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The CMS Final Rule for Emergency Planning and Preparedness – Are You in Compliance?

CMS Final RuleA significant number of healthcare providers in the United States must soon comply with a federal agency regulation (81 CFR 63859) authored by the Obama administration called the CMS Final Rule for Emergency Planning and Preparedness. The deadline for compliance – November 15, 2017 – is rapidly approaching. The rule applies to all healthcare providers and suppliers that accept Medicare or Medicaid.

In this video, Dr. Donald A. Donahue, Jr., a faculty member of the University of Maryland University College (UMUC), explains that far too many healthcare providers in America are insufficiently prepared for emergencies. One factor influencing the promulgation of the Final Rule by the Centers for Medicare & Medicaid Services in September 2016 is the existence of inconsistency with respect to emergency preparedness across all healthcare provider types, from hospitals and hospices to ambulatory surgical centers and long-term care facilities (e.g., nursing homes). What, specifically, must providers do by November 15, 2017 to make sure they comply with the Final Rule? Recent natural disasters such as Hurricanes Katrina, Ike, and Sandy each exposed serious inadequacies across the healthcare system regarding the ability of providers to continue normal operation in the face of extreme weather conditions, surging patient volumes, and other pressures that can impede business continuity. According to Dr. Donahue, before the Final Rule takes effect, all healthcare facilities subject to the CMS mandate must take concrete steps toward developing comprehensive plans in the realm of disaster preparedness. Failure to do so, or failure to do so in an adequate or timely manner, can have repercussions ranging from increased reporting requirements to withholding of funding. Providers that do not comply may even face expulsion from the Medicare and Medicaid programs and risk being unable to continue as financially solvent organizations.

Recently, the Centers for Medicare & Medicaid Services issued an advance copy of interpretive guidance for the Final Rule in the form of a revised Appendix Z of the State Operations Manual (SOM). According to the introduction to the revised Appendix Z, “[t]he interpretive guidelines and survey procedures in this appendix have been developed to support the adoption of a standard all-hazards emergency preparedness program for all certified providers and suppliers while similarly including appropriate adjustments to address the unique differences of the other providers and suppliers and their patients.”

For more information on this important topic, please contact the American Board of Physician Specialties® (ABPS). The ABPS is the official certifying body of the American Association of Physician Specialists®, Inc.

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Far too often, medicine is led by less than 5% of non-practicing physicians taking away and replacing the voice of the 95% of physicians practicing and placing patient safety and care first on the front lines every day. The American Board of Physician Specialties has raised the standards in physician board certification not only in the quality of their boards of certification, but in hearing and allowing for the voice of those active physicians caring directly for patients. Having been a part of the ABPS over the last 28 years has allowed me to grow as a woman leader in a field often wrought with challenges. It helped me and others raise the bar of the standards of care in my specialty, Emergency Medicine, through their Board Certification in Emergency Medicine (BCEM). ABPS also helped raise the standards of care for 21st century medicine through their certifications in other specialties, particularly in Integrative Medicine & Disaster Medicine. Having physician voices heard matters to medicine and is essential in the betterment of patient safety and care.

Sarah E. Gilbert, MD, FAAEP
Sarah E. Gilbert, MD, FAAEP
Emergency Medicine
On October 18, 2007, President George W. Bush released Homeland Security Presidential Directive 21 (HSPD-21), calling on our nation, among other initiatives, to “collectively support and facilitate the establishment of a discipline of disaster health”. It is a great testament to the wisdom and foresight of the American Board of Physician Specialties that it immediately set to work and created, within the short span of only one year, an educational blueprint and set of certification examinations, both written and oral, for a new subspecialty of disaster medicine—and it is why I chose to be part this vital initiative and this wonderful organization. This is but one of the many innovative programs initiated by the American Board of Physician Specialties over the years, and why I am proud to support its work on behalf of our nation’s public health.

Art Cooper, MD
Disaster Medicine
When the American Board of Physician Specialties offered to host the American Board of Integrative Medicine, ABPS became a landmark organization working to move medicine into the twenty first century. Certifying physicians who have completed rigorous academic training in Integrative Medicine ensures that the field of Integrative Medicine will continue to develop academically, clinically, and professionally. The leadership of ABPS continues to impress me - they are diligent in constantly innovating to provide certifications for physicians who want to advance their careers and their areas of expertise. I am honored to be a part of this organization.

Ann Marie Chiasson, MD
Integrative Medicine
There are many ways board certification advances a physician career. ABPS Board examination verifies your accuracy, precision, and reflects your mastery of your residency training verifying your expertise. ABPS Board certification demonstrates your level of expertise beyond your practice experience, primary education degrees, and training which are necessary for insurance reimbursement and practice privilege requirements. Attaining your ABPS Board Certification will clarify your purpose, secure your practice growth, and expand into leadership positions. Board certification can serve as an indication of a physician’s commitment to medicine, beyond the minimal standards and competency of training, their measurement to quality of care, and attaining an award for excellence.

Chris Kunis MD
Internal Medicine
When I think historically, advancement in medicine and patient safety and care has been driven by the diversity of people and scientific thought. That’s what I found at the ABPS and more. For over 60 years that is just who we are. I found a physician certifying body that provides a choice and voice to all physicians ensuring that patients are always placed first.

Jerry Allison, MD
Emergency Medicine
When I decided to pursue a full time role as a physician executive it was important to me to obtain additional professional training, education and work experience. Board certification through the ABPS in Administrative Medicine is validation of my efforts and a demonstration of dedication to professional development. We need more physicians to become full time health care executives, knowing there is a board certification option in Administrative Medicine encourages physicians to take the leap from full time clinical practice to healthcare organizational leadership.

Richard Paula, MD
Administrative Medicine
The American Board of Physician Specialties has provided me with the opportunity to demonstrate mastery of internal medicine through board certification. As a hospitalist, board certification is an expected credential, and hospitals recognize the American Board of Physician Specialties (ABPS) as one of the three standard credentialling bodies for Internal Medicine. Additionally, the ABPS has helped me develop leadership skills as a Board member and Committee Chairperson. ABPS has also helped me sharpen critical thinking skills as a test question developer and reviewer. The Allopathic (MD) and Osteopathic (DO) physicians in the ABPS are lifelong learners and frequently pursue multiple board certifications. I enjoy the camaraderie of my peers in ABPS.

Loren Jay Chassels, DO
Internal Medicine
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