CMS issued a February 1, 2019 update (Ref: QSO19-06-ALL) to the State Operations Manual (SOM) Appendix Z emergency preparedness interpretive guidance to clarify CMS requirements pertaining to alternate source power and emergency standby systems. The clarifications (in red) are easy to find within the 56-page document. In its Memorandum Summary, CMS stated “We are updating […]
The discussion below is an update to our more comprehensive previous analysis entitled CMS Emergency Preparedness Final Rule Could Require More Equipment on Generators. The Emergency and Standby Power Systems portion of the CMS Emergency Preparedness Final Rule (CMS EPFR) discussed “specific compliance with NFPA 99, NFPA 101 and NFPA 110 for generator design, location, […]
ECRI Institute (ECRI) recently published its 2019 Top 10 list of health technology hazards. Healthcare organizations could consider this latest update of this list as one of many potential sources for identifying new safety risks or guiding due reconsideration of previously-identified safety risks. ECRI determines the content of the annual list, by considering adverse incidents, […]
CMS changed the rules for both inventories and equipment inspection, testing and maintenance (ITM) requirements in December 2013. The CMS changes require that, where law and regulations do not stipulate ITM, manufacturer ITM recommendations must be followed unless the organization has a compliant AEM Program and uses a risk-based process to determine how and when […]
TJC recently released its newly updated Life Safety & Environment of Care Document List and Review Tool, marked REVISED: 4/30/2018. The individual pages of the list are each marked with a 3/13/2018 revision date, which correlates to the TJC speaker’s 3/27/2018 PDC Conference general session reference to those revisions. This is the list of documents […]
TJC recently released its newly updated Life Safety & Environment of Care Document List and Review Tool, marked REVISED: 4/30/2018. The individual pages of the list are each marked with a 3/13/2018 revision date, which correlates to the TJC speaker’s 3/27/2018 PDC Conference general session reference to those revisions. This is the list of documents […]
Surveyors often seem to find the violations you did not see before they arrived at your facility. Why is that? It may be because they have never seen your facility before, so they see everything with what professionals in the field call “fresh eyes.” A major contributing factor is also the important fact that surveyors […]
TJC recently updated its Survey Activity Guide (SAG) for 2018. Contained within that updated SAG is an updated Life Safety and Environment of Care Document List and Review Tool, found on SAG pages 101-108. It appears that the new LS/EC Document List and Review Tool included some of the January 2018 changes to TJC’s elements […]
Most hospitals have utility failure procedures for major utility systems or equipment. However, existing utility failure procedures may have room for improvement, particularly in how they deal with common-mode failure potential within their utility systems and equipment. Reliability professionals generally consider that multiple failures, including failures in otherwise redundant equipment, attributable to a common cause […]
TJC recently finalized the January 1, 2018 changes within its online Hospital Accreditation Standards Environment of Care (EC) and Life Safety (LS) chapters. With a few exceptions, those changes were driven by the CMS September 2016 publication of the NFPA 101-2012 and NFPA 99-2012 K-Tags according to previous TJC announcements. This article discusses the major […]
Perhaps the future of gathering information about projects is in the air. SSR is testing that theory. Drones came into the public consciousness a few years ago, mostly as novelty holiday gifts. The new age alternative to remote-controlled airplanes, drones offered something additional — they could hover and they included ample space to mount a […]
TJC recently published the January 1, 2018 changes to its online Hospital Accreditation Standards Environment of Care (EC) and Life Safety (LS) chapters. With a few exceptions, those changes were driven by the CMS September 2016 publication of the NFPA 101-2012 and NFPA 99-2012 K-Tags according to previous TJC announcements. This article discusses only the […]
Owners of sports and entertainment venues and design firms have long been focused on innovative design, comfort of their patrons, and facility performance. Over the past several years, the focus has shifted to include sustainability as a primary objective. As high-profile entertainment venues, sports facilities are in a unique position to showcase facility performance and […]
The CMS Emergency Preparedness Final Rule (CMS EPFR) took effect on November 16, 2016, and compliance is expected by CMS starting November 16, 2017. Per the handout for CMS’ April 27, 2017 webinar, the new CMS-required all hazards approach “is an integrated approach to emergency preparedness planning that focuses on capacities and capabilities that are […]
