Home Health & Hospice Week

Interpretive guidelines are out.

If you’ve been waiting (against CMS’s advice) to move forward with your compliance plans for the emergency preparedness rule issued last September, your wait is over. The Centers for Medicare & Medicaid Services has issued an advanced copy of the interpretive guidelines and survey procedures.

Remember: Requirements from the emergency preparedness final rule, which takes effect Nov. 15, 2017, will apply to all 17 provider and supplier types, CMS says on its website. “Each provider and supplier will have its own set of Emergency Preparedness regulations incorporated into its set of conditions or requirements for certification,” the agency explains.

“An advanced copy of the interpretive guidelines and survey procedures is available and will be incorporated into the [State Operations Manual] under Appendix Z and applies to all 17 provider and supplier types,” CMS says in a June 2 Survey & Certification memo about the guidelines. “Since the Conditions of Participation (CoPs), Conditions for Coverage (CfCs) and requirements apply across providers and suppliers and only vary slightly, CMS has compiled the requirements under one appendix.”

In a March survey & cert memo, CMS urged providers to move ahead with their training and testing requirements in the rule, which must be completed by the Nov. 15 implementation date (see Eli’s HCW, Vol. XXVI, No. 16).

The guidelines are available via a link on CMS’s webpage at www.cms.gov/medicare/provider-enrollment-and-certification/surveycertemergprep/emergency-prep-rule.html. See the 72- page memo at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-29.pdf.