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Streamlining Interpretations For Healthcare Fire Protection Issues
Background and History
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, safety and performance of a healthcare facility, slight (sometimes major) 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, created in 1996, was originally known as the Authority Having Jurisdiction Committee, was comprised of representatives from:
The purpose was to bring together the organizations that must enforce, implement, abide by or evaluate the various fire protection measures found in nearly every 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® the formally adopted reference for CMS. Ultimately, the 2000 edition was advanced and is now referenced for this purpose.
Another important area identified where across-the-board communication was deemed essential involved interpretation and understanding of the various NFPA codes and standards used in the healthcare environment. Use, interpretation and understanding of these documents; the relationship between NFPA criteria and state regulation; and how NFPA rules relate to the position and policy views of groups like CMS and The Joint Commission (TJC) can sometimes be difficult to navigate.
The Healthcare Interpretations Task Force established an original mission, purpose, and process by which the Task Force would operate. In 2012, the Task Force brings together the organizations shown below to evaluate, debate, and engage the resources of the member organizations to establish consistent interpretations of specific issues and questions. The Chair of the Life Safety Code Committee on Healthcare Occupancies and the Chair of the Healthcare Facilities Correlating Committee also maintain a seat on the HITF. While the debate and discussions are open to all parties, the actual voting by the committee is limited to the seven authority having jurisdiction members; CMS, DOD, IFMA, IHS, TJC, SHA, and VA. In addition, two-thirds of the voting members must be in agreement about a particular answer to a particular question.
The original mission statement, paraphrased below, captures the essence of what the HITF has worked to establish.
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.
The ideals of this original mission are now captured in the Charter and Bylaws of the HITF. In this process, nothing the HITF 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.
In the normal course of action, the HITF will receive several agenda items 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 or position that makes sense and that can be applied by the various enforcement agencies that look at the fire protection and life safety 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 - TJC, CMS, local and state fire marshal’s and state health departments. The HITF, through the publications and information media of their respective organizations, will make public the results of their efforts to get the widest possible dissemination of their discussions.
Questions for the HITF must come in through one of the member organizations. The HITF meets at least once per year, normally during the NFPA Conference and Expo held very June. Questions for this group should be directed to any of the organizations (listed below). Interpretations and answers to questions will be available in the NFPA website and other publications.
Currently, the twelve member organizations are:
Agency for Health Care Administration