Advocacy

CMS offers categorical waiver on power strips


ISSUE BRIEF

Key Points:

  • CMS is offering a categorical waiver allowing power strips to be used in patient care areas under circumstances outlined in S&C 14-46
  • A hospital wanting to use the waiver must have written documentation of this fact and must notify surveyors at the entrance conference that the facility is using the waiver and meets its requirements.
  • Power strips may not be used in a patient care vicinity to power non-patient care-related electrical equipment (e.g., personal electronics).
  • Power strips may be used outside the patient care vicinity for both patient care-related electrical equipment and non-patient care-related electrical equipment.

ASHE staff contact:
ASHE Deputy Executive Director of Advocacy
Chad Beebe, AIA, SASHE
312-422-3824
cbeebe@aha.org
September 29, 2014

The Centers for Medicare & Medicaid Services (CMS) is offering a categorical waiver that allows hospitals to use power strips (also known as multi-plug adapters or relocatable power taps) in patient care areas under certain circumstances. The policy change takes effect immediately.
Requirements in the 1999 edition of NFPA 99, which is referenced in the 2000 edition of NFPA 101: Life Safety Code®, did not permit the use of power strips. CMS said in a new memo that the power strip requirements in NFPA 99-1999 have become "outmoded and unduly burdensome." CMS pointed out that the 2012 edition of NFPA 99: Health Care Facilities Code expands the permitted use of power strips or RPTs in patient care rooms.
CMS is offering a categorical waiver to health care facilities that want to use power strips if the facility is in compliance with all applicable power strip requirements in NFPA 99-2012 as well as all other NFPA 99-1999 and NFPA 101-2000 electrical system and equipment provisions.
The CMS memo outlines the conditions under which power strips may be used and the requirements for using them. For example, power strips providing power to patient care-related electrical equipment must be special-purpose relocatable power taps (SPRPTs) listed as UL 1363A or UL 60601-1. Power strips providing power to non-patient care-related electrical equipment must be relocatable power taps (RPTs) listed as UL 1363.
To use the waiver, hospitals must have written documentationTo use the waiver, hospitals must have written documentation indicating they have elected to do so. Facility staff must notify surveyors at the entrance conference that the organization has elected to use the categorical waiver and that the facility meets the requirements. Surveyors will review the information and confirm the facility meets the conditions for the waiver.

ASHE has been working closely with CMS on this issue and will continue to keep members updated on the latest developments. Watch the ASHE Insider electronic newsletter for updates.




CMS Considers Reducing Low-End Humidity Requirement, Outlines Interim Waiver Process

by Deanna Martin, senior communications specialist, American Society for Healthcare Engineering of the American Hospital Association

The Centers for Medicare & Medicaid Services (CMS) is considering changing the low-end humidity requirement in operating rooms from 35 percent to 20 percent, according to the American Society for Healthcare Engineering (ASHE) of the American Hospital Association. ASHE has received word from CMS headquarters that the agency is looking to change its policy and that a draft memo on the subject is currently undergoing an internal review at CMS.

ASHE supports reducing the low-end humidity requirement in operating rooms. While high-end humidity limits are important to reduce infections and prevent mold and mildew, the current CMS low-end requirement for at least 35 percent relative humidity was first put in place to reduce static discharge and possible ignition of flammable anesthetics. Because such anesthetics are no longer used, this low-end requirement has outlived its usefulness, according to Chad Beebe, ASHE Director of Codes and Standards.

Beebe noted that lowering the humidity level to 20 percent in operating rooms has no adverse effect on patients but can save hospitals thousands of dollars. In a 2010 briefing to CMS on this issue, ASHE estimated the change could save the health care industry more than $200 million over the next 10 years by providing energy conservation savings, reducing the initial ventilation system installation cost, and eliminating the need to modernize existing systems to maintain 35 percent relative humidity.

The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) now requires at least 20 percent humidity in hospital operating rooms. And the latest version of NFPA 99: Health Care Facilities Code has removed the operating room humidity requirements, as those levels were deemed out of the document's scope. But because CMS still holds hospitals to the 2000 edition of NFPA 101: Life Safety Code, and because that code references an older version of NFPA 99, hospitals certified by CMS are still required to provide a minimum of 35 percent humidity in operating rooms.

