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News for Iowa Health Care Association members and their employees October 8, 2018
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Emergency Preparedness
Proposed rule: Emergency preparedness compliance

CMS issued the proposed rule, Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction, on September 20, 2018. CMS aims to reduce regulatory burden with this proposed rule, which includes two main issues of importance to skilled nursing centers and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID): Emergency Preparedness and Hospice.

What You Should Know
This proposed rule impacts regulations for 12 different types of health care providers and suppliers that must comply with the CMS requirements related to Emergency Preparedness. The following are the Emergency Preparedness provisions of the proposed rule that will impact nursing centers:

  • There is no longer a need to document efforts to contact local, tribal, regional, state, and federal emergency preparedness officials related to their participation in collaborative and cooperative planning efforts.
  • A training program for the emergency plan must be provided biennially (every 2 years), rather than annually, after the initial training for the emergency program. Additional training must occur when the plan is significantly updated.
  • The types of acceptable testing exercises that may be conducted is expended so one of the two annually required testing exercises may be an exercise of the provider's choice. This may include one community-based, full-scale exercise, if available, an individual facility-based functional exercise, a drill, or a tabletop exercise or workshop that includes a group discussion led by a facilitator.
  • Providers must review their emergency plan, policies and procedures, communication plan, and training and testing at least every two years (rather than annually).

Other Changes Proposed
There are proposed changes to the Hospice regulations when operating in a nursing center or an ICF/IID that relate to providing orientation to the nursing center and ICF/IID staff about the hospice philosophy and its approach to care. It is also important to note that under this proposal, ICF/IIDs must develop and maintain an emergency preparedness plan that must be reviewed and updated at least every two years. The ICF/IID must also conduct exercises to test the emergency plan at least twice per year.

Further, there are changes proposed to Long Term Care Hospitals and Critical Access Hospital Providers of Long-Term Care Services ("Swing Beds").

Additional Regulatory Reform Recommendations Requested
CMS is also asking for public comments on additional regulatory reforms for burden reduction in future rulemaking. Specifically, they are seeking public comment on additional proposals or modifications to the proposals set forth in this rule that would further reduce the burden on Medicare and Medicaid participating providers and suppliers and create cost savings, while also preserving the quality of care and patient health and safety. CMS notes that suggestions could include or expand on comments submitted in response to requests for information that were included in the 2017 prospective payment regulations for most provider types.

Comments to CMS
AHCA and the AHCA Emergency Preparedness Committee will be reviewing the proposed rule more carefully in the next few weeks and will provide more detailed information. Comments are due to CMS by 5 pm on November 19, 2018. 

For questions or comments relating to issues impacting nursing centers, contact Erin Prendergast at AHCA. For feedback relating to the ICF/IID provisions, contact Dana Halvorson at AHCA. 
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Education Calendar
MDS 101 - Introduction to MDS 3.0, October 16, West Des Moines
MDS 201 - Additional MDS 3.0 Training, October 17, West Des Moines
OASIS Blueprint for Accuracy, October 29-30, West Des Moines
Teepa Snow Dementia Care Webinar Series, October 31, 2018, 10:00-11:00 a.m., webinar (recording available)
SNF Medicare Review, November 1, Coralville
Assisted Living Management Certificate Program, November 5-9, West Des Moines
NW District Meeting & Education, November 6, 9 a.m. - 12 p.m., Storm Lake
Assisted Living Regulatory Nurse Class, November 8, West Des Moines
NE District Meeting & Education, November 8, 9 a.m. - 12 p.m., Cedar Falls
SE District Meeting & Education, November 13, 10 a.m. - 1 p.m., West Liberty
SW District Meeting & Education, November 15, 9:30 a.m. - 12:30 p.m., Atlantic
Assisted Living Management Certification, Online program
Online Dementia Care Training and Individual Certification Program
Click on the event link to learn more about each educational offering and to register. If you have additional questions, contact Georgene Olson at 800.422.3106.

West Des Moines area hotel discounts for IHCA members.

Map to the IHCA Education Center, 1775 90th Street, West Des Moines, IA.


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Regulatory and Survey
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Life & Fire Safety
Emergency Preparedness
Quality Improvement
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