Jun 27 2018

Occupancy Separation

Category: BlogBKeyes @ 12:00 am
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Q: I am a consultant hired by a health system to review a potential building they want to purchase. The architect on this project tells me that the building is NFPA 220 construction type II (111) which is basically a 1-hour rated assembly. The building is a fully sprinklered three story building, and has a mixed use including business and ambulatory healthcare occupancies. The health system is planning on buying the building and is looking to put a free-standing emergency clinic on the first floor which you’ve said needs to be healthcare occupancy. The second floor is a business occupancy. Here’s where it gets strange and I want to make sure I’m not crazy. The floor separation between the first and second floors in this case (business and healthcare) would need to be two-hour fire rated. But Type II (111) buildings have one-hour fire rated floors. I’ve received a drawing from the architect that states the construction type as II (111), but it shows the floors being upgraded to two-hour fire rated construction. The question is, can we have a two-hour floor supported by a one hour steel frame?

A: From my point of view, if they can document that the floor is 2-hour fire rated, then that should be enough for an AHJ to approve the separation between healthcare and business occupancies. I would view it as this: The floor is 2-hour fire rated, and it meets the requirements for a separation between healthcare and business occupancies, and it meets the requirements for Type II (111) construction type. Now, my opinion does not count, so I suggest they get an interpretation from their AHJs, including their accreditation organization.

By the way… CMS was the one who said in late 2016 that Emergency Departments need to be healthcare occupancies. Since then, they have modified their position a bit. Now they are saying an ED must be healthcare occupancy if they provide patient observation rooms. CMS’ rationale is if the patient is sleeping in an observation bed, then that should qualify it as healthcare occupancy. (I don’t agree, but my opinion does not count.) CMS does concede that an ED may be classified as ambulatory healthcare occupancy provide there are no observation beds.

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Apr 18 2012

IV Therapy

Category: BlogBKeyes @ 5:00 am
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I recently received a question asking if I thought a free-standing Chemo IV therapy center should be designated as an ambulatory care occupancy or a business occupancy. The reader said she knew that CMS already has specified that all Dialysis centers must be designated as ambulatory care occupancies and wanted to know if Chemo IV therapy centers had to follow suit.

Since there is not a specific directive from CMS concerning Chemo IV therapy centers, then it is perfectly acceptable to fall back on the Life Safety Code designation to determine occupancy designation. For review, I need to say ambulatory care occupancies are those areas (or facilities) that serve their clients as out-patients and do not provide any sleeping accommodations, and have 4 or more individuals incapable of self-preservation. Self-preservation is defined as the ability to stand, disconnect themselves from any equipment, and walk to the exit without any assistance from anyone else. In the case of IV therapy, taking the IV pole and solution is acceptable as well.

Business occupancies are defined as 3 or less patients that are incapable of self-preservation, and do not provide sleeping accommodations. As mentioned, CMS has already declared Dialysis centers and ambulatory surgical centers (regardless if they have less than 3 individuals incapable of self-preservation) as ambulatory care occupancies, so business occupancies are not an option for them. By the way, in case you’re wondering, a sleep-study center can be designated as business occupancy even though the patient is sleeping. The reason is they are constantly monitored and the accommodations are not considered ‘sleeping accommodations’.

So, to answer the reader’s question, it doesn’t matter what I say the Chemo IV therapy center is, it matters what the organization themselves say about it. They need to conduct an assessment of their patients to determine how many are incapable of self-preservation at any given time. I always advise my clients to be very conservative in this regards. Even if there is only a chance of once or twice a year that there would be more than 3 individuals incapable of self-preservation, then I strongly suggest they designate it as ambulatory care occupancy. Whatever decision the organization makes, it will be scrutinized by a surveyor during a survey. If the surveyor questions the decision, the organization will have to provide documentation supporting their decision, so keeping a written risk assessment is very important. I would also suggest having this decision reviewed and approved by the organization’s safety committee and get it in their minutes.

I do not have first-hand experience with Chemo IV therapy centers, so I cannot say what we did in our case. But we did have free-standing Dialysis centers and long before CMS made the decision that they had to be ambulatory care occupancies, our organization chose to designate them as business occupancies. I was never comfortable with that decision as it seemed obvious to me that most of the patients on dialysis were not capable of self-preservation. But the organization I worked for sold all of the dialysis centers to an independent organization, so that responsibility of making those facilities qualify for ambulatory care occupancy fell upon their shoulders.

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