When changing from one event to another, building pressure and air flow can be a major concern for venue operations. Not only can they affect energy efficiency, a major concern for many owners, they can also affect air quality in the building, and, by extension, both patron experience and the event itself. In 2016, SSR […]
The fight against Legionella bacteria within healthcare facilities has been a topic of healthcare industry discussions and concern for more than a decade. CMS substantially raised the bar in June 2017 when it issued a revised Survey & Certification Letter [S&C 17-30-Hospitals/CAHs/NHs REVISED 06.09.2017] PDF entitled “Requirement to Reduce Legionella Risk in Healthcare Facility Water […]
TJC recently published the July 1, 2017 changes to its online Hospital Accreditation Standards Environment of Care (EC) and Life Safety (LS) chapters. Published changes include some clarifications and corrections to previously-issued changes, such as EC.02.05.01 Element of Performance 6 (EP-6) regarding inspection, testing and maintenance (ITM) for non-high-risk utility system components. This change modified […]
Every building owner has to ask themselves that question. It’s inevitable and a long, hard look at the answer can sometimes be what stands between them and significant cost savings. It comes at no surprise that the biggest energy and cost drain is the HVAC system. So, the next question is then, “How much will […]
One important change in NFPA 99-2012 was the addition of Chapter 15, Features of Fire Protection. Within that chapter is a new Section 15.13, entitled Fire Loss Prevention in Operating Rooms. Subsection 15.13.1, Hazard Assessment, requires an evaluation of FIRE hazards that could be encountered during surgical procedures, including “hazards associated with the properties of […]
During his late afternoon March 14th session at the just-completed 2017 ASHE PDC Conference in Orlando, TJC speaker George Mills (Director of TJC’s Department of Engineering) announced upcoming additions and changes that will supplement the newly-released January 7th Elements of Performance (EPs) and the already-pending July 1st EP changes. Mr. Mills stated that the required […]
Every year, when Health Facilities Management and the American Society for Healthcare Engineering of the American Hospital Association release their Hospital Construction Survey results, I am always intrigued about what it will reveal. The 2017 report is out, and I’m happy to see the connection between designing healthcare facilities and the clinical workflow highlighted. Hospitals […]
Building enclosure (or envelope) commissioning (BECx) is a process by which the performance of a facility is evaluated and verified against the specific quality requirements of the owner. The commissioning team in charge of BECx is involved throughout the entire project, from the pre-design phase through the operations and maintenance phase. From the start, the […]
CMS has published the long-awaited K-Tags that reflect the adoption of the 2012 codes (NFPA 101-2012® Life Safety Code® and NFPA 99-2012 Health Care Facilities Code). Note that both of these codes also invoke many other NFPA codes and standards that can be between 10- and 15 years newer than the previously-enforced editions. K-Tags are […]
Many hospitals are still struggling with the AEM inclusion risk assessments required by both the CMS Survey & Certification Letter and Accrediting Organization (AO) requirements. This newsletter revisits and updates a previous discussion of AEM risk assessment requirements. TJC-accredited hospitals, for example, now face an even more important reason for having an effective AEM-inclusion risk […]
Now that CMS has adopted the 2012 Life Safety Code™ and 2012 Health Care Facilities Code, CMS is surveying for compliance with NFPA 110-2010. NFPA 110-2010 has very specific requirements for the 3-year 4-hour EPSS load test, and many hospitals may not be complying with those requirements. From NFPA 101-2012® Life Safety Code® [referencing NFPA […]
TJC released its long-awaited changes to its Life Safety (LS) and Environment of Care (EC) chapters Elements of Performance (EPs) on October 31, 2016. These documents are entitled “Prepublication Standards – Standards Revisions Related to Life Safety Code Update” and cover six TJC accreditation programs. The 49-page Hospital Prepublication Standards can be downloaded from that […]
The term “commissioning” is more and more frequently heard in every conversation about building construction, whether it’s new building construction or looking at the performance of an existing building. But what exactly is commissioning? The word has naval beginnings. A ship, especially in wartime, had to be commissioned before it was ready for active duty. […]
