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Over the past year, changes to the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers have quietly been introduced. With many providers and suppliers still unaware of what these changes mean, Atlas’ Emergency Fueling Team has determined five key things you need to know about these changes going forward.

1. Who do the new requirements affect?

The requirements affect more organizations than ever before. There are now 17 Medicaid and Medicare participating providers and suppliers affected by emergency preparedness requirements. Remember, compliance is required for participation in Medicare.

2. When do the new requirements go into effect?

Created in September of 2016, the new requirements will go into effect on November 16, 2017.  All Medicare and Medicaid participating providers and suppliers must comply with and implement all regulations within one year of November 15, 2017.

However, all training and testing requirements must be met by November 15, 2017.


3. What are the new requirements?

While there are several new requirements, some key changes include an indication that 72 hours of fuel assurance is no longer enough.  The requirements recommend holding agreements with suppliers, like Atlas Oil Company, that will guarantee continuity long beyond a mere 72 hours. This decision stems from the aftermath of Hurricane Katrina when several mission critical organizations were left without power following the depletion of emergency fuel.

Atlas can help you calculate and audit fuel run rates for generators. For more help with this, call 800.878.2000.

Additionally, extensive planning methods and annual reviews are new requirements along with regularly planned drills and exercises to test emergency procedures.

Hospitals, critical access hospitals, and long-term care facilities do have additional requirements that can be found within the Final Rule under Standard (e) for Emergency Power and Stand-by Systems.  More information on this topic can be found at cms.gov.

4. What are the four provisions of an Emergency Preparedness Plan?

The new requirements stress the importance of a strategic emergency preparedness plan through four basic provisions. These are Risk Assessment and Planning, Policies and Procedures, Communication Plan, and Training and Testing. Each of these areas have specific corresponding requirements.

Risk Assessment and Planning

  • Facilities must update their emergency plan annually—at the very least.
  • After a thorough risk assessment has been conducted using an “all-hazards” approach that focuses on capacities and capabilities of the facility, a corresponding emergency plan must be created.

Policies and Procedures

  • Just like emergency plans, policies must be updated annually.
  • Policies must address issues that include but are not limited to: subsistence needs, evacuation plans, procedures for sheltering, and patient and staff emergency tracking.

Communication Plan

  • Communication plans must comply with both State and Federal laws, and be coordinated with health care providers, state and local health departments, and emergency management systems.         

Training and Testing

  • All training and testing requirements must be met by November 15, 2017. A complete list of these requirements can be found at cms.gov.
  • Three types of exercises are included in the training and testing requirements: Facility-Based, Full-Scale Exercise, and a Table-top Exercise (TTX).
  • Facility-Based: Mindful of the risk assessment of each individual facility and includes aspects of risks unique to facilities like geographical location, resident/patient population, and surrounding community characteristics.
  • Full-Scale Exercise: Typically, full-scale exercises involve multiple agencies from a variety of disciplines, often including a “boots on the ground” element—like fire and police response. 
  • Table-top Exercise (TTX): Recommended as the step before Full-Scale Exercises, these are typically facilitated group discussions that involve narrated simulated scenarios in an informal setting.

5. What is an “all hazards” approach?

An “all hazards” approach involves a focus on capacities and capabilities that are critical for preparedness, regardless of emergency type.  Given that these preparedness plans must include types of emergencies particular to certain regions or areas, these are unique to each facility.  Types of hazards include, but are not limited to loss of power, interruptions in essentials like food and water, interruptions in communications, etc. More information can be found at cms.gov.

Still curious about what these changes mean for your facility or business?

Contact Atlas Oil today and speak with our Emergency Fueling Team to ensure your organization adopts best practices going forward under an “all hazards” approach.

800.878.2000 | www.atlasoil.com