Health Care Interpretations Task Force (HITF)

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Streamlining Interpretations For Healthcare Fire Protection Issues

As a field surveyor, policy administrator, fire marshal or other authority having jurisdiction, how many times have you received different interpretations from different parties, concerning the same problem? Because of the number and variety of groups that evaluate all aspects of the service and performance of a healthcare facility, slight differences in interpretations of applicable codes and standards can arise. The Healthcare Interpretations Task Force (HITF), is now in place to help reconcile organizational differences of opinion.

Formed in July 1998, this Task Force is the by-product of a unique coalition of the major organizations that most impact the healthcare community in terms of fire protection related issues. This coalition, now known as The Authority Having Jurisdiction Committee, is comprised of representatives from:

Agency for Health Care Administration
American Health Care Association (AHCA)
American Society for Healthcare Engineering (ASHE)
Centers for Medicare/Medicaid Servces (CMS)
Department of Defense (DoD)
Indian Health Services (IHS)
International Fire Marshals Association (IFMA)
Joint Commission on Accreditation of Healthcare Organizations (JCAHO)
National Fire Protection Association (NFPA)
Department of Veterans Affairs (VA)

When this larger coalition was founded in 1996, its purpose was to bring together the key players who must enforce, implement, or evaluate the various fire protection measures found in each healthcare occupancy in the U.S. This group has worked on several initiatives including working to make recognition of the 1997 Edition of the Life Safety Code a reality for CMS. Another area identified where across-the-board communication was deemed important involved interpretation and understanding of the various NFPA codes and standards used in the healthcare environment and how they relate to position and policy views of groups like CMS and JCAHO.

The Healthcare Interpretations Task Force established a mission, purpose, and process by which the Task Force would operate. In essence, the Task Force brings together the seven key organizations (CMS, JCAHO, IFMA, VA, NFPA, ASHE, AHCA, DoD, and IHS), to the table to evaluate and debate, and engage the resources of the talent pool to establish consistent interpretations of specific questions. While the debate and discussions are open to all seven parties, the actual voting by the committee is limited to the four authority having jurisdiction members; IFMA, CMS, JCAHO, VA, DoD, and IHS. In addition, 3 of the 4 voting members must be in agreement about a particular answer to a particular question.

The mission statement, paraphrased below, captures the essence of what this group hopes to establish during its existence.
MISSION: To provide consistent interpretations on national codes and standards referenced by CMS, JCAHO and state and territorial authorities having jurisdiction. This will be accomplished through the evaluation of field conditions, surveyor/inspector/fire marshal interpretations, and questions by consumers of these services generated through a member of the task force.

In this process, nothing the task force does is intended to usurp the power or authority of an NFPA Technical Committee who still has ultimate responsibility for rendering formal interpretations to their respective documents. In fact, the task force will actually recommend forwarding unresolved items to the appropriate NFPA Technical Committee for a formal interpretation, or as individual members, recommending changes to NFPA codes and standards to clarify certain issues.

At the very first meeting of the Task Force, several agenda items were provided for the group to consider and evaluate. As with any code or standard, one's perspective, background and experience may cause a slightly different opinion as to what is intended or meant by a particular requirement. A thorough, thoughtful debate, including some historical perspective, background or case history with a particular issue, results in a cohesive melding of the minds. The result is an interpretation that makes sense and that can be applied by the various enforcement agencies that look at the fire protection features in a healthcare facility.

This process will bring a great deal of consistency to the myriad issues with which a healthcare facility must deal, often times with, multiple, key authorities having jurisdiction - JCAHO, CMS, local and state fire marshals and state health departments. The Task Force, through the publications and information media of their respective organizations, will be publishing the results of their efforts to get the widest possible dissemination of their discussions.

Questions for the Task Force must come in through one of the member organizations. It is anticipated that this group will be meeting on a quarterly basis and will be looking for additional items to review and evaluate. Any questions for this group should be directed to any of these organizations (listed below). Interpretations and answers to questions will be printed in this and other publications in the future.

MEETING INFORMATION

Agendas