Emergency Preparedness – Updates to Appendix Z of the State Operations Manual

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare®

CMS has posted updates to Appendix Z – Emergency Preparedness. QSO19-06-ALL has a posting date of February 1, 2019.  The updates are effective immediately.  Here are the key points CMS makes in the Discussion section of this Survey & Certification notice (I have bolded the key words for quick identification of the changes.  The changes themselves are identified in the last 54 pages of this 56-page S&C and are highlighted in red ink.):

“We are updating Appendix Z of the SOM to reflect changes to add emerging infectious diseases to the definition of all-hazards approach, new Home Health Agency (HHA) citations and clarifications under alternate source power and emergency standby systems.

After review, CMS determined it was critical for facilities to include planning for infectious diseases within their emergency preparedness program. In light of events such as the Ebola Virus and Zika, we believe that facilities should consider preparedness and infection prevention within their all-hazards approach, which covers both natural and man-made disasters.

Additionally, since the release of the Interpretive Guidelines for Emergency Preparedness in 2017, stakeholders and providers have asked for additional clarifications related to portable/mobile generators. CMS has added guidance under Tag E0015- Alternate Source Power as well as clarifications under Tag E0042- Emergency Standby Power Systems. Facilities should use the most appropriate energy source or electrical system based on their review of their individual facility’s all-hazards risks assessment and as required by existing regulations or state requirements. Regardless of the alternate sources of energy a facility chooses to utilize, it must be in accordance with local and state laws, manufacturer requirements, as well as applicable Life Safety Code (LSC) requirements.

If a facility risk assessment determines the best way to maintain temperatures, emergency lighting, fire detection and extinguishing systems and sewage and waste disposal would be through the use of a portable and mobile generator, rather than a permanent generator, then the LSC provisions such as generator testing, maintenance, etc. outlined under the National Fire Protection Association (NFPA) guidelines requirements would not be applicable, except for NFPA 70 – National Electrical Code. However, the revisions, as the provisions under emergency preparedness themselves, do not take away existing requirements under LSC, physical environment or any other Conditions of Participation that a provider type is subject to (for example to maintain safe and comfortable temperatures).

Finally, in addition to minor technical edits, CMS has also made the change to the HHA citations from 482.22 to reflect the regulatory citation 484.102.”

Please share the QSO19-06-ALL posting with your management team and review the CMS updates.