Regulation detail

E-Tag E-0018

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E-Tag E-0018 active

§403.748(b)(2), §416.54(b)(1), §418.113(b)(6)(ii) and (v), §441.184(b)(2),

Jurisdiction: CM Agency: Centers for Medicare & Medicaid Services
CMHC (100%) HOME_HEALTH (100%) HOSPICE (100%) IDD_RESIDENTIAL (100%) PRTF (100%) PSYCH_FACILITY (80%) SNF (100%)
Plain-English summary

This federal CMS emergency preparedness regulation requires facilities to develop and implement policies and procedures for tracking the location of on-duty staff and sheltered patients during and after an emergency event. If staff or patients are relocated, facilities must document the specific name and location of the receiving facility or other destination. The regulation explicitly applies to PRTFs, CMHCs, ICF/IIDs, inpatient hospice, PACE organizations, LTC facilities, ASCs, hospitals, and ESRD facilities, each with tailored requirements. Facilities have flexibility in choosing their tracking method (electronic or paper) but must ensure information is accurate, readily available, and shareable with emergency response officials.

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Regulation text
E-0018
(Rev. 204, Issued: 04-16-21; Effective: 04-16-21, Implementation: 04-16-21) 
 
§403.748(b)(2), §416.54(b)(1), §418.113(b)(6)(ii) and (v), §441.184(b)(2), 
§460.84(b)(2), §482.15(b)(2), §483.73(b)(2), §483.475(b)(2), §485.625(b)(2), 
§485.920(b)(1), §486.360(b)(1), §494.62(b)(1). 
 
[(b) Policies and procedures. The [facilities] must develop and implement 
emergency preparedness policies and procedures, based on the emergency plan set 
forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this 
section, and the communication plan at paragraph (c) of this section. The policies 
and procedures must be reviewed and updated at least every 2 years [annually for 
LTC facilities]. At a minimum, the policies and procedures must address the 
following:] 
 
[(2) or (1)] A system to track the location of on-duty staff and sheltered patients in 
the [facility’s] care during an emergency. If on-duty staff and sheltered patients are 
relocated during the emergency, the [facility] must document the specific name and 
location of the receiving facility or other location. 
*[For PRTFs at §441.184(b), LTC at §483.73(b), ICF/IIDs at §483.475(b), PACE at 
§460.84(b):] Policies and procedures. (2) A system to track the location of on-duty 
staff and sheltered residents in the [PRTF’s, LTC, ICF/IID or PACE] care during 
and after an emergency. If on-duty staff and sheltered residents are relocated 
during the emergency, the [PRTF’s, LTC, ICF/IID or PACE] must document the 
specific name and location of the receiving facility or other location. 
 
*[For Inpatient Hospice at §418.113(b)(6):] Policies and procedures. 

(ii) Safe evacuation from the hospice, which includes consideration of care and 
treatment needs of evacuees; staff responsibilities; transportation; identification of 
evacuation location(s) and primary and alternate means of communication with 
external sources of assistance. 
(v) A system to track the location of hospice employees’ on-duty and sheltered 
patients in the hospice’s care during an emergency. If the on-duty employees or 
sheltered patients are relocated during the emergency, the hospice must document 
the specific name and location of the receiving facility or other location. 
 
*[For CMHCs at §485.920(b):] Policies and procedures. (2) Safe evacuation from the 
CMHC, which includes consideration of care and treatment needs of evacuees; staff 
responsibilities; transportation; identification of evacuation location(s); and 
primary and alternate means of communication with external sources of assistance. 
 
*[For OPOs at § 486.360(b):] Policies and procedures. (2) A system of medical 
documentation that preserves potential and actual donor information, protects 
confidentiality of potential and actual donor information, and secures and maintains 
the availability of records. 
 
*[For ESRD at § 494.62(b):] Policies and procedures. (2) Safe evacuation from the 
dialysis facility, which includes staff responsibilities, and needs of the patients. 
 
Interpretive Guidelines applies to: §403.748(b)(2), §416.54(b)(1), §418.113(b)(6)(ii) 
and (v), §441.184(b)(2), §460.84(b)(2), §482.15(b)(2), §483.73(b)(2), §483.475(b)(2), 
§485.625(b)(2), §485.920(b)(1), §486.360(b)(1), §494.62(b)(1). 
 
NOTE: This does not apply to Transplant Programs, HHAs, Clinics, Rehabilitation 
Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy 
and Speech-Language Pathology Services, RHCs/FQHCs. 
 
Facilities must develop a means to track patients and on-duty staff in the facility’s care 
during an emergency event. In the event staff and patients are relocated, the facility must 
document the specific name and location of the receiving facility or other location for 
sheltered patients and on-duty staff who leave the facility during the emergency. 
 
CMHCs, PRTF’s, LTC facilities, ICF/IIDs, PACE organizations and ESRD Facilities are 
required to track the location of sheltered patients and staff during and after an 
emergency. 
We are not specifying which type of tracking system should be used; rather, a facility has 
the flexibility to determine how best to track patients and staff, whether it uses an 
electronic database, hard copy documentation, or some other method. However, it is 
important that the information be readily available, accurate, and shareable among 
officials within and across the emergency response systems as needed in the interest of 
the patient. It is recommended that a facility that is using an electronic database consider 
backing up its computer system with a secondary source, such as hard copy 
documentation in the event of power outages. The tracking systems set up by facilities 

may want to consider who is responsible for compiling/securing patient records and what 
information is needed during tracking a patient throughout an evacuation. A number of 
states already have such tracking systems in place or under development and the systems 
are available for use by health care providers and suppliers. Additionally, tracking of 
staff can often be more challenging based on the mechanism used for signing in and out 
for payment of staff based on hours worked, especially in the event of a power failure. 
Facilities can consider implementing a staff tracking system such as designating an area 
or protocol to check in with a designated person(s) during the emergency. 
 
Facilities are encouraged to leverage the support and resources available to them through 
local and national healthcare systems, healthcare coalitions, and healthcare organizations 
for resources and tools for tracking patients. While collaboration with healthcare 
coalitions is encouraged, it is not a requirement.
 Though the precise details of the actual 
collaboration with state and local emergency officials is not required to be documented, 
it is expected that sufficient information is documented to support verification of the 
process as part of the investigation. 
 
Facilities are not required to track the location of patients who have voluntarily left on 
their own, or have been appropriately discharged, since they are no longer in the facility’s 
care. However, this information must be documented in the patient’s medical record 
should any questions later arise as to the patient’s whereabouts. 
 
We also recommend facilities ensure they follow their evacuation procedures as outlined 
under this section during disasters and emergencies. Facilities are required follow all 
state/local mandates or requirements under most CoPs/CfCs. If your local community, 
region, or state declares a state of emergency and is requiring a mandatory evacuation of 
the area, facilities should abide by these laws and mandates. 
 
NOTE: If an ASC is able to cancel surgeries and close (meaning there are no patients or 
staff in the ASC), this requirement of tracking patients and staff would no longer be 
applicable. Similarly to ESRD standard practices, if an emergency was imminent and 
able to be predicted (i.e. inclement weather conditions, etc.) we would expect that ASCs 
cancel surgeries and cease operations, which would eliminate the need to track patients 
and staff. 
 
Survey Procedures 
• Ask staff to describe and/or demonstrate the tracking system used to document 
locations of patients and staff. 
• Verify that the tracking system is documented as part of the facilities’ emergency 
plan policies and procedures.