How to Run a Healthcare Emergency Preparedness Drill at Your Facility

To run a useful healthcare emergency preparedness drill, start with your facility’s risk assessment and emergency plan, choose a scenario that tests a real capability, assign clear roles, observe performance against specific objectives, and turn the findings into corrective actions with owners and retest dates. First confirm your facility’s applicable CMS, state, local, and accreditation requirements: the exercise schedule and acceptable formats depend on provider type, and the hospital rule does not apply universally.

Confirm the requirements for your facility

Before scheduling an exercise, identify the facility’s Medicare or Medicaid certification category and check the regulation and guidance that apply to it. CMS’s Emergency Preparedness Rule applies across provider and supplier types, but specific requirements vary. State and local rules and accreditor standards may add obligations. Consult the relevant regulation, CMS Appendix Z, and provider-specific CMS guidance before deciding which exercise counts or how often to conduct it.

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What the hospital rule requires

For Medicare-participating hospitals, 42 CFR 482.15(d) requires exercise testing at least twice a year. Each year, one exercise must be a community-based full-scale exercise or, if that is not accessible, a facility-based functional exercise. The hospital must also conduct an additional annual exercise from the permitted options. An actual emergency that requires activation of the emergency plan can exempt the hospital from its next required community-based full-scale or facility-based functional exercise. The 2024 edition of the regulation is available in the official CFR publication; confirm current requirements for your certification type.

That hospital cadence is not a universal healthcare-facility schedule. CMS guidance describes differences by provider and supplier category, including distinct provisions for some outpatient settings, religious nonmedical health care institutions, and organ procurement organizations. Do not assume that a hospital’s required format or frequency applies to another facility.

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What the hospital rule says about training and review

For hospitals, the training and testing program must be based on the emergency plan, risk assessment, policies and procedures, and communication plan. The program is reviewed and updated at least every two years; staff receive initial emergency preparedness training and further training at least every two years, and the hospital must demonstrate staff knowledge of emergency procedures. These are separate requirements from the hospital’s exercise schedule.

Choose a scenario and objectives from actual facility risks

Use the facility’s hazard vulnerability analysis or other risk assessment and emergency plan to select a scenario that could plausibly affect the site. The exercise should test a capability or gap—not simply replay a familiar scenario. A useful test might examine how the facility notifies staff, evacuates or relocates patients, tracks patients, maintains critical services, requests resources, or coordinates with community responders.

Write a small number of observable objectives before developing the scenario. For example, an objective might be whether the designated response lead activates the facility’s response structure, whether staff use a backup communication method when the primary channel is unavailable, or whether the facility can account for patients during a relocation. Objectives give participants a clear purpose and let evaluators record what happened against the plan rather than grade individual employees. ASPR recommends using exercises to address identified gaps and coordinating with response partners where useful in its healthcare preparedness capabilities guidance.

Select the exercise format that fits the objective

The format determines how much participants will do, how much can be observed, and what resources are needed. CMS recognizes multiple exercise approaches, but an exercise only satisfies a regulatory requirement if the format is permitted for the facility’s provider category and applicable schedule. CMS discusses exercise formats in QSO-21-15-ALL and its interpretive guidance.

A tabletop is not automatically a substitute for a live exercise, and a more realistic format is not automatically better. Choose the least disruptive format that can meaningfully test the objective and meet the applicable requirement.

Prepare people, materials, and safety controls

Set a date and define the exercise’s scope, affected locations, participating departments, and any outside organizations. Invite only the participants needed for the objectives, while including the roles that would actually make or carry out decisions. Prepare the scenario, timed injects or discussion questions, participant briefing, evaluator notes, and an evaluation plan.

Assign responsibilities before the exercise. Depending on its scale, name:

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• Exercise lead: Owns the scope, schedule, coordination, and overall conduct.
• Facilitator or controller: Presents the scenario and prompts, manages timing, and keeps simulated activity within the defined boundaries.
• Participants: Respond in their assigned facility roles using the plan and procedures.
• Evaluators: Observe actions and decisions against the objectives and capture relevant evidence.
• Safety contact: Handles safety concerns and helps distinguish a real incident from simulated activity.

For a small tabletop, one person may cover more than one exercise-management role, but participants should know who is facilitating and how to raise a concern. ASPR’s Medical Response and Surge Exercise Situation Manual describes leadership and operational, clinical, facilitation, and evaluation roles, and aligns healthcare exercise design with HSEEP principles.

Brief everyone on the objectives, scope, scenario boundaries, safety limits, and how to report an actual emergency or pause the exercise. For a live drill, coordinate with facility operations and community partners so simulated activity is not mistaken for a real event. Protect patient care: define what areas or activities are out of scope and how the exercise will stop if operations require attention.

Conduct the exercise and capture evidence

1. Open with a briefing. State the objectives, exercise rules, safety boundaries, participant roles, and the method for flagging a real event. Explain how participants should respond to simulated information.
2. Present the scenario in a controlled way. Deliver the narrative and injects at the planned pace. Give participants enough information to act, but do not coach them toward the intended response.
3. Observe actions and decisions. Evaluators should record what participants did, when they did it, and which procedure or communication channel they used. Focus on the objective, not individual performance ratings.
4. Track decision points and handoffs. Note communications, patient-accounting steps, resource requests, coordination with partners, and places where roles or written procedures are unclear.
5. Pause or stop if needed. Use the agreed safety process if a real incident, patient-care need, or other concern arises. Make sure participants know when simulated activity has ended.

Keep an exercise timeline and collect relevant records, such as evaluator notes, communication logs, completed forms, and resource requests. A record of what participants actually did is more useful for improvement than a general impression that the exercise went well or poorly.

Debrief, document, and close corrective actions

Hold a short hotwash soon after the exercise while participants’ recollections are fresh. Ask what worked, what was difficult, and what should change. Combine those observations with evaluator notes and relevant logs; distinguish direct observations from participants’ impressions.

For hospitals, CMS requires analysis and documentation of responses to exercises and actual emergency events, with revisions to the emergency plan as needed. The training and testing program’s review schedule does not replace documenting and addressing exercise findings. ASPR’s preparedness capabilities guidance recommends after-action reports and improvement plans, and using findings in the next preparedness cycle.

Create an after-action report and an improvement plan that turn each meaningful gap into a trackable action. For each action, record:

• The observed strength or gap and the related exercise objective.
• The specific change needed, such as clarifying a procedure, revising a contact list, or training staff on a process.
• An accountable owner, target date, and any resources or approvals required.
• How completion will be verified, including the method and timing of a retest when the action requires one.

Update plans, procedures, and training where findings warrant, assign the corrective work to a named owner, and schedule a retest that checks whether the change resolved the original gap. Keep the report, improvement plan, and verification records with the facility’s preparedness documentation.

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CMS complianceemergency exercisesemergency preparedness drillhealthcare emergency preparednesshealthcare facility