CMS Updates to QSO-20-41 Emergency Preparedness Exercise Exemption

On May 26, 2022, CMS released a newly updated version of QSO-20-41 which clarifies that providers are exempt from the 2021 and 2022 full scale exercise (FSE) so long as the facility is still operating under an activated emergency plan or has reactivated its plan due to COVID-19.

If you choose to utilize the exemption, you should ensure you document your organization's COVID-19 response in a formal After-Action Report (AAR). If you already have completed a COVID-19 AAR in a previous year, you should consider updating the AAR to reflect on-going response, lessons learned and opportunities for improvement. AHCA/NCAL members can access a
COVID-19 AAR Template on the website.

One key component to a comprehensive AAR is an Improvement Plan (IP). The IP should serve as roadmap for future plan enhancements and training focus.

Don't forget that documenting your organization's COVID-19 response will only address one of the two required annual exercises.  To comply with CMS requirements, facilities must still conduct one of the following:
  • Another full-scale exercise
  • Individual-facility-based functional exercise
  • Mock disaster drill
  • A tabletop exercise or workshop.
Read the full updated CMS QSO memo.

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