SSR’s May 2016 Compliance News article entitled CMS Adopts the 2012 Codes provided breaking news along with numerous hyperlinks to assist organizations in assessing the impact of CMS’ adoption of the 2012 codes. SSR’s June 2016 Compliance News article entitled CMS to survey 2012 codes starting November 1, 2016 passed along a few clarifications issued […]
One of the significant changes resulting from CMS’ adoption of the 2012 Life Safety Code® is the impact of the NFPA 101-2012 Building Rehabilitation Chapter 43. Chapter 43 is intended to apply to work that the owner or occupant has elected to perform within an existing building. In its final rule adopting the NFPA 101-2012 […]
Building energy modeling has been used for many years to show compliance with local energy codes and to document energy performance-related points in beyond-code rating systems such as LEED® and Green Globes. When used in this manner, energy modeling is typically seen as a necessary evil – just another box to check at the end […]
The November 2015 Compliance News issue discussed the joint work that both ASHE and TJC had performed to that point in providing assistance on major physical environment compliance problem areas. Last month’s Compliance News issue discussed TJC’s contributions to that initiative through July 2016. This article reviews ASHE’s ongoing contributions to their joint program through […]
I recently had the opportunity to visit Iceland with my Graduate Nursing Program as part of a Global Healthcare class. With my head down working on healthcare design projects across the country, it is easy to get tunnel vision and forget about the bigger picture. But I was reminded when I found this: according to […]
The November 2015 Compliance News issue discussed the joint work that both ASHE and TJC had performed in providing assistance on major physical environment compliance problem areas. The TJC Physical Environment Portal (TJC PE Portal) is still available at TJC’s website under the main TOPICS heading. Interested parties can sign up at that location to […]
SSR’s May 2016 Compliance News article entitled CMS Adopts the 2012 Codes provided breaking news along with numerous hyperlinks to assist organizations in assessing the impact of CMS’ adoption of the 2012 codes. In its June 20, 2016 Survey & Certification Letter S&C 16-29-LSC, CMS advised that CMS will begin surveying to the 2012 Life […]
Many people consider it ironic that a nurse works at an engineering firm. The experience has turned out to be quite serendipitous for me. The growing role of the executive nurse as a true partner in healthcare strategy requires systems thinking and an engineering-based approach. During a keynote address, BYU professor Margaret J. Wheatley Ed. […]
Changes take effect July 5, 2016. CMS has adopted the 2012 codes (NFPA 101®-2012 Life Safety Code® and most of NFPA 99-2012 Health Care Facilities Code.) However, the full consideration of this change also requires taking into account the impact of changes in the referenced documents that will now be 10 to 15 years newer. […]
As of April 8, 2016 all projects registered under the LEED v2009 BD+C for New Construction rating system will be required to achieve a minimum 18% reduction in energy cost over ASHRAE 90.1-2007. This is an 8% increase over the previous minimum requirement of 10%. Additional increased energy thresholds apply to other ratings systems as […]
Changes to EPA regulations will soon prohibit or severely restrict participation in “emergency demand response” programs for owners of standby generators. The change will take effect on May 1, 2016. A number of hospitals with significant investment in standby generation participate in these programs, generating substantial revenue. Most will soon see their participation curtailed. Demand […]
As the landscape in healthcare is continually changing, increasing pressures for hospitals to perform leaner is becoming commonplace. By definition, lean thinking is the concept of finding value and eliminating waste in a process. Waste is anything that does not bring value to your “customer” or the end recipient of your service. Lean comes from […]
The March 2016 issue of Health Facilities Management Magazine discusses “Best practices for hospital power system reliability.” The following highlights some of the topics contained within that detailed article, and we recommend that Compliance News readers review and share the hyperlinked HFM Magazine article within their organizations. Best practices can be undertaken throughout the life […]
There continue to be questions regarding the use of maintenance-free generator starting batteries since they seem to be the preferred starting battery type of most generator set manufacturers. This article discusses the original prohibition and when it was removed from NFPA 110. Within the NFPA 110-1999 edition presently enforced by CMS and its accrediting organizations, […]
