In a recently released memo from the Centers for Medicare & Medicaid Services,

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facilities still tackling COVID-19 and utilizing their activatedemergency plans will remain exempt from their next required full-scale emergency exercise.

In addition to acknowledging that many facilities are still operating under emergency conditions, the new memo provides additional guidance for inpatient providers/suppliers.

Normal federal regulations compel facilities to test their emergency plans, ensuring staff are appropriately prepared to carry out these plans, should it become necessary.
Surveyors will be recognizing currently activated emergency plans as having met the full-scale exercise requirement for 2021, even if the exemption was claimed in 2020. The new guidance states,

“If the facility claimed the full-scale exercise exemption in 2020 based on its activated emergency plan and has since resumed normal operating status, the inpatient provider/supplier is expected to complete its required full-scale exercise in 2021, unless it has reactivated its emergency plan for an actual emergency during its 12-month cycle for 2021”.

According to Amy Stewart, vice president of education and certification strategy for the American Association of Post-Acute Care Nursing, facilities will have to determine if they meet the exemption status and proceed accordingly.

“If they are, then they are exempt from having a full-scale emergency exercise until their next 12-month cycle. But if they are not working under the activation of an emergency plan, then they must have one during the current 12 month exercise cycle. Many facilities were exempt during 2020 due to the activation of their emergency plan and may need to look back to 2019 to determine when they conducted their last full-scale exercise.”