Nancy J. Beckley (nancy@nancybeckley.com) is President of Nancy Beckley & Associates LLC, a rehab compliance consulting firm in Milwaukee, WI.
December signals the end of the year and sets the stage for the coming year. December is the ideal month to wrap up 2020 compliance processes, conduct a compliance program effectiveness review, update the compliance risk assessment, set the stage for the 2021 compliance program, and conduct another review and update of your emergency preparedness plan.
Emergency preparedness is the never-ending story of 2020. Notwithstanding significant disruption to post-acute care compliance processes in 2020 and emergency plan (EP) activation, EP may still have pressing needs for updated policies, procedures, and processes. The Emergency Preparedness Rule’s purpose was to “establish national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters.”[1] Requirements are applicable to 17 provider types subject to Centers for Medicare & Medicaid Services’ survey and certification program, including post-acute care providers (i.e., skilled nursing facilities, home health agencies, rehab agencies, and comprehensive outpatient rehabilitation facilities). Each of 17 provider types has its own set of EP regulations incorporated into their respective conditions of participation and requirements for certification.
