The Proposed Rule requires covered providers to develop and maintain a comprehensive EP program that includes four core elements: (1) conducting a risk assessment and establishing an emergency plan; (2) developing and implementing policies and procedures based on the risk assessment and emergency plan; (3) developing and implementing a communications plan including coordination with emergency response partners; and (4) developing and implementing a training and testing program that would require the provider to conduct drills and exercises to test the emergency plan.

The specific proposed requirements differ by provider category. For example, inpatient providers would be subject to additional proposed requirements related to emergency and standby power system capacities, including the requirement to maintain an emergency generator and onsite fuel source. All proposed requirements would have to be implemented within one year following the publication of any Final Rule.

Implementing these changes will require organizations to commit more time, talent, and resources in order to stay compliant. Organizations including the American Hospital Association have concerns regarding the cost of implementation. Fortunately, HSS’s EM Solutions® team can offset some of these expenditures by bringing in best practices and their experience to streamline the compliance process. Contact HSS National Director, Healthcare Emergency Management, Dr. Tracy Buchman Sonday at if your organization has questions or needs assistance with Emergency Management compliance.