The clinical voice is sometimes overshadowed by other “voices” that are slowly making an entry into clinical processes. I was struck recently by the fact that electronic health records dictated the workflow in one recent incident. In another situation a patient education/entertainment system was a driving force in workflow. Creating an organizational structure to accommodate […]
2016 brings a host of ongoing compliance challenges along with a few new ones. The ongoing challenges often revolve managing and mitigating the myriad risks within our facilities: general safety hazards, utility risks, fire safety risks, and life safety risks. Of concern is the accelerating pace of changes combined with increasing complexity of the impact […]
ECRI recently published its 2016 Top 10 Health Technology Hazards list. Healthcare organizations could consider the latest update of this list as one of many potential sources for identifying new safety risks or ensuring due consideration of previously-identified safety risks. Element of Performance # 1 under TJC’s Standard EC.02.01.01 requires identifying safety and security risks […]
Since the Affordable Care Act (ACA) was signed into law in 2010, there have been continuing transformations in hospital financial, technological, and clinical practices. These transformations have in some cases led to the establishment of competing priorities for hospital decision makers. Two of the biggest issues facing hospitals that cross financial, technological, and clinical lines […]
Since ASHE and TJC announced their joint effort to address the most problematic physical environment issues at the July 2015 ASHE Annual Conference in Boston, both organizations have been making good on that promise. The TJC Physical Environment Portal (TJC PE Portal) is available at TJC’s website under the main TOPICS heading. Interested parties can […]
ASHE and five other professional organizations issued an important Joint Interim Guidance statement in late September addressing the ongoing challenges with HVAC systems serving operating rooms and sterile processing departments. The Joint Interim Guidance document was dated September 21, 2015 and issued shortly thereafter as a PDF file by the signatory organizations. The six signatory organizations […]
The healthcare facilities community is expecting CMS adoption of NFPA 101-2012 (Life Safety Code®) and NFPA 99-2012 (Health care Facilities Code) later this year or sometime early next year. While we have been awaiting adoption, may organizations have already made it a point to become familiar with some of the major changes within those two […]
TJC Director of Engineering George Mills announced some July 2015 changes to the Life Safety Surveyor’s portion of hospital triennial surveys during his recent TJC Update session at the ASHE Annual Conference in Boston. Mr. Mills covered many important subjects during this presentation. This SSR Compliance News issue discusses only some changes that directly affect […]
Hospitals are dealing with the issues of utility system equipment technology failures and managing the need for ongoing technology upgrades as equipment designs evolve. Many hospitals have varying generations of utility system digital control technology built into major electrical, mechanical, vertical transportation, etc. operating components that were installed over the past few decades. Examples include […]
In its June 3, 2015 issue of the NFPA TODAY blog, (also in the June 5, 2015 NFPA conference blog post), NFPA stated that 27 standards in the Annual 2015 revision cycle, including the new NFPA 110, were issued by the NFPA Standards Council on May 26, 2015 as Consent Standards. The new NFPA 110 […]
Most hospitals have utility failure procedures for major utility systems or equipment. However many utility failure plans have room for improvement, particularly in how they deal with common-mode failure potential within those utility systems. The HFM Magazine article How to Plan for Water Outages published in early 2015 referenced an excellent document published by the […]
A historical area of compliance challenges, related to hospital construction/renovation projects, may be getting worse. Many organizations have struggled with obtaining timely receipt of details relating to new utility system components as well as manufacturer’s operating and maintenance manuals. The CMS December 2013 Alternate Equipment Management changes (related TJC July 2014 Alternate Equipment Maintenance changes), […]
Many hospitals are struggling with the AEM risk assessments required by both the CMS Survey & Certification Letter and the TJC July 2nd revisions. This newsletter discusses the AEM risk assessment requirements. Compliance News previously discussed the driving CMS 2014 Survey & Certification Letter S&C:14-07-Hospital and its enclosed Appendix A interpretive guidelines generally in our […]
