FGI Standards on Ventilation

Q: The Centers for Medicare & Medicaid Services (CMS) standard §482.41(c)(4) states in their Interpretative Guidelines that hospitals must comply with the Facilities Guidelines Institute (FGI) for ventilation in anesthetizing locations. The Joint Commission standard EC.02.06.05, EP 1 requires compliance with the same FGI standards on ventilation. Our operating rooms were designed more than 20 years ago when the AIA guidelines at the time had less air changes per hour than what the new 2010 FGI guidelines require. Am I supposed to modify my current ventilation equipment in order to comply with the new 2010 FGI guidelines for air changes per hour? 

A: This short answer is No; you do not have to modify your existing air handler to meet the new 2010 FGI guidelines on air changes per hour, unless you alter, renovate or remodel the rooms the ventilation equipment serves. The Interpretative Guidelines for the CMS standards are not part of the enforceable standards, and are considered references. CMS does not expect compliance with the new FGI guidelines on existing equipment; only on new construction. Also, CMS states “acceptable standards such as from the Association of Operating Room Nurses (AORN) or the FGI should be incorporated into hospital policy.” This means, the FGI guidelines are not the only standard you should consider when designing new construction or renovated areas.

In regards to the Joint Commission standard EC.02.06.05, EP 1, it clearly states in the standard: “When planning for new, altered, or renovated space…” This means the FGI guidelines only apply to new construction, and not to existing conditions. And the FGI guidelines are only one of a set of criteria that the organizations may choose to comply with. The others are state rules and regulations or other reputable standards and guidelines that provide equivalent design criteria.

CMS Requirements on Ventilation Testing

Q: What does CMS require as far as frequency of testing of air changes per hour (ACH) in hospitals? I see where we are supposed to test and know what ACH is required, but I have not seen at what frequency we are to test. 

A: You raise a very interesting point. CMS seems to have a different philosophy when it comes to writing standards, than say, The Joint Commission, HFAP or DNV. CMS does not write into their standards as much detail or specifics as the accreditors do. CMS does rely heavily on their written Interpretive Guidelines and Survey Procedures that they include with their standards. At times, these Interpretive Guidelines and Survey Procedures have very useful and detailed information.

In regards to ventilation requirements, CMS standard §482.41(c)(4) says “There must be proper ventilation, light, and temperature controls in pharmaceutical, food preparation, and other appropriate areas”. That’s all it says in the standard, which is not much to go on. But their Interpretive Guidelines for this standard says: Acceptable standards such as from the Association of Operating Room Nurses (AORN) or the Facilities Guidelines Institute (FGI) should be incorporated into hospital policy.”

So, CMS is saying in their Interpretive Guidelines that the FGI Guidelines must be followed for ventilation requirements. But it is important to understand that the FGI Guidelines are not retroactive to existing conditions, but are used for the design of new construction or renovated areas. For existing conditions, you need to be compliant with the laws, regulations and FGI Guidelines (or AIA Guidelines, if the area is that old) that were in affect at the time the area was designed or renovated.

If your existing area can meet the current FGI Guidelines, then that is great and you’re in good shape. If your existing area cannot meet the current FGI Guidelines, then you need to determine what regulations or guidelines were in effect at the time the area was constructed. If you meet those ventilation requirements, and you can document that, then you’re in good shape.

Now, to answer your direct question: “What does CMS require as far as frequency of testing of air changes per hour (ACH) in hospitals?” The answer is…CMS does not specify how frequent you need to check the ACH rates, and neither does the FGI Guidelines appear to specify how frequently you need to check your ACH rates. But that does not mean you do not have to perform periodic checks. The answer is… You get to decide how often you check the ACH rates, but it better be based on reasonable assumptions. The state agency surveyors who will survey your hospital on behalf of CMS will have expectations on how often you check the ACH. I could offer suggestions, but ultimately you need to know and follow what your state agency inspectors expect. I suggest you contact them and discuss this issue with them to understand what their expectation will be.

More on the CMS S&C Memo Concerning Power Strips

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 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- 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 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.

CMS Issues Categorical Waiver on Power Strips

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- (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 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 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

Congratulations! CMS Approves The Joint Commission for Six More years

I suspect most of you didn’t give this much thought, but ever since 2009, The Joint Commission has had to apply to CMS for their deeming authority to survey hospitals and other healthcare organizations on behalf of the federal agency for Medicare & Medicaid reimbursements. Joint Commission was approved by CMS in 2010 for 4 years, which would expire this year if they did not re-apply.

Re-apply they did and this time it appears CMS was waiting for them and gave them a huge list of things they needed to change about their standards and practices, or they would not receive CMS deeming approval. In all, CMS identified at least 52 specific items that Joint Commission needed to address before they would receive the deeming status that they needed to stay in business.

To their credit, The Joint Commission did the work necessary to comply with the CMS demands. The changes they made that would be most notably in the physical environment areas, include:

  • Open PFIs will be cited on the final survey report;
  • Agreeing that only CMS can approve equivalencies;
  • Issuing two new Elements of Performance (EPs) which address the requirements for the organization to conduct risk assessments when determining the best equipment maintenance strategy, under EC.02.04.03, EP 24, and EC.02.05.05, EP 6;
  • Issued new EC.02.02.01, EP 18 requiring radiation workers to be checked periodically;
  • Issued new EC.02.02.01, EP 19 requiring procedures for trash storage and disposal;
  • Changed EC.02.03.01, EP 10 to include the phrase “and report fire alarms”;
  • Changed EC.02.05.03 to add the rooms “intensive care, and emergency rooms”.

You might be surprised to learn how hard The Joint Commission has been working to re-write their standards to comply with CMS’s demands. It is easy to think of the largest accreditor as an agency that perpetuates itself year after year, but that is not the case anymore. They have a boss (CMS) that they have to report to, and follow their directives. One indication of the seriousness of this issue, is usually The Joint Commission announces changes to the standards six months before they become effective. The fact that most of the changes mentioned above are effective July 1 (or July 2), 2014, and were only announced to the public during June, says they deviated from their normal practice to satisfy CMS.

It must have worked, since CMS published a statement in the Federal Register on Friday, June 27, 2014 announcing their approval for The Joint Commission as a deeming authority, for another six years. I seriously mean this when I say Congratulations! to The Joint Commission for this achievement. I know it must have been difficult.

Changes With Equivalency Requests for The Joint Commission

imagesO752ZQ8RAs a result of the June 4, 2014 online announcement by The Joint Commission which identified major changes for the Statement of Condition Plan for Improvement (PFI) list, they also mentioned that beginning July 1, 2014 all equivalency requests submitted to them will be passed along to the appropriate CMS Regional Office for their approval.

What The Joint Commission did not say is CMS will not accept any equivalency requests unless it is submitted as part of the organization’s Plan of Correction. This means, hospitals will no longer be able to submit an equivalency request prior to a survey, but will only be able to submit equivalency requests after the Life Safety Code deficiency is cited in a survey report.

What affect will this have on hospital facility managers? I think both changes involving the PFI list and the equivalency requests has the potential for a huge impact on the overall safety of the physical environment, and it won’t be positive.

In just the two days since Joint Commission announced this change, I must have talked with or emailed with over 20 different facility managers and safety officers of Joint Commission accredited hospitals, discussing what options they have with these new changes. This has many of these individuals very concerned since two key tools are changing on how they manage their Life Safety Code deficiencies.

Allow me to summarize these changes:

1). Beginning July 1, 2014, Joint Commission says all items identified on the PFI list will be cited as deficiencies on the survey decision report. No longer will hospitals enjoy a pass from receiving a written deficiency in the survey report for anything identified on the PFI list. [I talked with one facility manager who has over 200 items on his PFI list and their organization is in the survey window for their triennial survey. He needs to clear those PFIs or risk having them identified on the survey report.]

2). Joint Commission says they will review equivalency requests and send them on to the CMS Regional Office for final action. Since CMS does not accept equivalency requests for LSC deficiencies that have not been cited on a survey report, no longer will facility managers be allowed to be proactive and seek an equivalency for a deficiency prior to a survey.

