On September 28, 2020, CMS issued guidance related to emergency preparedness testing exercise requirements in the context of the COVID-19 Public Health Emergency (PHE). In the guidance, CMS clarifies that the published Medicare and Medicaid Programs; Regulatory Provisions To Promote Program Efficiency, Transparency, and Burden Reduction; Fire Safety Requirements for Certain Dialysis Facilities; Hospital and Critical Access Hospital (CAH) Changes To Promote Innovation, Flexibility, and Improvement in Patient Care Final Rule (84 FR 51732) modifies the exemption to allow providers to be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event during which the provider activates their emergency plan.
The provider’s emergency preparedness testing scheduling and when the provider implemented their incident command center will impact what types of testing exercises will still be required. For example, if a hospital conducted a full-scale exercise test in January 2020 and then activated their incident command center in March 2020, they would still need to perform a tabletop or workshop exercise within 2020 but would be exempt from having to do a full-scale exercise in 2021. For additional details and other scenarios, see CMS S&C Letter QSO-2-41-ALL.