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Expanded Emergency Preparedness Guidelines for Long-Term Care Facilities

As we reported earlier this month, the Centers for Medicare and Medicaid Services (CMS) has issued memorandum QSO-21-15-ALL providing updated guidance (Appendix Z) for all providers covered by the federal Emergency Preparedness requirements.

Many of the revisions to Appendix Z focus on changes that tie back to a so-called "Burden Reduction Rule" issued in 2019 – specifically adjustment of cycles of updates required for non-long term care providers and changes to the training and testing program, which CMS had previously announced. However, CMS is also expanding the guidelines to further expand on best practices, lessons learned, and planning considerations for emerging infectious diseases (EIDs) in light of the COVID-19 Public Health Emergency. In Feb. 2019, in the wake of the emergence of Zika and Ebola, CMS added EIDs to Appendix Z, noting that it was important for facilities to include planning for infectious diseases within an all-hazards approach to emergency preparedness, and COVID-19 has motivated CMS to add additional content in this area.

In its revised form, Appendix Z now tops 100 pages in length. For the convenience of care centers, LeadingAge Minnesota has prepared a modified version of Appendix Z that includes only the requirements for long term care facilities (42 CFR §483.73) and related interpretive guidelines. We have removed regulatory citations and other content that is applicable only to one of the other 16 provider or supplier types affected by the Emergency Preparedness Final Rule (hospitals, hospice, ambulatory surgical centers, and so on).

CMS is still working on updates to the Emergency Preparedness Basic Surveyor Training Course to reflect the new changes, and, when complete, will be available for providers to view. We will watch for the update to be posted and provide a link for members when it is available.

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