So, I see a very strong potential for facility managers to discontinue being proactive and identify their LSC deficiencies prior to a triennial survey, since there is no relief from the PFI list and there is no opportunity to seek an equivalency. They very likely will take the stand of wait-and-see if the surveyor finds the deficiency and then deal with it afterwards. I fear our industry may fall back into the “hide our skeletons” concept of over 20 years ago. No longer will some facility managers want to be transparent and self-identify their problems. By failing to self-identify their deficiencies, those deficiencies do not get resolved, and if the surveyors fail to identify them, then they likely will not get resolved at all. How safe is that for our patients?

Do not misunderstand me… I do not advocate facility managers to discontinue being proactive and identifying their LSC deficiencies prior to a survey. In fact, I encourage them to continue as though nothing has happened in regards to the PFI list, and still use it as a tool to manage their deficiencies. But, human nature being what it is, I suspect many hospitals will not be as safe as they once were because some facility managers will no longer be proactive and self-identify their LSC deficiencies.

And, you can forget about the cost effective and economical Traditional Equivalencies that Joint Commission used to accept. CMS will not accept those at all, and will only accept the more costly Fire Safety Evaluation System (FSES) as identified in NFPA 101A.

I think this is a very sad day for healthcare. While I was an advocate for fair play amongst all the accreditation organizations, I wanted CMS to approve the advantage that Joint Commission had with the PFI list and approving equivalencies prior to the deficiency being cited, for all accreditors, not just for Joint Commission. Instead, CMS did not clearly understand the potential actions their insistence will cause.

It looks like CMS will not stop until all the accreditation organizations are homogenized into one big quasi-government group whereby you won’t be able to tell them apart. What good is that?

Follow Up on Changes to the PFI LIst

imagesFWHXWLWMSince yesterday, I have received a lot of emails and calls concerning the Joint Commission announcement on changes to their PFI list. On Wednesday, June 4, 2014, Joint Commission published an online article which announced major changes to their survey decision report process, which will become effective July 1, 2014.

Currently, an organization is encouraged to report any Life Safety Code deficiency that they cannot resolve within 45 days of discovery, onto the Statement of Conditions Plan for Improvement (PFI) list, and identify a projected completion date. For many years (20 years?) placing a LSC deficiency on the PFI list provided the organization relief from a surveyor finding in the event of a survey. In the accreditation organization’s announcement on Wednesday, items listed on the PFI list will no longer be free from a surveyor’s citation beginning July 1, 2014.

The reason is the Centers for Medicare & Medicaid Services (CMS) has insisted that the Joint Commission stop this practice, and cite every deficiency that the surveyor sees during the survey. To their credit, Joint Commission has agreed to comply with the federal agency’s directive.

But I have received many emails and telephone calls from facility managers asking “What should I do?” Now that the Joint Commission will cite any item identified on the PFI list, many facility managers are reluctant to self-identify their deficiencies that will likely lead to a surveyor finding.

Let’s remember what the Statement of Conditions PFI list is all about: It is a Joint Commission management tool designed for facility managers to self-report Life Safety Code deficiencies so they can manage the resolution of the deficiency.  The PFI list is there for you to use in order to track the LSC deficiencies to completion. It is not a device in which Joint Commission can say “Gotcha” and hit you over the head.

There is no Joint Commission standard that says you must enter all LSC deficiencies into the PFI list that cannot be resolved within 45 days. Joint Commission does have a Frequently Asked Question (FAQ) on the subject, and the answer they provided is as follows:

The Joint Commission allows resolution of a deficiency by either correcting it immediately (preferred), managing it using a corrective maintenance work order system (with tracking capabilities) with resolution within 45 days, or creating a Plan for Improvement (PFI) and managing it using the electronic Statement of Conditions (SOC).

This is not a standard requirement of the accreditation organization, but more like a recommendation. I see it as an option for the facility manager. He/she does not need to enter the LSC deficiencies in the PFI list if he/she does not want to, especially now that there is no incentive to do so.

But don’t let that short-sightedness be your downfall: It may be better to list all your LSC deficiencies that you cannot resolve within 45 days on the PFI list and risk being cited for them, in order to track and manage each deficiency to a successful conclusion. I guess each facility manager needs to consider all of the alternatives and make their own decision.

For those that missed the Joint Commission announcement, click on the following link:  http://www.jointcommission.org/issues/article.aspx?Article=3hzpYDrgAaZdWi6C%2b1xoxANtx2DFfvVdArnSt2rJ2Yc%3d&j=1752680&e=brad@keyeslifesafety.com&l=9552_HTML&u=28545686&mid=1064717&jb=0

Joint Commission Announces Changes to PFIs and Equivalencies

Yesterday, Joint Commission published an online notice of changes to their survey decision reports effective July 1, 2014, that effectively eliminates the strategic advantage of healthcare organizations self-reporting Life Safety Code deficiencies on the PFI list, and changes how equivalencies are approved. The reason for these changes is to align Joint Commission’s survey process with the requirements of the Centers for Medicare & Medicaid Services (CMS). Joint Commission is in the process of having their renewal application for deemed status from CMS approved, and this action appears to be a direct result of CMS insistence to follow their rules.

CMS has for many years prevented other accreditation organizations (HFAP and DNV) the ability to have documents similar to the PFI list that provides protection from surveyor findings during a survey, and eliminated those AO’s authority to approve equivalencies. It appears now that by this action, a level playing field with all the AOs has been achieved and any unfair advantage that Joint Commission had is eliminated.

Specifically, the changes that Joint Commission announced in their online publication stated:

  • While Joint Commission retains their Plan For Improvement (PFI) section of the Statement of Conditions, they eliminated the protection of a finding on a survey report. They now say they will list all open, unresolved PFIs on the survey decision report, which puts them on the same level with the other AOs.


  • Joint Commission will no longer approve equivalencies, but will submit them to the appropriate CMS Regional Office for their approval. This also puts Joint Commission on the same level as the other AOs. In addition, this appears to eliminate the Traditional Equivalencies that Joint Commission used to approve, as CMS will only accept equivalencies that are based on NFPA 101A, which uses the Fire Safety Evaluation System (FSES).

Joint Commission also announced that they have created a new section in the survey decision report called the “Opportunities For Improvement” (OFI), in addition to the still current “Requirement for Improvement” (RFI) section.  This is significant as currently single observations of Category C elements of perforamce are not posted on the survey decision report, which is contrary to CMS’s directive. CMS has stated for years that all deficiencies observed by a surveyor must be cited in the survey decision report.

Now, single observations of Category C elements of performance will be cited in the survey decision report under the OFI section, rather than the RFI section. The ability to clarify away surveyor findings after the survey on Category C standards in the OFI section is eliminated. However, the online notice did not say that Joint Commission is eliminating the ability for healthcare organizations to clarify Category C findings scored under the RFI section.

So, based on this online notice, it is apparent that CMS held their ground with Joint Commission and made them implement the changes to eliminate the uneven playing field. It appears that all AOs are on the same page, and Joint Commission no longer has an unfair advantage on PFIs or Equivalencies.

It appears that these changes only applies to Joint Commission programs that are under the authority of CMS.

To review the online notice on these significant changes, go to:   http://www.jointcommission.org/issues/article.aspx?Article=3hzpYDrgAaZdWi6C%2b1xoxANtx2DFfvVdArnSt2rJ2Yc%3d&j=1752680&e=brad@keyeslifesafety.com&l=9552_HTML&u=28545686&mid=1064717&jb=0

Problems with the CMS Categorical Waivers


I have been receiving some feedback from friends and readers of the Keyes Life Safety Compliance website concerning the CMS categorical waivers. One of the issues seems to focus around whether a building is fully sprinklered or not.

The whole concept of what constitutes a fully sprinklered building seems to be different among various AHJs. Some want every square inch to be protected with water-based fire protection systems, and others will permit the exceptions found in NFPA 13. Here is how I see the issue:

Sections 18/ in the 2000 LSC says new healthcare construction needs to be protected with automatic sprinkler systems in accordance with section 9.7. The exception to 18/ allows for areas of buildings where the AHJ will not permit sprinklers, to be protected by ‘alternative protection measures’ (whatever that means) without the building being classified as nonsprinklered. This exception was inserted to account for those areas of the country where the local AHJ would not permit sprinklers in electrical rooms or elevator equipment rooms. The phrase ‘alternative protection measures’ means whatever the AHJ wants it to mean; from installing clean agent suppression systems (Halon, FM-200, CO2, etc.) to perhaps just a smoke or heat detection system. Or, it can mean something else.

