The Health and Human Services (HHS) Office of Inspector General (OIG) released a report on July 29 examining Centers for Medicare & Medicaid Services (CMS) controls related to hospital emergency preparedness for emerging infectious diseases.

Following a similar audit reported in 2021 that assessed the design and implementation of CMS controls, this audit addressed the operating effectiveness of CMS controls. OIG made five recommendations to CMS to expand and align surveyor training and processes to include key planning areas, to ensure emergency plans address all at-risk populations, and to ensure emergency plans consider the mental health needs of frontline staff. CMS concurred with these recommendations.

While this audit and report focused exclusively on acute care hospitals, it is important to note that CMS emergency preparedness requirements apply to all CMS-certified settings, including nursing homes, home health, hospice, and PACE providers.

Changes to emergency preparedness requirements, interpretive guidance, and surveyor protocols are likely to impact more than just acute care hospitals. LeadingAge members, especially those considered by CMS as “inpatient providers” similar to hospitals, should take note of these recommendations such as recommendations to include mental health considerations for staff in emergency plans.

Recommendations from previous OIG reports related to emergency preparedness also called for increased state oversight; implementation of standardized, required training; and improved surveyor guidance to allow state agencies to better evaluate the effectiveness of emergency plans. A Biden Administration-proposed rule enhancing emergency preparedness requirements was withdrawn from the Office of Management and Budget at the start of the Trump Administration and no further rule has been sent for review to date; however, it would be wise for providers to stay on alert for future regulatory action.