On June 21, CMS issued a revision to QSO-20-41-ALL, which provides guidance on emergency preparedness. If a facility is still operating under its activated emergency plan, any currently activated emergency plan it will continue to be exempt from its next required full-scale emergency exercise.

The memo states:

The updated guidance only applies if a facility is still currently operating under its activated emergency plan. Facilities which have resumed normal operating status (not under their activated emergency plans) and were exempted from a full-scale exercise for its 2020 cycle, must conduct a full-scale exercise or an individual facility-based exercise for its next cycle.

For inpatient providers, including long term care facilities, the memo clarifies:

If the facility is still operating under its currently activated emergency plan, the plan will be recognized by surveyors as having met the full-scale exercise requirement for 2021 (even if it claimed the exemption for the 2020 full-scale exercise).

Members are encouraged to review the memo in its entirety.

Additional Resources

Template for COVID-19 Pandemic Facility After-Action Report to Meet Emergency Prep Requirements