When CMS finalized the Emergency Preparedness Rule last fall they raised the emergency preparedness bar considerably for Ambulatory Surgery Centers (ASC).  Like all of the 17 affected providers, ASCs must comply with the major components of the rule:

  • Comprehensive Emergency Preparedness Program
    • Emergency Plan
    • Facility Based Risk Assessment
    • Policy & Procedures
    • Training, Exercise, & Evaluation
    • Communications Plan

Additionally, the ASC will need to incorporate local planning efforts and engage at the local level.  This may prove difficult as local emergency management agencies are being overwhelmed with requests from providers for support.  ASCs will need to partner with other local providers through healthcare coalitions and/or other local providers to incorporate into community planning efforts.

ASCs also have increased requirements and expectations around facility evacuation and shelter in place policies and procedures.  This also could provide an interesting exercise scenario where an ASC simulates evacuation due to a facility-specific threat to a receiving facility requiring community assistance meeting the needs of multiple partners while complying with the CMS Rule.

The key now is moving to action through the emergency preparedness cycle, starting with befriending local responders and moving through the risk analysis.  There are a lot of steps to take in the next 4.5 months, and we have more insight in our recent Overview and Analysis of the Interpretive Guidelines from earlier this month.


If you need help, join us for our ASC Specific Webinar Series designed to help ASCs gain compliance over the coming months.

Crisis Focus, LLC has focused expertise in healthcare emergency management, including CMS compliance. Please visit Crisis Focus’ CMS Emergency Preparedness resource page or contact us for more information.