Emergency Preparedness- Updates to Appendix Z of the State Operations Manual (SOM)

To: Administrators and Directors,

The Centers for Medicare and Medicaid Services (CMS)) has made revisions, effective immediately, to Appendix Z of the State Operations Manual (SOM), which is the Interpretive Guidance for Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. These are not changing any requirements, but just adding some clarifications. You can view or download the revised Appendix Z at: https://drive.google.com/file/d/1yEoPpmWUOGHXAoeE3lgKnCEON_RN_W9I/view?usp=sharing 

Changes are highlighted in red italics.

The main revisions include: 

– (Definitions) CMS is adding “emerging infectious diseases” or “EIDs” to the current definition of all-hazards approach, after determining that is critical for facilities to include planning for infectious diseases within their emergency preparedness programs. Examples of EIDs include Influenza, Ebola Virus, Zika and others.

– (Tag E-0004)It added EIDs to the list of hazards that facilities should include as their conduct their risk assessments. 

– (Tags E-0015 and E-0042) Alternate Source Power and Emergency Power Standby Systems, clarifies that facilities should use the most appropriate energy source or electrical system based on their facility’s risk assessment and as required by existing regulations or state requirements. Whatever alternate source is selected must meet local and state laws, manufacturer requirements and Life Safety Code requirements. If a facility chooses a portable and mobile generator (rather than permanent generator), then the LSC provisions, e.g. generator testing/maintenance/etc under NFPA guidelines would not apply, except for NFPA 70-National Electrical Code. 

These updates are NOT related to the proposed rule changes published in the Federal Register September 20, 2018, related to reducing the regulatory burden on facilities in meeting the emergency preparedness requirements. We still await guidance on the outcome of that proposed rule. 

If you have questions regarding the emergency preparedness rule, please contact SCGEmergencyPrep@cms.hhs.gov or Melanie Roth at CDPHE, Melanie.Roth-Lawson@state.co.us

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