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Friday, June 23, 2017

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Are you ready for July 5?
The Centers for Medicare & Medicaid Services (CMS) adopted the 2012 edition of NFPA 101: Life Safety Code® as part of its Conditions of Participation (CoPs) last year. July 5 marks the date for health care facility teams to verify compliance with the code since its adoption.

Verifying compliance with the Life Safety Code as adopted by the CMS Conditions of Participation presents its challenges - especially since the code has not been adopted as written and since state surveyors may interpret aspects of the code differently.

How do occupancy requirements in the CoPs affect hospitals and health facilities and what does this mean for the greater community?

Differences for Health Care Occupancies
The 2012 edition of NFPA 101 addresses several different health care occupancies. Differences exist for occupancy types within the CoPs and some of the adopted codes. Comparing health care occupancies with business occupancies often presents a Catch 22 for health care facility managers.

For example, a business occupancy may not be subdivided into two or more smoke compartments. For health care occupancies, the smoke compartments are needed to shelter in place and move patients horizontally instead of evacuating them from a building. Evacuation may be more prudent for these types of uses, so subdividing the space may not have any benefit for the occupants. In some cases, it may even set false sense of security.

What This Means for the Community
What's concerning about requirements for various health care occupancies in the Conditions of Participation is that they have the potential of reducing access to health care in the community. Today, many health care clinics exist as business occupancies. These clinics are often located in office buildings in an effort to integrate the delivery of care across cities, suburbs, and small towns.

However, business occupancies are challenged by the adoption of the Life Safety Code as part of CMS Conditions of Participation because they are, in some cases, expected to meet standards of ambulatory or health care occupancies. These buildings often do not have the existing infrastructure in place to be transformed into a health care occupancy; the process of changing occupancies for many facilities is simply too expensive. Thus, over the last year, some facilities have had to decide if upgrades are feasible or they are left with no other option than to shut down and close its doors.

"If hospitals are not able to use structures found in strip malls or other traditional business buildings, this could negatively impact the delivery of care to communities," said Chad Beebe, AIA, FASHE, deputy executive director and advocacy leader of ASHE.

What's Next for Health Care Facility Managers?
The full impact of CMS adoption of the Life Safety Code on population health and the community at large is still to be determined. In the meantime, facility managers in all occupancy types should verify compliance with CMS by July 5.

With hopes of guiding health care facility teams, ASHE has compiled a list of resources that may help you prepare for compliance with CMS Conditions of Participation for NFPA 101:

  • Resources for CMS Conditions of Participation. This ASHE web page includes a variety of resources and guides to keep you up to speed with CMS Conditions of Participation. Under the Life Safety Code section of this web page exists an exclusive ASHE member comparison chart of business and ambulatory occupancy requirements - intended to help facility managers decipher the differences.

  • Hospital Conditions of Participation Accreditation Crosswalk. This exclusive ASHE member resource provides a comparison of the regulations applicable to most hospitals. It lists out CMS language; specific Joint Commission EP references; the 2012 edition of NPFA 101 references; 2015 edition of ICC references; and additional ASHE commentary with guidance.

  • Exploring the Occupancies of the CMS Conditions of Participation. This ASHE Annual Conference session will take place August 7 in Indianapolis. It will cover several different health care occupancies and discuss the differences within the Conditions of Participation and some of the adopted codes. The presenters will also lead an open discussion on the next steps for future Life Safety Code adoption and participation opportunities for attendees. Click here to register for the ASHE Annual Conference and participate in this session (you will have the option of joining or renewing your ASHE membership upon registration).

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