New CMS Requirements Tricks & Tips

The following “Tips & Pointers” are intended to help healthcare organizations develop their new Comprehensive Emergency Management Plans (CEMP) in compliance with the new CMS Emergency Management Rules.  Please do not consider the following as the “be-all, end-all” solution to developing a CEMP.  We’re providing this information as a value added service to help our partners who’ve never developed these plans before.  Healthcare organizations who are familiar with CEMP development may find this information useful as well.

Some additional “Pointers”:

  • There are several references in the CMS Emergency Management rules about maintaining a list of outside suppliers and vendors.  It’s not necessary to insert this litany of information in several spots within your plans.  We suggest referencing an Attachment where this contact information is maintained.  Then, when it’s time to update you review the one Attachment and make changes as needed.  This approach also gives your organization one place where this information is maintained making accessing it easier and far more efficient.
  • Some healthcare agencies are concerned about including a staff roster in their plans with complete contact information for security reasons.  Instead, consider including a reference to your personnel system and instructions on who can access that system or how to access this information.  They key is to ensure your 2nd and 3rd tier leadership can access personnel contact information quickly no matter where it’s kept.
  • Your CEMP should be broken into separate Annexes for specific responses.  For example, during a fire emergency it’s not necessary to list the specific steps to take in the CEMP.  Those details should be in an CEMP Annex written in a checklist format.  The same concept applies to other threats or circumstances where your agency may need written procedures.

We’re quite interested in your feedback.  Please let us know if these “Tips & Pointers” were beneficial.”