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REGULATORY REVIEW


TTXs can be used to assess plans, poli- cies and procedures.” Examples of emergency scenarios


that ASCs may consider for either of the required exercises include earth- quakes, tornados, hurricanes, flooding, fires, cyber security attacks, single- facility disasters (power outages), med- ical surges (i.e., community disasters leading to an influx of patients), infec- tious disease outbreaks or active shoot- ers. ASCs should assess which emer- gencies are most appropriate to them. Please note that if your facility


must activate its emergency plan due to a disaster, the facility is exempt from one full-scale/individual-based exercise that year.


Emergency Preparedness Resources There are many resources available to help facilities comply with the new emergency preparedness requirements.


CMS Resources


CMS has a web page, www.cms.gov/ Medicare/Provider-Enrollment-and- Certification/SurveyCertEmergPrep/ Emergency-Prep-Rule.html, dedicated to resources that could help facili- ties as they implement this new rule. On this page, there is a link to Appen- dix Z of the State Operations Manual (SOM), which outlines the require- ments in the final rule that apply to all Medicare-certified providers and sup- pliers. The CMS website also includes an Excel spreadsheet for surveyors that breaks down the requirement by surveyor tags. While this document includes all facility types, ASCA has created a document specifically for ASCs so that our members can look at only the information that applies to ASCs. That document is available at www.ascassociation.org/emergency- preparedness-tool.


In addition, the CMS Survey & Certification Group (SCG) developed an Emergency Preparedness Basic Surveyor Training Course to help sur- veyors gain proficiency in surveying


Health and Human Services and the US Department of Homeland Security. These steps should be incorporated into every ASC’s policies and procedures.


CDC Training


and Educational Resources The Centers for Disease Control and Prevention (CDC) provides a number of training and educational resources. There are resources related to spe- cific 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 the CDC’s Clinician Outreach and Communication Activity (COCA) program.


OSHA Preparedness and Response Resources


for compliance with emergency pre- paredness requirements. Although this training course is geared toward sur- veyors, providers can access it and use it as a resource to see what the surveyors are being taught. The esti- mated course completion time for this training is 16 hours, and it is avail- able at https://surveyortraining.cms. hhs.gov/pubs/CourseMenu.aspx?cid= 0CMSEmPrep_ONL.


OCR Cyber Security Checklist With high-profile ransomware attacks threatening health care stakehold- ers of many kinds, cyber security has been a popular topic on the evening news recently. Interruption in commu- nication, including cyber attacks, are included in the elements that ASCs must consider when developing their emergency preparedness plans. The Office of Civil Rights (OCR)


has developed a checklist that explains steps facilities should take in response to cyber security incidents. These rec- ommendations address both internal facility response procedures as well as steps for reporting these cyber events to the OCR, the US Department of


The Occupational Safety and Health Administration (OSHA) provides pre- paredness and response resources for a variety of emergency scenarios. There are many good resources pertaining to national disasters and weather, which should be considered as part of an ASC’s all-hazards risk assessment. ASCs might also want to consider OSHA’s recom- mendations regarding planning for safe evacuations and deciding when to evac- uate or shelter in place.


FEMA Emergency Preparedness Trainings The Federal Emergency Manage- ment Agency (FEMA) supplies sev- eral training courses through its Emer- gency 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 pre- paredness resources in one place. Go to www.ascassociation.org/


federalregulations/emergency-prep aredness to access all resources.


Kara Newbury is ASCA’s regulatory counsel. Write her at knewbury@ascassociation.org.


ASC FOCUS JANUARY 2018 |www.ascfocus.org 23


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