Understanding the Regulatory Mandate
Response testing in skilled nursing facilities is a critical component of regulatory compliance, mandated by the CMS Emergency Preparedness Rule. This rule requires facilities participating in Medicare and Medicaid to have an emergency preparedness program with annual training and testing. The foundation of this program is a thorough, documented, facility-based and community-based risk assessment.
The All-Hazards Risk Assessment as a Trigger
The risk assessment is a foundational trigger for the type and frequency of testing. It requires facilities to identify potential hazards to tailor their preparedness program. Potential risks include natural disasters like hurricanes, floods, or wildfires; man-made disasters such as hazardous material accidents or infrastructure failures; facility emergencies like power outages; and emerging infectious diseases.
Annual Testing and Exercise Requirements
CMS mandates specific annual testing to validate the emergency plan. Facilities must conduct one full-scale exercise (FSE) or a facility-based functional exercise annually, which may involve multiple agencies for a community-based FSE. Additionally, a second, different type of exercise is required annually, which can include another full-scale/functional exercise, a tabletop exercise, a mock disaster drill, or a workshop. If a facility activates its emergency plan during an actual event, it may be exempt from its next FSE for one year with proper documentation.
Special Triggers for Infectious Disease Outbreaks
Infectious disease outbreaks, like COVID-19, are major triggers for response and testing. Testing is required for symptomatic individuals regardless of vaccination status. A new confirmed positive case triggers outbreak testing and contact tracing. In cases where contacts are difficult to identify, facility-wide testing may be required. Ongoing surveillance testing every 3-7 days is necessary until 14 days after the last positive result.
Mandatory Fire and Evacuation Drills
Mandated by the Life Safety Code® and CMS, fire and evacuation drills are also essential response tests. Fire drills are required at least quarterly on each shift, with varying times and conditions. Annually, at least one fire drill per shift must include a simulated full evacuation to test this critical procedure.
Policies, Procedures, and Communication Testing
Drills also test a facility's policies and procedures, including shelter-in-place protocols, communication plans involving primary and alternate methods, and the ability to manage resources like medications and supplies during an emergency.
Comparison of Key Exercise Types
| Feature | Full-Scale Exercise (FSE) | Tabletop Exercise (TTX) | Mock Disaster Drill |
|---|---|---|---|
| Scope | Most comprehensive; involves multiple agencies and full operational response. | Discussion-based; involves senior staff and key decision-makers discussing a scenario. | Coordinated, supervised activity validating a specific function (e.g., evacuation). |
| Personnel | Typically includes facility staff, local emergency services, and community partners. | Leadership and key decision-makers lead a group discussion. | Staff and residents participate in a focused activity. |
| Resources | High resource investment; requires activation of equipment and personnel. | Low resource investment; primarily relies on group discussion. | Moderate resource investment; may involve specific equipment or procedures. |
| Purpose | To test a wide range of operational capabilities and inter-agency coordination. | To discuss plans, policies, and procedures for a specific scenario. | To practice and reinforce specific skills or procedures. |
| Documentation | Detailed after-action report and improvement plan. | Discussion notes and identified action items. | Drill log and evaluation of performance. |
Conclusion
Response testing in skilled nursing facilities is driven by regulatory mandates and potential or actual events, beginning with a risk assessment and including various annual drills and specific protocols for situations like infectious disease outbreaks. Understanding what triggers response testing in the skilled nursing facilities is crucial for compliance and resident safety.
For more detailed guidance on emergency preparedness regulations, consult the Centers for Medicare & Medicaid Services website [https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-emergency-preparedness/emergency-preparedness-rule].
