New survey guidance on emergency preparedness planning, an updated version of QSO-20-41-ALL, clarifies CMS’ expectations when it comes to exemptions for training due to the pandemic.
During or after an actual emergency, the regulations allow for an exemption from an agency’s next required full-scale exercise, normally required every other year. Regardless of emergency activation, during alternate years, agencies still are required to conduct a facility-level table-top exercise, drill or workshop with a facilitator.
CMS has added the following scenario for a full-scale exercise exemption, noting some agencies are working under an activated emergency plan in 2022.
Scenario #4. Facility Z conducted a table-top exercise in June 2019 (based on its annual cycle). It is scheduled to conduct a full-scale exercise in June 2020. In March 2020, Facility Z activates its emergency preparedness program due to the COVID-19 PHE. The facility conducts its required exercise of choice in June 2021.As of March 2022, the facility continued to operate under an activated emergency plan. When must the facility conduct its next required full-scale exercise? What is the exemption based on the requirements?
Answer: The facility is exempt from the June 2020 scheduled full-scale exercise for that "annual year" and is required to complete an exercise of choice in June 2021, and a following full-scale exercise in June 2022. It is exempt from its next required full-scale or individual facility-based exercise which would have been in June 2020. However, since the facility is continuing to operate under its activated emergency plan in early 2022, the facility is exempt from the full-scale exercise in June 2022.