CMS Emergency Preparedness Testing Clarification

CMS continues to make clarifications to the Emergency Preparedness regulation.  A revision to QSO-20-41-ALL was released on June 21, 2021 and was directed to State Surveyors.  As previously established, outpatient providers of services, such as home health and home hospice, are required to test their program annually.  In 2019, CMS changed the testing requirement for outpatient providers to alternate the type of testing exercise every year.  The latest revision clarifies if the provider fully activates its emergency preparedness plan during a given year, it may only replace the required full scale exercise.  In other words, if a full-scale exercise was scheduled in 2020 and the agency fully activated its emergency preparedness plan due to the public health emergency, an exercise of choice (community-based full-scale exercise as available, individual facility-based functional exercise, mock disaster drill, table-top exercise or workshop) is required for 2021 (as established by the agency’s or hospice’s calendar of testing).  Mock disaster drills, table-top drills, and workshops may be used only as an exercise of choice.

What does this mean for home health and home hospice providers?  The Public Health Emergency due to COVID-19 may apply as a substitute only for a full-scale exercise if the agency fully  implemented its emergency preparedness plan.  This means an exercise of choice must be performed according to the agency or hospice’s cycle of testing.  Home health and hospice providers should establish a calendar to determine the type of testing to be performed each year.  Ensure documentation of each test and actual emergency is up-to-date to avoid being cited during a State Survey.