Inpatients in Outpatient Locations

Q: Back in June of 2017, you posted an article about “Inpatients in Outpatient Locations”, but I am unable to access that posting. Can you re-post that article as I am interested in what you have to say about inpatients being treated in outpatient areas.

A: Yeah… I pulled that posting from my website because it had inaccurate information in it. That was an “Oops” on my part. I believe in my original posting (which is now gone) I said it was not permitted to take inpatients out of a healthcare occupancy, into an adjoining ambulatory healthcare occupancy or an adjoining business occupancy for treatment or exam. I based this thought on CMS’ position that one or more outpatients in an ASC requires the ASC to be classified as an ambulatory healthcare occupancy, instead of the four-or-more that NFPA says. For some reason, I thought this carried over to non-ASC ambulatory healthcare occupancies, which I found out it does not.

So, to be sure, section of the 2012 LSC does say ambulatory care facilities, medical clinics, and similar facilities that are contiguous to healthcare occupancies shall be permitted to be used for diagnostic and treatment services of inpatients who are capable of self-preservation. But the key point here, is the inpatients must be capable of self-preservation. This means they are capable of getting up out of the wheelchair or off of the gurney under their own power and exit the building without assistance from others. Most inpatients in a healthcare occupancy (at least the traditional hospital and nursing home healthcare occupancy) are not capable of self-preservation. So be extra careful by ensuring staff only take those inpatients that are capable of self-preservation into adjoining non-healthcare occupancies for treatment or exam.

I apologize for the confusion and misinformation.

Brad Keyes
Brad Keyes, CHSP

Brad is a former advisor to Healthcare Facilities Accreditation Program (HFAP) and former Joint Commission LS surveyor. He guides clients through  organizational assessment; management training; ongoing coaching of task groups; and extensive one-on-one coaching of facility leaders. He analyzes and develops leadership effectiveness and efficiency in work processes, focusing on assessing an organization’s preparedness for a survey, evaluating processes in achieving preparedness, and guiding organizations toward compliance. 

As a presenter at national seminars, regional conferences, and audio conferences, Brad teaches the Keyes Life Safety Boot Camp series to various groups and organizations. He is the author or co-author of many HCPro books, including the best-selling  Analyzing the Hospital Life Safety Survey, now in its 3rd edition. Brad has also authored a variety of articles in numerous publications addressing features of life safety and fire protection, as well as white papers and articles on the Building Maintenance Program. Currently serving as the contributing editor of the monthly HCPro newsletter Healthcare Life Safety Compliance  gives Brad further insight into the industry’s trends and best practices.