Emergency Preparedness Plans for Senior Living

In March 2022, the Centers for Medicare and Medicaid Services (CMS) released guidance on Emergent Infectious Diseases (EID) and planning for infectious diseases within the community emergency preparedness program. CMS determined it was critical for communities to include planning for infectious diseases after the coronavirus disease 2019 (COVID-19) public health emergency.

According to the CMS¹, the emergency plan supports, guides, and ensures a facility's ability to collaborate with local emergency preparedness officials. This approach is specific to the location of the facility and considers particular hazards most likely to occur in the surrounding area. These include, but are not limited to:

• Natural disasters
• Man-made disasters,
• Facility-based disasters that include but are not limited to:
  • Care-related emergencies;
  • Equipment and utility failures, including but not limited to power, water, gas, etc.;
  • Interruptions in communication, including cyber-attacks;
  • Loss of all or portion of a facility; and
  • Interruptions to the normal supply of essential resources, such as water, food, fuel (heating, cooking, and generators), and in some cases, medications, and medical supplies (including medical gases, if applicable).
• Emerging infectious diseases (EIDs) such as Influenza, Ebola, Zika Virus, and others
  • These EIDs may require modifications to facility protocols to protect the health and safety of patients, such as isolation and personal protective equipment (PPE) measures.

Additionally, the Agency for Healthcare Research and Quality (AHRQ) released a resource, “Incorporating Infection Prevention and Control into an Emergency Preparedness Plan”² outlining the critical components of a nursing home’s emergency preparedness plan. AHRQ also included a “Sample Disaster Preparedness Plan Letter to Families”.

AHCA/NCAL has developed and provided a sample policy for “Emergent Infectious Diseases for Skilled Nursing Care Centers”.³ The guidance will help communities prepare and incorporate infectious diseases into their current Emergency Preparedness Plan.

Per CMS, the successful adoption of the emergency preparedness requirements will enable all communities to better anticipate and plan for emergency needs. Below are additional resources available to communities for the development of an Emergency Preparedness Program:

[1]Appendix Z of the State Operations Manual: p.18 https://www.cms.gov/files/document/qso-21-15-all.pdf

² AHRQ: https://www.ahrq.gov/nursing-home/materials/prevention/emergency-preparedness-plans.html

³ AHCA & NCAL: “Sample Policy for Emergent Infectious Diseases for Skilled Nursing Care Center”https://www.ahcancal.org/Survey-Regulatory-Legal/Emergency-Preparedness/Documents/EID_Sample_Policy.pdf

Additional Resources:

• Appendix PP of the State Operations Manual: F838 Facility Assessment, F880 Infection Control, and F882 Infection Preventionist: https://www.cms.gov/medicare/provider-enrollment-and-certification/guidanceforlawsandregulations/downloads/appendix-pp-state-operations-manual.pdf
• Emergency Preparedness Requirements for Medicare & Medicaid Providers: https://asprtracie.hhs.gov/cmsrule
• CMS Emergency Preparedness Rule: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule
• Appendix Z of the State Operations Manual: https://www.cms.gov/files/document/qso-21-15-all.pdf
• CMS Quality, Safety & Oversight Group Emergency Preparedness website: https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertemergprep