Jan 15 2015

More on the CMS S&C Memo Concerning Power Strips

Category: BlogBKeyes @ 6:00 am
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12-120-878-TS[1]I received a question from a reader that I was unable to immediately answer. The question dealt with the use of power strips in a business occupancy: Did the categorical waiver to allow the use of power strips described in the  S&C memo 14-46-LSC, issued September 26, 2014 apply to business occupancies? The reader explained that the physician office building where he worked did not have hospital grade receptacles so it did not make sense to him that using UL listed power strips was necessary.

My immediate thought was the CMS issued categorical waiver would only apply to healthcare occupancies because NFPA 99 (2012 edition) does not apply to business occupancies. NFPA 99 is referenced by the healthcare occupancy chapter in section 18.5.1.3 of the 2012 LSC, but it is not referenced by the business occupancy chapters in the same LSC.

But, since I was not sure, I asked the question of a reliable source at CMS and they said the 2012 NFPA 99 Section 3-3.2.1.2(d)2 pertains to the minimum number of receptacles in all Patient Care Rooms.  Patient Care Rooms is defined as any room of a health care facility wherein patients are intended to be examined or treated.  In addition, the 2012 NFPA 99 Section 10.2.3.6 pertains performance criteria and testing for patient-care-related electrical appliances and equipment.  Patient-care-related electrical equipment is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity.

As these definitions do not make a differentiation based on occupancy,  it is CMS’s understanding that 2012 NFPA 99 power strip requirements would be applicable in all health care facilities in rooms where patients are intended to be examined or treated regardless of occupancy classification.

So, the answer to the question is the categorical waiver applies to all patient care rooms, regardless of the occupancy classification. This means if you want to use power strips in a physician exam room in a medical office building that is a business occupancy, you need to follow the guidelines in the S&C memo and only use UL listed power strips. However, for other areas of the business occupancy that are not considered patient care rooms, the NFPA 99 requirements concerning UL listed power strips do not apply. But it is wise to purchase only UL listed power strips since you cannot control where they may end up.

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Oct 01 2014

CMS Issues Categorical Waiver on Power Strips

Category: BlogBKeyes @ 3:00 pm
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12-120-878-TS[1]CMS issued a new S&C memo 14-46 in late September that made allowances for healthcare organizations to utilize power strips in patient care areas.

CMS has determined that the 2000 edition of the Life Safety Code contains provisions on the use of power strips in health care facilities that may result in unreasonable hardship for providers or suppliers. Further, CMS says an adequate alternative level of protection may be achieved by compliance with the 2012 edition of the Life Safety Code, which has extended allowances on the use of power strips in patient care areas.

CMS has determined that the 1999 edition of NFPA 99 Standard for Health Care Facilities, section 3-3.2.1.2 (d)(2) which requires a sufficient number of receptacles located so as to avoid the need for extension cords or multiple outlet adapters, is outmoded and unduly burdensome. NFPA 99 is referenced in part by the Life Safety Code. Power strips are also known as multiple outlet adapters, multiple-plug adapters, and relocatable power taps.

CMS says by contrast, the 2012 edition of NFPA 99 has extended allowances for use of power strips in ‘patient care rooms’, which replaces the term ‘patient care areas’.

The requirement in the 1999 edition of NFPA 99 for sufficient receptacles to be located in all patient care areas as to avoid the need for power strips has been removed in the 2012 edition. In place, the 2012 edition has increased the minimum number of receptacles in patient care rooms for new construction.

Effective immediately, CMS is permitting a categorical waiver to allow for the use of power strips in existing and new health care facility patient care areas/rooms, if the provider/supplier complies with all applicable 2012 NFPA 99 power strip requirements and with all other 1999 NFPA 99 and 2000 Life Safety Code electrical system and equipment provisions. NOTE: This applies to patient care rooms in all occupancies; not just healthcare occupancy. So does apply to patient care rooms in business occupancies as well as ambulatory care occupancies.

A patient care room is defined as any room in a health care facility wherein patients are intended to be examined or treated. This definition appears to include operating rooms and procedure rooms as well and is not limited to just healthcare occupancies.

The CMS S&C memo 14-46 describes basic requirements that health care facilities must comply with in order to use the new categorical waiver.