While ASHE appreciates the fact that CMS is considering this issue, it is unclear whether making the change simply by altering CMS policy is permitted or advisable. ASHE supports the administrative procedures process, in which stakeholders have a chance to submit public comments and provide input throughout the process. CMS could also opt to change the humidity requirements by adopting the 2012 edition of the Life Safety Code because it references the latest edition of NFPA 99, which doesn't include any humidity requirements. There is no word from CMS on when it might change its policy or adopt the 2012 edition of the Life Safety Code. However, CMS has accepted public comments on the proposal to adopt the 2012 Life Safety Code. That public comment period ended in December, and ASHE submitted comments urging CMS to adopt the 2012 edition.

ASHE will continue to monitor this issue and keep its members apprised of the latest developments. In the mean time, ASHE reminds hospitals that they can apply for CMS waivers if the humidity requirements would cause an unreasonable hardship and there would be no negative effect on patient health and safety. CMS has indicated that they are considering these waivers on a case-by-case basis, and have provided a process outline for facilities to follow:

  1. The facility must submit for a waiver as part of their plan of correction after being cited for this Life Safety Code deficiency. The request shall provide sufficient detail in supporting evidence on the hardship it would cause, and the effect that granting the waiver would have on patient health and safety.
  2. The State Agency or Accrediting Organization will review the facility waiver request and may recommend the waiver approval/denial to the CMS Regional Office.
  3. The Regional Office will review the facility request, supporting evidence, the State Agency or Accrediting Organization recommendation, and make a final determination to approve or deny the request.


Beebe suggests that ASHE members applying for waivers could share their applications with other ASHE members using the ASHE LISTSERV ® drop box. For more information or to get involved with ASHE's advocacy efforts, contact Chad Beebe at cbeebe.aha@gmail.com or at 312-422-3824.




ASHE's new Code Reform Initiative aims to reduce the burden health care professionals face when it comes to maintaining compliance with facility-related codes and standards. Your input is needed in order for ASHE to build a strong case in favor of consolidating facility-related codes and standards. NOSHE can serve as a central repository for submitting information to ASHE regarding ideas for code reform. If interested, please submit ideas to NOSHE's Advocacy Liaison, Paul Dzurinda at dzurinp@ccf.org. This will allow ideas to be submitted to ASHE from a consistent source.

ICC Considers Changing Corridor Width Rules to Reflect Shift from Life Safety Concerns


The rationale for constructing and maintaining hospital corridors at 8 feet wide has shifted from a life safety issue to one of operations and logistics. The International Code Council (ICC) Ad Hoc Committee on Healthcare is considering recommending a change that would reflect this shift, codify more realistic requirements, and end confusion surrounding this issue, which has nagged hospitals for years and is reported to be among the top causes for Joint Commission citations. The recommended language would bring the I-Codes into line with a change in the 2012 edition of NFPA 101: Life Safety Code ® regarding corridor width.

The I-Codes currently require hospitals to provide corridors with 8 feet of clear and unobstructed width. An important proposal currently being debated by the ICC Ad Hoc Committee on Healthcare would clarify those corridor width requirements in the I-Codes, definitively identifying what equipment is permitted to be positioned in hospital corridors.

Most ICC ad hoc committee members recognize that the day-to-day operations of a hospital require keeping some equipment near patient rooms, including life-saving crash carts. While some code enforcement authorities allow such equipment to be staged in 8-foot corridors, others interpret the I-Codes to require 8 feet of completely clear corridor space at all times. The ad hoc committee's work to clarify this issue could result in more consistent and realistic application of codes while keeping the means of egress safe and usable by staff and others during a disaster.

The advocacy team at the American Society for Healthcare Engineering (ASHE) of the American Hospital Association (AHA) points out that the need for quick access to critical equipment like crash carts far outweighs the probability of needing 8 feet of completely clear space during emergency evacuations, which are rare now that hospitals use quick response sprinkler systems and defend-in-place procedures. A look at the history of corridor width requirements further supports the argument that 8 feet allows plenty of space to position certain portable equipment in hallways without endangering hospital patients, visitors, staff, firefighters, and others who may be present during an emergency.

For additional information regarding this potential change, please visit the ASHE web page at www.ashe.com

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