CMS Updates Health Care Provider Guidance Requirements

WASHINGTON—The Centers for Medicare & Medicaid Services (CMS) recently released updated Health Care Provider Guidance aimed at strengthening emergency preparedness across care settings, including long term care. This guidance is in alignment with current long term care regulatory requirements under Appendix Z of the state operations manual (SOM), there are no regulation or surveyor guidance changes.  

Per orders from CMS, Medicare participating providers and suppliers have been required to have an established emergency preparedness program—specifically, 18 providers and suppliers are required to maintain a comprehensive emergency preparedness program, based on an all-hazards approach, encompassing four primary elements, including risk assessment and planning, policies and procedures, a communication plan and a training and testing program. 

The American Health Care Association (AHCA) said the update reinforces the message that effective planning, coordination and continuous readiness are central to protecting patients, staff and communities before, during and after emergencies.

Key Elements of the Updated Information:

1. A Comprehensive All-Hazards Planning Approach  

CMS underscoreed that emergency preparedness must begin with robust hazard identification, commonly known as a hazard vulnerability assessment (HVA), addressing both direct impacts to a facility and indirect threats affecting the surrounding community—such as utility disruptions or supply chain interruptions. This approach ensures plans aren’t designed for just one scenario but can flex to address a wide spectrum of events.  

2. Strengthening Mitigation Strategies

The information elevates the importance of proactive mitigation, encouraging organizations to minimize risk before an event occurs. This includes safeguarding residents, ensuring staff receive appropriate safety training and integrating mitigation into day-to-day operations. These mitigation plans can be built into your HVA and should be documented in your EP Plan. Notably, CMS emphasizes that mitigation is not a standalone phase—it directly shapes response and recovery readiness.  

3. Preparedness Through Training, Testing & Plan Evolution

Preparedness now centers on an organization’s capacity to maintain continuity of operations even when essential services are compromised. This requires ongoing review of hazard analyses, facility capabilities and resource availability, at least annually as per the regulatory requirements.  

CMS reiterated that emergency plans must be regularly trained, tested and revised, ensuring teams know their roles and systems perform under stress.  

4. A Coordinated, System-Level Response

CMS highlighted that no provider operates in isolation during an emergency. An effective response is built on coordination with public health agencies, emergency medical services, health care coalitions and other community partners. Establishing, maintaining and documenting partnerships should be part of your annual EP updates.  

Why This Update Matters for Providers

The AHCA said for leaders responsible for quality improvement and emergency preparedness, this guidance is more than regulatory direction—it’s a blueprint for safer, more resilient health care delivery. The emphasis on comprehensive planning, staff readiness and community collaboration aligns with best practice emergency management principles and supports providers in meeting both operational and regulatory expectations.