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Emergency preparedness: Medicare and Medicaid provider and supplier requirements

Michael Kotch ( is a Director and Healthcare Management Consultant at SunHawk Consulting residing in Arizona. Jan Elezian ( is a Director at SunHawk Consulting and resides in Denver, Colorado.

Is your organization’s emergency preparedness plan current, tested, and functioning? Earlier this year, the Department of Health & Human Services (HHS) added auditing of organizational plans for emergency preparedness planning, which now includes emerging infectious disease preparedness planning, to its Work Plan.[1] Centers for Medicare & Medicaid Services (CMS) plans to audit internal controls over hospital preparedness for an emerging infectious disease epidemic, such as coronavirus disease 2019 (COVID-19), along with hospital compliance and CMS’s emergency preparedness requirements.[2] Hospitals that participate in the Medicare program must comply with federal participation requirements, including requirements that hospitals engage in all-hazards emergency preparedness planning.[3] Business continuity plans are required under 42 C.F.R. § 422.504(o) and 42 C.F.R. § 423.505(p) to ensure restoration of business operations following disruptions, including emergencies, and should be outlined in each required facility’s emergency preparedness plan.

As we continue to experience the impact of COVID-19 on our healthcare system, it is a good time to reflect on lessons learned regarding emergency preparedness and response. CMS recommends that current business continuity plans include necessary planning for business operations disruption due to a public health emergency.[4]

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