Once a facility is built and fully operational, what assurances does the owner have that the building will perform as intended? Operational energy performance is a priority for building owners, and as the old adage goes, “You can’t manage what you don’t measure.” Without actionable, systems-level data on energy usage for our facilities, performance decay […]
Why does it have to be so hard…integrating devices to give clinicians the information they need to deliver optimum care? How many times do I have to sit in meetings and hear, “We don’t integrate with that company?” Enough is enough! As a nurse, I am beginning to see this impact the delivery of care at […]
An article just published in the February 2015 issue of Healthcare Facilities Management (HFM) Magazine discusses in detail many issues related to planning for hospital water outages. The article is available online at the HFM Magazine website. Water outages are unfortunately a common cause or effect of cascading failures. They can occur as a result […]
Modern building enclosures are designed and constructed using numerous complex systems and materials. Combined with demands for quality, durability, schedule, and energy performance, it’s not surprising that the building enclosure represents the majority of building failures and construction defect claims. Simply defined as a quality-based process implemented to evaluate and verify the owner’s project requirements […]
By now many hospital facility directors have reviewed the Hospital Equipment Maintenance Requirements contained within the current CMS Alternate Equipment Management (AEM) program rules being enforced by CMS and all of its deemed accrediting organizations. We previously discussed the driving CMS 2014 Survey & Certification Letter S&C:14-07-Hospital and its enclosed Appendix A interpretive guidelines generally […]
Facility owners are becoming more in tune with the fact that 90% of a building’s lifetime cost is tied to operating cost, while only about 10% is dedicated to construction. This realization is driving owners and building professional organizations to compile increasingly sophisticated levels of facility operation and maintenance documentation. The amount of documentation required […]
Hospitals are expected to identify risks that can adversely affect the safety of patients and others. As an example, under TJC’s Standard EC.02.01.01, Element of Performance 1 lists examples of both internal and external sources of information on probable risks. The annually updated ECRI list of Top 10 Health Technology Hazards is not listed but […]
ASHE just published a new 80+ page management monograph detailing a comprehensive program for managing hospital emergency power systems. This document addresses recent lessons learned, best practices, and new regulatory issues. Readers who have questions on the content of the monograph are invited to email the author at DStymiest@ssr-inc.com. Entitled Managing Hospital Emergency Power Systems: […]
Resources for information on Ebola Preparedness The World Health Organization (WHO) declared Ebola to be a Public Health Emergency of International Concern (PHEIC) on August 8, 2014. This extraordinary event has created worldwide awareness and panic of the threat of such an epidemic. Generations of the past have been touched by such epidemics as yellow […]
The design and construction industry has made great strides in the past decade towards creating more sustainable and higher performing buildings. Building owners pursue green buildings for many reasons: operational cost effectiveness, marketing, ethics, occupant health, natural resource conservation, among others. Several industry organizations have formulated standards or rating systems to guide the development of […]
The new AEM program requirements can represent a sea change in hospital utility system management. The new requirements can affect a multitude of existing processes as laid out in a hospital’s current Plans, Policies or Procedures (PPPs). This article briefly discusses a few of those processes. We previously discussed the driving CMS 2014 Survey & […]
Since the passage of the Affordable Care Act, the healthcare industry has evolved and will continue to for the foreseeable future. Hospitals have been tasked with becoming more efficient, with fewer resources, and adapt to the new marketplace. However, buildings are decaying, becoming more inefficient, and costing more to operate year-after-year. When buildings and equipment […]
In a new Clarifications and Expectations article entitled “Revised Equipment Maintenance Standards for Hospitals” published in the September 2014 issues of Environment of Care News and TJC Perspectives, TJC Director of Engineering George Mills provided guidance regarding the enhanced TJC equipment maintenance requirements that took effect on July 2, 2014. We previously discussed the driving […]
In late spring 2012, SSRCx began utilizing a cloud based database, Building Start, to execute the commissioning process for all new construction projects. Building Start is mobile workflow management software that merges a cloud based project management platform with a mobile, offline workflow and audit trail system. This unique combination allows the assignment and sequencing […]
