CMS SOM App. Z, Tag E-0038

(d)(1) Training program. The dialysis facility must do all of the following:

(i) Provide initial training in emergency preparedness policies and

procedures to all new and existing staff, individuals providing services under

arrangement, and volunteers, consistent with their expected roles.

(ii) Provide emergency preparedness training at least every 2 years.

Staff training must:

(iii) Demonstrate staff knowledge of emergency procedures, including

informing patients of—

(A) What to do;

(B) Where to go, including instructions for occasions when the geographic

area of the dialysis facility must be evacuated;

(C) Whom to contact if an emergency occurs while the patient is not in

the dialysis facility. This contact information must include an alternate

emergency phone number for the facility for instances when the dialysis

facility is unable to receive phone calls due to an emergency situation

(unless the facility has the ability to forward calls to a working phone

number under such emergency conditions); and

(D) How to disconnect themselves from the dialysis machine if an

emergency occurs.

(iv) Demonstrate that, at a minimum, its patient care staff maintains current

CPR certification; and

(v) Properly train its nursing staff in the use of emergency equipment and

emergency drugs.

(vi) Maintain documentation of the training.

(vii) If the emergency preparedness policies and procedures are significantly

updated, the dialysis facility must conduct training on the updated policies

and procedures.

Interpretive Guidelines for §494.62(d)(1).

Training Program- General

ESRD facilities are required to provide initial training in emergency preparedness

policies and procedures that are consistent with their roles in an emergency to all new

and existing staff, individuals providing services under arrangement, and volunteers.

This includes individuals who provide services on a per diem basis such as agency

nursing staff and any other individuals who provide services on an intermittent basis and

would be expected to assist during an emergency.

The training provided by the facility must be based on the facility’s risk assessment,

policies and procedures as well as the communication plan. The intent is that staff,

volunteers and individuals providing services at the facility are familiar and trained on

the facility’s processes for responding to an emergency. Training should include

individual-based response activities in the event of a natural disaster, such as what the

process is for staff in the event of a forecasted hurricane. It should also include the

policies and procedures on how to shelter-in-place or evacuate if the natural disaster

was not able to be forecasted. Training should include how the facility manages the

continuity of care to its patient population, such as triage processes and

transfer/discharge during mass casualty or surge events.

Furthermore, the ESRD facility must train staff based on the facility’s risk assessment.

Training for staff should mirror the facility’s emergency plan and should include training

staff and focus on procedures are relevant to the hazards identified. For example, for

EIDs, this may include proper use of PPE, assessing needs of patients and how to screen

patients and provide care based on the facility’s capacity and capabilities.

Many large ESRD Networks already implement trainings for staff regarding evacuation

procedures of the facilities. Through this requirement, all facilities are required to

demonstrate upon survey that that staff know the current evacuation plans, alternate

locations as well as their emergency contacts. Among the training, ESRD staff must be

able to demonstrate knowledge on procedures for informing patients on how to

disconnect themselves from a dialysis machine in the event of a disaster/emergency.

The ESRD facility must train staff on informing patients on whom to contact if the

facility is closed and cannot provide treatment due to an emergency situation and how

they can locate an alternate dialysis facility (e.g. Kidney Community Emergency

Response Program (KCER)) or hospital that can assist them.

The ESRD facilities are expected to rearrange patient appointments if a disaster or

emergency is forecasted through emergency notification channels, such as national

weather forecasts. For instance, for inclement weather such as a snow storm which could

cause community-wide closures and dangerous road conditions, we would expect the

facility to make the appropriate arrangements for patients to receive their dialysis or be

transferred into an inpatient setting to be provided with the appropriate care. Therefore,

ESRD facilities may gear their training and testing program to include evacuation

procedures in the event the facility is unable to close prior to an emergency.

All ESRD facility patient care staff are required to maintain current CPR certifications

and all nursing staff are required to be properly trained in clinical emergency protocols

that include the use of emergency equipment and emergency drugs. The training and

CPR certifications must be documented and maintained on file.

Survey Procedures

• Verify the facility has an emergency preparedness training program and that it is

updated at least every 2 years.

• Interview staff and ask them to describe the evacuation procedures and plan.

• Verify current copies of CPR certifications for all patient care staff are on file.