This is nothing new - basically it dates from the 2008 memo mentioned below - but would only apply IF the dental facility is certified by CMS for Medicare/Medicaid reimbursement, i.e. as an Ambulatory Surgery Center. And yes, CMS essentially requires every ASC to be an Ambulatory Health Care Occupancy, regardless of number of patients. But no, if it isn't an ASC, the CMS position is irrelevant. Period, end of story.
Now, there are any number of scenarios under which the local or state AHJ could require the facility to comply with AHCO, per whatever version of NFPA 101 is applicable there. Or any number of other life safety design standards that the jurisdiction in question might have adopted, and it can get quite arcane.
For example, in CA any facility with "more than 5" patients receiving "care that may render the patient incapable of unassisted self-preservation" must be designed as an Institutional occupancy, per the (IBC-based) state building code. But, any location where anesthesia is administered in does that...well, let's say moderate or higher levels of sedation, or general anesthesia, must be "licensed, accredited or certified", potentially bringing in NFPA requirements enforced by accreditation organizations. Even that's largely simplified (I'm interested to see if any fellow Californians chime in), but my point is that it can get very complicated and depends greatly on your AHJ. Good luck!
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S. Ross Bogen AIA
Prinicpal Architect/Planner
Kaiser Permanente National Facilities Services
Oakland CA
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Original Message:
Sent: 02-16-2017 11:15
From: Gregg Ostrow
Subject: Occupancy designation for Physician Offices
We have been notified that a ruling by CMS may cause some physician offices to conform to the Ambulatory Health Care Occupancy in the LSC if they have one person that meets the definition of an Ambulatory Health Care Occupancy and that all existing facilities that meet this requirement will need to be upgraded. This will mean meeting ASHRAE standards for Type A Procedure Rooms, ducted returns, and smoke compartments that are more restrictive than the Business Occupancy. We are in the process of researching this before we meet with our AHJ.
Has anyone worked with their AHJ on this issue? If you have information on this issue can you please shed some light on it?
Thanks
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Gregg Ostrow AIA
Architect
Gregg D. Ostrow, AIA
Boise ID
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