Long-term care providers still struggling with COVID-19 and working under their activated emergency plans will continue to be exempt from their next required full-scale emergency exercise, according to newly revised federal guidance. 

Amy Stewart, MSN, RN, DNS-MT, QCP-MT, RAC-MT, RAC-MTA

The Centers for Medicare & Medicaid Services on Monday issued an updated memo regarding the emergency preparedness exercises exemption. The updated memo notes that many facilities are still operating under disaster/emergency conditions due to the pandemic and provides additional guidance for inpatient providers/suppliers.

The guidance states that if the facility is still operating under its currently activated emergency plan, any currently activated emergency plan will be recognized by surveyors as having met the full-scale exercise requirement for 2021 — even if it claimed the exemption for the 2020 full-scale exercise. 

“If the facility claimed the full-scale exercise exemption in 2020 based on its activated emergency plan and has since resumed normal operating status, the inpatient provider/supplier is expected to complete its required full-scale exercise in 2021, unless it has reactivated its emergency plan for an actual emergency during its 12-month cycle for 2021,” the guidance explains. 

Under normal conditions, federal regulations require facilities to conduct exercises to test its emergency plans and ensure staff are trained on their roles and processes. The agency allowed facilities a one-year exemption from the requirement during the coronavirus public health crisis. 

The guidance means that providers must determine if they are currently working under the activation of their emergency plan or not, to figure out their exemption status, explained Amy Stewart, vice president of education and certification strategy for the American Association of Post-Acute Care Nursing. 

“If they are, then they are exempt from having a full-scale emergency exercise until their next 12-month cycle,” Stewart told McKnight’s Long-Term Care News on Monday. “But if they are not working under the activation of an emergency plan, then they must have one during the current 12 month exercise cycle. Many facilities were exempt during 2020 due to the activation of their emergency plan and may need to look back to 2019 to determine when they conducted their last full-scale exercise.”