CMS Proposed Rule
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1 CMS Proposed Rule CMS: 2012 Life Safety Code Adoption 2014 American Society for Healthcare Engineering 155 N. Wacker Drive, Suite 400 Chicago, IL ashe.org
2 Important Dates Publication of the proposed rule: April 16, 2014 Comments due: June 16, Search: Fire Safety
3
4 Review Rule and Comments
5 Comment Now
6 Support 2012 Adoption On the whole, ASHE supports the adoption of current codes. The new codes: Incorporate lessons learned Reduce conflicts Are consistent with other codes Recognize changes in heath care delivery Provide greater flexibly Incorporate categorical waivers
7 Support 2012 Adoption
8 Support 2012 Adoption ASHE Strategic Imperative - Unified Codes While regulations are a critical part of keeping patients, staff, and visitors safe, current codes and standards still have much room for improvement. ASHE is working to improve outdated codes, conflicting codes, codes not based on science, and inappropriate code interpretations.
9 Why do we use consensus codes? OMB Circular A-119 (1998) intended to: Encourage federal agencies to benefit from the expertise of the private sector Promote federal agency participation in such bodies to ensure creation of standards that federal agencies can use Reduce reliance on government-unique standards where an existing voluntary standard would suffice
10 Overview PROPOSED RULE
11 Adoption, change in definition (b)(2)(i) Changes definition of health care occupancy from applying to 4 or more patients to regardless of the number of patients served Could apply to hospital outpatient depts. Based on billing of hospital-based provider services in outpatient buildings Do your buildings comply with health care occupancy requirements?
12 Roller Latches (b)(2)(ii) Does not allow the exception in the LSC that permits use of roller latches CMS standards have permitted use of roller latches for more than 20 years Roller latches have become common in behavioral health
13 Alcohol Based Hand Rubs (b)(7) 2012 LSC allows ABHRs Accepts 2012 LSC requirements but adds if installed to prohibit inappropriate access Interpretive guidance is needed to determine what this means.
14 Sprinkler 4-hour rule (b)(8) NFPA 25 formerly required evacuation or fire watch of facilities if a sprinkler system was out of service for more than 4 hours in a 24-hour period. This has been changed in NFPA 25 to 10 hours to accommodate a work day. CMS proposes going back to the 4-hour period.
15 OR Smoke Vents (b)(9) Required when flammable anesthetics were used Removed as operating room ACH increased, sprinkler requirements were added, severity of fire risk and extent decreased ECRI data suggests 250 fires annually Surgical fires are extremely rare:.00092% Potential cost nationwide:?
16 36" Sill Height (b)(10) Okay for new construction As written will apply to existing construction How many existing facilities will this affect? What is the cost to fix this condition? Is it worth it? Staff should not break out windows during a fire Patients should not be evacuated through windows
17 Adoption of NFPA 99, 2012 edition (c)(1) Directly adopts NFPA 99: Health Care Facilities Code Except chapters: Chapter 7 Chapter 8 Chapter 12 Chapter 13 = IT and Nurse Call = Plumbing = Emergency Preparedness = Security
18 Waivers for NFPA (c)(2) Gives CMS authority to grant waivers to NFPA 99 requirements Same requirement as for NFPA 101
19 Guidance on MAKING COMMENTS
20 Making Comments You are more likely to have an impact on regulatory decision-making if your comment: Is constructive Is information-rich Clearly communicates and supports your claims Begin by reading and understanding the regulatory document you are commenting on.
21 Making Comments The comment process is not a vote one well-supported comment is often more influential than a thousand form letters. This is not a Me Too! vote Duplicating comments by others lessens the value of both comments
22 Making Comments Clearly identify the issues. If you are commenting on a particular word, phrase, or sentence, provide the page number, column, and paragraph citation from the Federal Register document. Do not feel obligated to comment on every issue select those that concern you the most, affect you the most, and/or you understand the best.
23 Making Comments Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (e.g., facility manager, recent construction project, attorney, etc.), say so.
24 Making Comments Consider including examples of how the proposed rule would negatively and/or positively affect your facility. Comments that include quantitative and qualitative data on the economic effects of rules are especially helpful.
25 + =
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28 Question What do you think of the proposal to require providers to meet the applicable provisions of the 2012 edition of NFPA 101, regardless of the number of patients served will affect the hospitals you work with?
29 Question Does your hospital currently discharge inpatients to use outpatient services and then re-admit the patients?
30 Question Do you have buildings constructed as business or ambulatory health care occupancies that are used to provide hospital services?
31 Question Do have windowless anesthetizing locations (windowless operating rooms)? If so, do they have a dedicated exhaust system that automatically vents smoke? If they have a dedicated system, do the controls shut down the surgical suite airhandling units? If so, would the shut down of the air handling unit shut down ventilation of multiple operating rooms?
32 Question Is your hospital partially sprinklered? Do you already have plans to sprinkler the unsprinklered area? Will you be able to do so in the 12 year timeframe. How many sprinkler system impairments do you have each year that are over 4 hours and less than 10 hours?
33 Question Typically, what does your local authority require you to do to perform a fire watch because of a sprinkler impairment?
34 Provide Feedback to CMS! This impacts everyone who has a stake in health care! Architects, plannners, facility professionals, contractors, consultants etc. Share your feedback Share your evidence Share your burden
35 Comments Due: June 16, ail;d=cms
36 Help is Available! Call The ASHE Comment Helpline!
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