CMS exercise obligation
The same obligations as a major health system. A fraction of the staff.
Critical access hospitals and clinics carry federal emergency preparedness requirements written for organisations with a full-time emergency manager. Most do not have one. That gap is not a failure of will — it is a staffing reality, and it is the specific problem we exist to solve.
You already have to do the exercise.
The CMS Emergency Preparedness Rule requires participating providers to maintain an emergency plan, communications plan, training, and a testing programme. In broad terms, inpatient providers carry a two-exercise annual obligation — one full-scale or community-based, and one of choice such as a functional exercise, drill, tabletop, or workshop. Outpatient providers generally carry one, with a full-scale or functional exercise at least every other year.
The distinction worth knowing. The staff training requirement was relaxed from annual to every two years. We will not sell you annual training on a compliance argument that no longer holds. We will sell you training on competence, and exercises on compliance — and we will tell you which is which.
Requirements vary by provider type and change over time. Confirm what applies to you against current CMS interpretive guidance and with your own compliance officer. We identify gaps; we do not provide legal advice.
Tornado, ice, and a response time that decides your plan.
Response capability is the single largest local variable in survivability planning, because it determines how long your people are on their own. In much of Kansas that window is long: deputy coverage may be one unit across a large county, tactical resources are a regional call-out, and the nearest trauma centre may be forty-five minutes away or an air transport.
That is not a reason for alarm. It is a design input. It means on-site bleeding control capability moves from best practice to necessity, it means a helicopter landing zone should be identified and prepared before anyone needs it, and it means your plan should never assume a rapid tactical entry.
- Best-available refuge area. The critical technical question in every Kansas building — and the honest answer in many older facilities is that the designated shelter area is not adequate. Identifying that, documenting it, and connecting it to a mitigation funding path is a concrete, defensible piece of work.
- Ice storms and extended power loss. Access, staffing continuity, heating failure, and the supply position that follows a three-day road closure.
- Workplace violence. Nursing and patient-facing staff carry substantially higher exposure than most industries, and a large share of incidents are never formally reported — which means your internal counts understate what your people are living with.
We are the emergency management capability you do not have on payroll.
- Hazard vulnerability analysis. Facilitated as a working session with your leadership, producing scored, documented output rather than a form somebody filled in alone.
- Plan and annex development. All-hazards emergency operations plan aligned to NIMS and ICS, with the annexes that make it usable — surge, evacuation, shelter-in-place, communications, continuity.
- Staff training. De-escalation, workplace violence prevention, Stop the Bleed and casualty triage, and active threat response.
- The exercise programme. A multi-year progressive schedule with after-action reports and corrective actions tracked to closure — so the second year builds on the first instead of repeating it.
- Quarterly threat and trend intelligence. What changed in your county and what it means for your facility, delivered on a fixed calendar.
We come alongside your existing safety committee and your insurer’s loss-control resources. We do not replace either, and we reference their material rather than duplicating it.
What people ask us first
We are a small critical access hospital. Are we too small for you?
No — small providers are the reason the firm exists. Large consultancies cannot profitably serve a facility your size, which is why so many providers have never been offered real help. Our cost structure is built for exactly this.
Can you facilitate the exercise, or do we still have to organise it?
We design the scenario, facilitate the exercise, and write the after-action report and improvement plan. You provide the people and the building. Most providers find the after-action report is the part they were missing, because it is what turns an exercise into evidence.
Will you coordinate with our local fire, EMS, and law enforcement?
Yes, and we encourage it. Pre-incident coordination with the agencies who will actually respond is worth more than any document, and a community-based exercise satisfies more of the requirement than a facility-only one.
Do you work outside the Wichita area?
Yes. We serve providers across Kansas, and our co-founder covers the Phoenix, Arizona metro. Site work requires travel and we price it transparently; our quarterly threat and trend intelligence requires no site visit and is available anywhere.
How is this different from what our insurer already gives us?
Your carrier’s loss-control team produces good guidance at scale. What no carrier’s team is structured to produce is a site-specific, individually documented assessment with named owners and due dates on every recommendation, followed by the plan development, training, and exercise programme that make those recommendations operational. That is the gap we fill, and we work alongside them rather than against them.
One conversation, and you will know where the gaps are.
Bring your current plan and your last exercise record. Thirty minutes is usually enough to tell you whether you have a documentation problem, a training problem, or neither.