There has been activity without many answers since TJC Director of Engineering George Mills announced a change in TJC’s approach to power strips in patient care areas on June 1, 2014 at the AAMI Conference. Although most facility managers call these devices power strips, both Underwriters Laboratories (UL) and CMS call them relocatable power taps […]
The healthcare landscape is changing so fast that it is difficult to keep up or predict the future. What does the future hold for the delivery of healthcare? How will future practitioners innovate? It is safe to say, however, that the future of healthcare will be more about value than about volume. The healthcare continuum […]
The Joint Commission recently issued numerous changes to its Hospital Accreditation Standards (HAS) Environment of Care (EC) and Life Safety (LS) chapters. TJC accredited hospitals should closely review all changes within the HAS book itself. TJC’s Prepublication Requirements issued June 20, 2014 identified the below-listed EC chapter changes that took effect July 2, 2014. There […]
The building enclosure (envelope, skin, etc.) represents one of the highest risk elements of construction. Water intrusion, air leakage, and increased energy consumption are common consequences of poorly designed and constructed building enclosure systems. An effective building enclosure commissioning (BECx) and testing program can reduce these risks along with associated long term effects such as […]
Project teams pursuing certification under the LEED® v4 Building Design and Construction rating system should carefully examine their commissioning process and scope, as the updated rating system includes several new requirements and options for building commissioning. Following is a selection of significant changes in commissioning requirements, based on information currently available within the LEED v4 […]
According to a new press release from AAMI, TJC Director of Engineering George Mills announced new restrictions on the use and application of Relocatable Power Taps during his speech at the AAMI 2014 Conference in Philadelphia on June 1, 2014. According to Underwriters Laboratories (UL) relocatable power taps, often also called outlet strips, are listed […]
TJC Director of Engineering George Mills clarified TJC’s requirements for safe storage of medical gas cylinders in the February 2014 editions of both TJC Perspectives and EC News. The TJC articles, both entitled Maintaining Medical Gas Safety and located within the Clarifications and Expectations portion of each periodical, referred to NFPA 99-1999 section 4-3.5.2.2(b). Section […]
CMS recently issued Survey & Certification Letter S&C:14-07-Hospital, which changed the requirements for hospital equipment maintenance. The new requirements apply to utility systems equipment as well as medical equipment. The CMS letter can be found at http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-07.pdf, and hospital facility directors should obtain and review a copy of it. That letter also includes as Appendix […]
CMS recently announced its intent to adopt the 2012 editions of the NFPA 101 Life Safety Code® (LSC) and the NFPA 99 Health Care Facilities Code with modifications. This process in now within a 60-day public comment period, and all public comments must be submitted by June 16, 2014. This round of public comments followed, […]
The 2014 TJC Hospital Accreditation Standards include wording changes in Standard EC.02.05.07, EP-4 (generator test intervals) and EP-6 (transfer switch test intervals) that tweak the required test intervals a little. The new 2014 test interval language in both EPs states “At least monthly, the hospital tests ….” This is a change from the 2013 TJC […]
Take a close look at your 2014 schedules for quarterly requirements such as fire safety system testing found in several elements of performance (EPs) under Standard EC.02.03.05. The brand new 2014 TJC definition of QUARTERLY can be found on page EC-3 at the beginning of the EC Chapter in the 2014 Hospital Accreditation Standards. The […]
In its Joint Commission Online article, dated June 26, 2013,(www.jointcommission.org/assets/1/23/jconline_June_26_13.pdf) The Joint Commission announced a new 2014 National Patient Safety Goal NPSG .06.01.01 on clinical alarm safety for both hospitals and critical access hospitals. The July 2013 issue of Joint Commission Perspectives discusses the new NPSG in detail. The NPSG requirements include 4 elements of […]
The Centers for Medicare & Medicaid Services (CMS) issued a categorical Life Safety Code waiver permitting new and existing ventilation systems supplying hospital and critical access hospital (CAH) anesthetizing locations to operate with a relative humidity (RH) of ≥20%, instead of ≥35%. CMS is also recommending that RH not exceed 60% in these locations. CMS […]
