ASCA has created a spreadsheet that identifies all parts of the rule and interpretive guidelines applicable to ASCs. That document is available to our members here.
CMS SOM Interpretive Guidelines
The requirements in the final rule apply to all Medicare certified providers and suppliers, and CMS has published interpretive guidelines in Appendix Z of the State Operations Manual (SOM) to aid compliance.
The CMS rule adds to a previous standard delineated in section 416.41(c) of Appendix L of the SOM which compelled ASCs to develop and maintain a disaster preparedness plan. That standard can be found here (pages 45-46).
CMS Final Rule Presentation
CMS has posted a presentation that provides a general overview of the contents of the final rule. The presentation also includes timelines for compliance, some additional FAQs, and an overview of the CMS Emergency Preparedness website.
OCR Cybersecurity Checklist
Cybersecurity has been a prevalent news topic recently, with high-profile ransomware attacks threatening a number of healthcare stakeholders. “Interruption in communication, including cyber-attacks” are included in the elements that ASCs must consider when developing their EP plans.
The Office of Civil Rights (OCR) has developed a checklist that explains steps facilities should take in response to cyber-security incidents. This includes both internal facility response procedures as well as steps to report cyber-events to the OCR, Department of Health and Human Services, and Department of Homeland Security. These steps should be incorporated in policies and procedures.
CDC Training and Educational Resources
The Centers for Disease Control and Prevention (CDC) provide a number of training and educational resources. There are resources related to specific emergencies such as bioterrorism or chemical emergencies, as well as trainings targeted to specific audiences such as public health professionals and clinicians. Additional resources are available through CDC’s Clinician Outreach and Communication Activity (COCA) program.
OSHA Preparedness and Response Resources
The Occupational Safety and Health Administration (OSHA) provides preparedness and response resources for variety of emergency scenarios. There are a number of good resources pertaining to national disasters and weather, which should be considered as part of the all-hazards risk assessment. ASCs may also want to consider OSHA’s recommendations regarding planning for safe evacuations and deciding when to evacuate or shelter-on-place.
FEMA Emergency Preparedness Trainings
The Federal Emergency Management Agency (FEMA) supplies a number of training courses through its Emergency Management Institute. There are web-based training courses that come out roughly every week, as well as a comprehensive course catalog that combines all FEMA emergency preparedness resources in one place.
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