Emergency Preparedness Drills

Can the COVID-19 pandemic be used for CMS Emergency Preparedness, Internal and External drill? Yes.

Not only can you use it, but it is also specifically required. In February of 2019, CMS rolled out an addition to Appendix Z (Emergency Preparedness Final Rule) which added “emerging infectious diseases” in regards to planning, preparing, and training for emergency situations (QSO19-06-ALL).  This event would definitely be viewed as a community event (for CMS) and as either an external or an internal (especially if a staff member of the patient was found positive) for AHCA.  If you shut-down during this time, you still had/have protocols and practices which you have implemented since re-opening (temperature checks, masks, telehealth, cleaning, etc.).  Staff actions, responsibilities, and procedures are what the surveyors are looking for.

With that said, I believe the pending question would be, “What about the After Action Report (AAR)”?  AAR’s are completed after an event has concluded and there has been discussion and analysis of strengths and weaknesses and an overall quality improvement plan.  How can you prepare an AAR for something you are still in the midst of?  My opinion is that we have been dealing with this for so long that definitive lessons have been learned and that there are/have been strengths and weaknesses identified that could be documented.  The obvious key here is to have something to put in front of the surveyor.  One surveyor suggests writing a monthly summary.  This would not only give you something to hand the surveyor but it would make compiling months and months of information a lot easier at the end.

Need help with your Life Safety and Facilities Management requirements? Our Life Safety Compliance Officer, Franklin Sands is equipped to help you stay in compliance and more importantly maintain a safe environment for your patients, visitors, and employees.