WYNTK: CMS recently released updated  aimed at strengthening emergency preparedness across care settings, including long term care.

• The update reinforces a clear message: effective planning, coordination, and continuous readiness are central to protecting patients, staff, and communities before, during, and after emergencies.
• 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.

Situational awareness: As health care organizations continue to navigate increasingly complex threats ranging from natural disasters to technological failures and public health events, this refreshed information provides a timely framework for resilience.

Key elements of the updated information:

1. A comprehensive all hazards planning approach: CMS underscores 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 are not 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, and plan evolution: Preparedness now centers on an organization’s capacity to maintain continuity of operationseven 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 reiterates 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 highlights 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 it matters: 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. 

Practical steps for compliance and readiness: Long term care providers are required to review and update emergency preparedness programs and their elements annually, per §483.73(a). These actions not only support compliance but also build a stronger safety culture and improve operational resilience. Consider using this update as an opportunity to: 

• Review the current regulatory requirements in Appendix Z of the State Operations Manual (SOM).
• Use AHCA’ s Emergency Preparedness regulations crosswalk tool to determine your survey preparedness.
• Revisit and revise your all hazards risk assessment (also known as a hazard vulnerability assessment, or HVA). You can use this HVA template
• Strengthen cross departmental training and ensure all staff understand their emergency roles.
  • Use this EP checklist to build, mature, and nurture your preparedness, including building an EP team.
• Evaluate and update communication protocols, both internal and external.
  • CMS requires LTC facilities to complete and document two annual exercises. One needs to be a full-scale exercise, and the second can be a tabletop exercise or mock disaster drill, or a second full-scale exercise, per §483.73(d).
• Conduct more frequent tabletop or full-scale exercises reflecting realistic event scenarios.
  • California Association of Health Facilities Disaster Preparedness and Arizona’s Disaster Ready site provide exercise and drill resources.
  • Enhance partnerships with local and regional emergency management entities. Review guidance on engaging with health care coalitions.

To help Medicare-participating long term care organizations, ASPR TRACIE created a Topic Collection area that includes by-provider checklists, encompassing CMS’s Appendix Z guidance, and also provides various other resources and tools. Long-term Care Facilities | ASPR TRACIE.  

• Additionally, ASPR TRACIE provides personalized support for requests for information and technical assistance (TA) and is accessible by toll-free number (1-844-5-TRACIE (587-2243)), email (askasprtracie@hhs.gov), or web form (https://asprtracie.hhs.gov/assistance-center/online-request-form).