  • Patient bed locations in new health care facilities, or in existing facilities that undergo renovation or a change in occupancy, shall be provided with the minimum number of receptacles as required by section 6.3.2.2.6.2 of the 2012 NFPA 99.
  • Power strips may be used in a patient care vicinity to power rack-mounted, table-mounted, pedestal-mounted or cart-mounted patient care related electrical equipment assemblies, provided all of the conditions are met in section 10.2.3.6. They do not have to be an integral component of manufacturer tested equipment.
  • Power strips may not be used in a patient care vicinity to power non-patient care-related electrical equipment, such as personal electronics.
  • Power strips may be used outside of the patient care vicinity for both patient care-related equipment and non-patient care-related equipment.
  • Power strips providing power to patient care-related electrical equipment must be Special Purpose Relocatable Power Taps (SPRPT) listed as UL 1363A or UL 60601-1.
  • Power strips providing power to non-patient care-related electrical equipment must be Relocatable Power taps (RPT) listed as UL 1363.

The categorical waiver is available to all health care providers and suppliers and need only to document their decision to use the waiver, stating that they comply with all of the requirements to do so. This document must be provided to the surveyor team at the entrance conference. Organizations wishing to use the categorical waiver need not apply for them or wait until they are cited to use them.

To review the CMS S&C 14-46 memo, follow this link:  http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-46.pdf

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Jun 30 2014

Relocatable Power Taps (Power Strips)

Category: BlogBKeyes @ 6:30 am
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12-120-878-TS[1]There has been a lot of discussion about power strips (or relcoatable power taps, as some authorities call them) lately, and most of it is not to our advantage. None of the discussion is actually news to us, it’s just a re-hash of existing positions.

During the recent NFPA Annual Conference in Las Vegas earlier this month, George Mills, the Director of Engineering for The Joint Commission said he approached the NFPA Healthcare Interpretation Task Force (HITF) back in 2007 and asked them to make a ruling on whether power strips are acceptable for use in patient care areas. George said after much discussion, the HITF did not come to a consensus, and therefore no interpretation was issued.

Since then, The Joint Commission surveyors have been allowing power strips in patient care areas, and some surveyors even required the devices to be UL listed for the application. Then, earlier this year, the leadership at The Joint Commission asked George what the accreditor’s official position was on the use of power strips, so he decided to contact the CMS home office in Baltimore to see what they allow.

George reported at the May AAMI Annual Conference in Philadelphia that CMS is taking the hard line of saying power strips (relocatable power taps) are not to be used in anesthesia areas and on medical equipment. This is based on NFPA 99 (1999 edition), section 7-5.1.2.5 which only allows relocatable power taps provided they are an integral part of the equipment assembly and permanently attached; and the sum of the ampacity of all appliances connected to the relocatable power tap shall not exceed 75% of the ampacity of the relocatable power tap. A regular program to verify the integrity of the above permanently attached relocatable power taps is required.

This piece of information was picked up by a lot of different healthcare news outlets, blogs and online notification services (including yours truly) and re-distributed to the point where CMS had to make an unofficial email announcement to their deemed accredited organizations (and presumably to their state agencies) that in fact no new issuance of a policy or an announcement was made concerning power strips, and they referred to NFPA 99 as their standard. Now ASHE has made an announcement acknowledging CMS’ position, and to say they are working to convince CMS to consider issuing a categorical waiver to allow the immediate use of NFPA 99 2012, which seems to have a more user friendly approach to power strips.

But, the bottom line is The Joint Commission (and the other accreditors) do not have any option but to follow this difficult interpretation of the standard as dictated by CMS. George Mills unofficially said they will enforce no power strips in patient care areas, and no power strips on medical equipment, unless it meets the requirement of NFPA 99 7-5.1.2.5 and it is integrated with the medical equipment, and this is all regardless of the UL listing. So power strips like UL 1363A which are listed for use in anesthetizing locations would not be acceptable to the accreditors.

For the record, the HITF wrestled with the issue of power strips once more this year in Las Vegas but again did not arrive at a conclusive interpretation. Chad Beebe representing ASHE said he wants to take this issue to CMS to attempt them to change their minds on the rigid interpretation.  I guess you need to stay tuned to see what transpires next…

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