04/02/2026
Survey Tip of the Week: Emergency Preparedness Deficiencies
Emergency preparedness continues to be an area of focus during surveys, with CMS identifying recurring deficiencies under Appendix Z. The Centers for Medicare and Medicaid Services (CMS) has developed a Frequently Cited Emergency Preparedness (EP) Citation & Potential Impact resource to help providers better understand how these requirements are evaluated and commonly cited. This resource highlights key compliance gaps and offers insight into surveyor expectations.
To further support providers, ASPR TRACIE has created the CMS Emergency Preparedness Rule webpage, which includes provider-specific checklists aligned with Appendix Z, as well as additional tools and resources to assist with compliance. This includes by-provider checklists, encompassing CMS’ Appendix Z guidance, and also provides various other resources and tools. CMS has identified the following as the top five most commonly cited emergency preparedness deficiencies in nursing homes:
- Emergency preparedness testing requirement
- Development, review and updating of the emergency preparedness plan
- Long-Term Care emergency power
- Subsistence Needs
- Emergency preparedness training
Surveyors are evaluating not only whether required elements are in place, but also whether they are current, implemented, and reflective of the facility’s operations and risks. Deficiencies often occur when plans are not updated, drills are not conducted or documented appropriately, or staff are unable to demonstrate knowledge of their roles during an emergency.
CMS also offers free on demand emergency preparedness training through the QSEP portal. This course is the same training used for surveyors and provides a helpful overview of regulatory requirements and the survey process. CMS notes that facilities may benefit from completing this training to better understand expectations and identify potential gaps in their programs.
