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New RHC Final Rule – Patient Policies, Program Evaluation and Emergency Preparation

September 26, 2019 By Charles James Jr.

CMS Final Rule for RHCs and FQHCs!  Policy and Procedure Review, Annual Evaluation, and Emergency Preparedness requirements have been changed.

Document Number:  2019-20736 “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 Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. ”

The new final rule does the following:

  • changes the Policy Review and Annual Evaluations to biennial requirements.
  • changes the requirement for facilities to review their emergency preparedness program to at least biennial.
  • eliminates the need to document outreach efforts to local emergency resources, but facilities will “still be required to include a process for cooperation and collaboration” with them.
  • requires facilities to provide training biennially or every 2 years, after facilities conduct initial training on their emergency program.
  • requires that providers of outpatient services conduct only one testing exercise per year, that either a community-based full-scale exercise (if available) or conduct an individual facility-based functional exercise every other year.
  • In the opposite years, these providers may conduct the testing exercise of their choice, which may include either a 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.
  • if a provider experiences an actual natural or man-made emergency that requires activation of their emergency plan, inpatient and outpatient providers will be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event.

https://www.federalregister.gov/documents/2019/09/30/2019-20736/medicare-and-medicaid-programs-regulatory-provisions-to-promote-program-efficiency-transparency-and

The following are now biennial, not annual requirements:

Review of Patient Care Policies §491.9(b)(4)

RHC and FQHC Program Evaluation – §491.11(a)

Annual Review of Emergency Preparedness Program – §491.12

Annual Emergency Preparedness Training Program §491.12(d)(1)(ii)

The requirements for the following have been eased:

Documentation of Cooperation Efforts – §491.12(a)(4) has been eliminated

Annual Emergency Preparedness Testing – §491.12(d)(2) – only one required per year

 

Let us know if you have any questions!

Charles

Filed Under: Uncategorized

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