CMS SOM App. G, Tag J-0136

(3) Emergency. The clinic . . . provides medical emergency procedures as a first

response to common life-threatening injuries and acute illness and has available the

drugs and biologicals commonly used in life saving procedures, such as analgesics,

anesthetics (local), antibiotics, anticonvulsants, antidotes and emetics, serums and

toxoids.

Interpretative Guidelines § 491.9(c)(3)

The RHC ensures staff is available to appropriately handle medical emergencies as a first

response to common life-threatening injuries and acute illnesses at all times the clinic

operates. The clinic maintains the types and quantity of drugs and biologicals commonly

used by first responders in accordance with accepted standards of practice. The RHC’s

patient care policies are expected to address which drugs and biologicals it maintains for

emergencies and in what quantities. The RHC must maintain a supply of commonly used

drugs and biologicals adequate to handle the volume and type of medical emergencies it

typically encounters. The following are categories of drugs and biologicals commonly

used in life saving procedures:

• Analgesics;

• Local Anesthetics;

• Antibiotics;

• Anticonvulsants; and

• Antidotes, emetics, serums & toxoids.

While each category of drugs and biologicals must be considered, all are not required to

be stored. For example, it is appropriate for a RHC to store a small volume of a

particular drug/biological, if it generally handles only a small volume/type of a specific

emergency. Likewise, it may be acceptable if the clinic did not store a particular

drug/biological because it is located in a region of the country where a specific type of

emergency is not common (e.g., snake bites). Nonetheless, when determining which

drugs and biologicals it has available for purposes of addressing common life-threatening

injuries and acute illnesses, the RHC should consider, among other things, the

community history, the medical history of its patients and accepted standards of practice.

The clinic should have written policies and procedures for determining what

drug/biologicals are stored and that address the process for determining which

drugs/biologicals to store, including identifying who is responsible for making this

determination. The RHC should be able to provide a complete list of the

drugs/biologicals that are stored and in what quantities.

Survey Procedures § 491.9(c)(3)

• Review the RHC’s written policies and procedures to determine the types and

quantities of drugs/biologicals it stores for medical emergency purposes,

• Review all of the drugs/biologicals that are stored and available in the RHC,

including in what quantities, to verify the RHC maintains a supply of commonly used

drugs and biologicals adequate to handle the volume and type of medical emergencies

it typically encounters.

• Ask RHC staff how they determine the quantity and specific types of drugs and

biologicals to have on hand. How do they ensure that the specified drugs and

biologicals are on hand in the quantities specified per RHC policy and have not

expired?

• Any findings as a result of the inquiry, may lead to noncompliance under 42 CFR

491.9(b).