Innovation, Flexibility, and Improvement in Patient Care” Final Rule, which revised the requirements for emergency preparedness for a variety of inpatient and outpatient health facilities. Under the 2019 Final Rule, CMS requires long-term care facilities to: