nshe annual trade show & conference brad taylor, chfm ashe region 8 board representative may 2,...

NSHEAnnual Trade Show & Conference

Brad Taylor, CHFMASHE Region 8 Board Representative

May 2, 2014

• Publicationof the proposed rule: April 16, 2014

• Comments due: June 16, 2014

www.regulations.govSearch: “Fire”

CMS Proposed Rule §482.41

CMS: 2012 Life Safety Code Adoption5.02.2014

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

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ASHE is working to improve outdated codes, conflicting codes, codes not based on science, and inappropriate code interpretations.

Why do we use consensus codes?OMB Circular A-119 (1998) intended to: 1. Encourage federal agencies to benefit from

the expertise of the private sector2. Promote federal agency participation in such

bodies to ensure creation of standards that federal agencies can use

3. Reduce reliance on government-unique standards where an existing voluntary standard would suffice

PROPOSED RULEOverview

§482.41 (b)(2)(i) Adoption, change in definition

Changes definition of “health care occupancy” from applying to “4 or more patients” to “regardless of the number of patients served”

Would apply to hospital outpatient depts.o Based on billing of hospital-based provider

services in outpatient buildingso Do your buildings comply with “health care

occupancy” requirements?

§482.41 (b)(2)(ii) Roller Latches

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 becomecommon in behavioralhealth

§482.41 (b)(7) ABHR

2012 LSC allows ABHRs Accepts 2012 LSC requirements

but adds “if installed to prohibit inappropriate access”o Interpretive guidance is

needed to determine what this means.

§482.41 (b)(8) Sprinkler 4-hour rule

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.

§482.41 (b)(9) OR Smoke Vents

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 annuallyo Surgical fires are extremely rare: .00092%oPotential cost nationwide: ?

§482.41 (b)(10) 36" Sill Height

Okay for new construction As written will apply to existing construction

oHow many existing facilities will this affect?oWhat is the cost to fix this condition?

Is it worth it?o Staff should not break out windows during a fireo Patients should not be evacuated through

windows

§482.41 (c)(1) Adoption of NFPA 99, 2012 edition

Directly adopts NFPA 99: Health Care Facilities CodeExcept chapters:

o Chapter 7 = IT and Nurse Callo Chapter 8 = Plumbingo Chapter 12 = Emergency Preparednesso Chapter 13 = Security

§482.41 (c)(2) Waivers for NFPA 99

Gives CMS authority to grant waivers to NFPA 99 requirements

Same requirement as for NFPA 101

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

Next Steps Communicate with your members Start the discussion Provide guidance for commenting Share the ASHE Issue Brief on the subject

with hospital leadership Encourage members to comment on the

proposed rules

Provide Feedback to ASHE

Share your feedbackShare your evidence

Share your commentsSuggest other resources

To:firesafetyfeedback@aha.org

Comments Due: June 16, 2014

www.regulations.govSearch: “Fire”

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• Facilities Management will be expected to contribute to cost-cutting efforts

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