Section says where automatic sprinklers are required by the occupancy chapter, they must be in accordance with NFPA 13 (1999 edition). NFPA 13 has some exceptions where a building does not have to have sprinklers installed in certain areas and it still would qualify as ‘being protected with automatic sprinklers in accordance with NFPA 13’. Therefore, with the exceptions allowed by NFPA 13, I see the Life Safety Code as saying these buildings are protected with automatic sprinklers in accordance with NFPA 13.

The CMS categorical waivers on unoccupied openings in exit enclosures references the new 2012 LSC, section (9)(c), which says existing openings in an exit enclosure are permitted as long as it meets multiple conditions, one of which being the building is protected with automatic sprinklers in accordance with section 9.7. There we are… back to 9.7, which references NFPA 13, which has some exceptions in certain buildings to not have sprinklers, but the building still has an ‘automatic sprinkler system in accordance with NFPA 13’. If the hospital implements any of these NFPA 13 exceptions then I would say it qualifies for the CMS categorical waiver. But technically, the hospital is not “fully sprinklered”, but would be considered protected with automatic sprinklers in accordance with section 18/19.3.5 and 9.7 of the 2000 LSC. The CMS S&C memo 13-58-LSC does not require a fully sprinklered building in order to qualify for the categorical waiver on the unoccupied openings to an exit enclosure. It only requires automatic sprinklers in accordance with section 9.7, which references NFPA 13.

But it never matters what I say; only what the AHJs say. If you have an AHJ that will not allow the CMS categorical waivers due to an approved NFPA 13 exception, then use the above logic as an argument that it should be allowed.

I also have some reports that certain state department of public health (DOH) do not recognize the CMS categorical waivers and will not permit them in the hospitals under their jurisdiction. That’s okay, as the state AHJs do not have to follow what CMS says, if they are assessing compliance with their own regulations and standards. Even if the state DOH is the official designated state survey agency for CMS, the most restrictive codes and regulations apply, and in this case the state regulations would take precedence of the CMS categorical waivers.

I hope this information is helpful…

CMS Issues New Proposed Rule on Disaster Preparedness

CMS Logo 2The Centers for Medicare & Medicaid Services (CMS) has issued a new proposed rule in the Federal Register on Friday, December 27, 2013. This is a Notice of Proposed Rulemaking and is not a Final Rule. CMS is soliciting comments on this proposed rule concerning healthcare facility disaster preparedness, and the general public has 60 days to respond.

Being a Federal Agency, CMS must follow the Administrative Procedure Act of 1946 whenever they want to add, remove or change a rule or regulation, and they must issue a public notice in the Federal Register that they are proposing a new rule. Then there is a 60-day window for the public to respond with comments to the proposed rule. After the 60-day window is over, CMS will take the time to review the comments made and will respond to them when they issue a final rule, in about 6 months or so (my guess of time- not theirs). The changes that CMS is proposing are to the respective Conditions of Participation or Conditions for Coverage to 17 different sets of rules (or laws) for healthcare organizations.

I have started an initial review of the proposed rule and I like what I see. CMS  identified four core elements that they believe are central to an effective emergency preparedness system and must be addressed by healthcare organizations to offer a more comprehensive framework of emergency preparedness requirements for the various Medicare- and Medicaid-participating providers and suppliers. The four elements are—(1) risk assessment and planning; (2) policies and procedures; (3) communication; and (4) training and testing.

CMS admits that they took into consideration the existing standards and regulation of national agencies, such as The Joint Commission and AOA/HFAP. The current CMS Conditions of Participation (CoP) for acute care hospitals are light on specific requirements for emergency management, and most experts agree that The Joint Commission Emergency Management chapter provided better guidance for healthcare facilities than any other standard.

Below is the link to the proposed disaster preparedness rule that was published today.


I encourage you to review the proposed new rule and if you have a comment, please follow the directions and submit it to the CMS. They will appreciate your insight and considerations.

After you have reviewed the proposed new rule, please let me know what you think of it.