Big changes ahead for codes and standards with the recent adoption of the 2012 edition of the Life Safety Code.
The Centers for Medicare & Medicaid Services (CMS) has adopted the 2012 edition of NFPA 101: Life Safety Code®. The final rule adopting the 2012 edition was published in the Federal Register on May 4. The change is effective July 5 and comes after years of CMS considering the change to the more updated standard. In its rule, CMS adopts the 2012 edition of the Life Safety Code and the 2012 edition of NFPA: Health Care Facilities Code—but makes several changes to the codes. For example, the chapters of NFPA 99 on the following topics are not included in the adoption: information technology (Chapter 7), plumbing (Chapter 8), emergency management (Chapter 12), and security (Chapter 13). The Centers for Medicare & Medicaid Services (CMS) issued a memo stating it will begin surveying hospitals for compliance with its new Conditions of Participation (CoPs) starting Nov. 1. Health care facilities will be surveyed under existing regulations until then although facilities will need to comply with the existing chapter (Chapter 19) of the life safety code beginning the July 5th date.
One potential negative impact came with a recent change to the original may 4th release that would require all hospital outpatient surgery departments to be classified as Ambulatory Surgical Occupancies under chapters 20 and 21 of the 2012 edition of NFPA 101: Life Safety Code®. This change, which the Centers for Medicare & Medicaid Services (CMS) released in June after the initial update to the Conditions of Participation, would apply to all existing and new business occupancies performing any type of surgery as defined by the American College of Surgeons.
It is likely that this change will affect all facilities that are 1) performing services such as dental or oral surgery, plastic surgery, Mohs surgery, lithotripsy, endoscopy, hernia repair, knee arthroscopy, laser surgeries and other minimally invasive surgeries such as the Syme procedure for ingrown toenails and 2) billing either hospital or outpatient services under the hospital provider number.
Codes and standard committees
The Codes and Standards Committees have been hard at work reviewing the changes proposed for several codes and standards including the International Building Code, The Life Safety Code (NFPA 101), The Health Care Facilities Code (NFPA 99) and the FGI Guidelines. All of the documents are currently in the later stages of the process for developing their 2018 editions. The input of the committees was forwarded to those committees through our Academy representatives. If you are interested in serving on one of these committees contact aah@aia.org.
Chad Beebe, AIA, SASHE