With the deadline for implementation and compliance with the new CMS Preparedness Rule quickly approaching, many provider types have started seeking additional clarification and guidance regarding the training and exercise requirements.  For those not familiar with training and exercise strategy or planning, the requirements may seem overwhelming upon initial review.  We have received several inquiries and questions specifically pertaining to these requirements, so I wanted to take a moment to highlight a few components.

The foundation of training and exercises and elements within this rule are based on the traditional preparedness cycle.  Once a risk assessment has been completed, with supporting policies, plans, and procedures, organizations must begin to train staff on their roles and responsibilities during an emergency or disaster.  Training requirements as listed in the rule, go beyond employees and must also include volunteers and contractors.  Training must be completed annually and documentation of all training is subject to review.  Any time a policy, plan or procedure is updated, refresher training must also be provided.  As with any compliance related issue, documentation is critical.

Once training has been provided, the preparedness cycle continues with exercises.  Exercises are designed to test training initiatives, policies, plans, and procedures so that an organization can evaluate response readiness.  Training and exercises should build off one another, meaning they should support one another and continually grow in scope and structure.  Training and exercise design and program development should be viewed more as a marathon, rather than a compliance “checkbox”.  It is important to strategize and to look at program development over several years, versus a single calendar year strictly for compliance purposes.

Exercise requirements for many of the provider types, includes 1 community-based full-scale exercise, in addition to 1 table-top exercise or second full-scale exercise.  A table-top exercise is discussion based, while a full-scale is tactical and operationally driven.  Real world events can be substituted for exercise requirements, pending appropriate documentation and after-action reporting is completed.  As with training, all exercises should be properly documented and are based off a rolling 12-month cycle.

There are many resources available to assist organizations with building a robust training and exercise program.  Homeland Security Exercise and Evaluation Program (HSEEP) is mentioned as a tool within the rule and can be used for reference.  Additional resources can be found on the US Department of Health and Human Services and CMS websites, in addition to many state and coalition sites.  Your local emergency management agency and community partners may also have additional resources and expertise to provide, so do not feel like you are alone in this stage of the preparedness cycle.  Successful programs involve multi-disciplinary teams and actively involve community stakeholders, so reach out to your partners for guidance and support.


If you need help designing your training and exercise program, join us for our “Creating a Realistic Training and Exercise Plan” webinar designed to help healthcare entities 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.