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Compliance to Medicare Standard Disaster Preparedness Plan

by Sandy Cericola, RN

According to the World Health Organization (WHO), in the last decade, more than 2.6 billion people have been affected by natural phenomena such as earthquakes, tsunamis, landslides, cyclones, heat waves, floods or severe cold weather. These disasters lead to mass casualties (e.g., blunt trauma, crush-related injuries, drowning) that can overwhelm local medical resources and prevent them from delivering comprehensive and definitive medical care.

Essential surgical care at the firstreferral health facility reduces  the burden of disasters and allows tertiary-care facilities to focus on more complicated cases.

The map below displays information about the types of natural disasters prone to the different regions in the United States.

OR Today Magazine | AAAHC Update  | October 2013

Other natural disasters include: extreme weather, electrical storms, fires, pandemics, solar storms and solar flare effects.

Man-made disasters include: biological threats, chemical threats, dam failures, oil spills, chemical spills, explosions, nuclear accidents, power outages, terrorist attacks and wars.

If your facility is Medicare-certified, you must have a Disaster Preparedness Plan that meets the following three requirements (1):

1. The Ambulatory Surgical Center must maintain a written disaster preparedness plan that provides for the emergency care of patients, staff and others in the facility in the event of fire, natural disaster, functional failure of equipment or other unexpected events or circumstances that are likely to threaten the health and safety of those in the ASC.

2. The ASC coordinates the plan with state and local authorities, as appropriate.

3. The ASC conducts drills, at least annually, to test the plan’s effectiveness. The ASC must complete a written evaluation of each drill and promptly implement any corrections to the plan.

The goal of this article is to help you comply with the second requirement: the coordination of your plan with state and/or local authorities.

This requirement is also in the standards for accreditation agencies who conduct Medicare-deemed surveys including: the Accreditation Association for Ambulatory Health Care (AAAHC), The American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF) and the Joint Commission.

During a survey, the surveyor may ask for evidence of coordination with appropriate authorities.

The Medicare Interpretative Guidelines state that, “At a minimum, the ASC must have documentation that it has identified appropriate state and local agencies, and that the ASC has made these agencies aware.” (2)

How can you document compliance with the requirement? A letter or email to the appropriate agencies will satisfy this requirement.

If it’s time to update your disaster preparedness plan, there are numerous resources to help you, including:

The Centers for Disease Control and Prevention (CDC) Emergency Preparedness and Response website is the CDC’s primary source of information and resources for preparing for and responding to public health emergencies. Topics include: Natural & Severe Weather, Bioterrorism, Chemical Emergencies, Radiation Emergencies and Recent Outbreaks & Incidents.

The Federal Emergency Management Agency’s (FEMA) website business can assist in developing a preparedness program by providing tools to create a plan that addresses many hazards. This website and its tools utilize an “all hazards approach” and follow the National Fire Protection Association 1600 (NFPA) Standards on Disaster Emergency Management. NFPA 1600 is an American National Standard and has been adopted by the u.S. Department of Homeland Security.

The website has a sample Emergency Response Plan template for your use.

The World Health Organization (WHO), together with its partners, has worked towards disaster preparedness and response by creating the “WHO Disaster Management Guidelines: Emergency Surgical Care in Disaster Situations,” a comprehensive manual that details management of common injuries encountered in disaster situations.


1, 2, Department of Health & Human Services (DHHS) Centers for Medicare and Medicaid Services (CMS), “Interpretative Guidelines for Ambulatory Surgical Centers”, 416.41(c), Pages 4760. 5/18/2009

About the Author: Sandra A Cericola RN is Vice President of Clinical Services for Cericola & Associates, LLP, an organization that provides accreditation support to ambulatory surgery centers. She has been a surveyor for The Accreditation Association for Ambulatory Health Care (AAAHC) for 17 years. Sandra is also the past chairman of the Disaster Preparedness Committee of Huntington Landmark Association in Huntington Beach California. She can be reached by email at sandycericola@

OR Today Magazine | AAAHC Update  | October 2013



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