Benefits of the CMS move to the 2012 edition of NFPA 101
BY RON COTÉ
ON THE WEBSITE FOR the Centers for Medicare and Medicaid Services, it is reported that health care spending in the United States in 2014 reached $3 trillion, or more than $9,500 per person, with Medicare and Medicaid funding $1.1 trillion. Health care services providers rely heavily on CMS funding, which requires compliance with NFPA 101®, Life Safety Code®, as a condition of participation (CoP) in the Medicare and Medicaid programs.
In 2003, CMS began requiring compliance with the 2000 edition of NFPA 101, and that CoP remained in effect for more than 13 years. During the period when CMS enforced the 2000 edition, the code was continually refined by the NFPA life safety technical committees over five different editions. Compliance with the 2000 edition helped maintain the high level of life safety from fire and other emergencies in hospitals and nursing homes that had been established in the previous decade. NFPA data shows that from 2009 through 2013, less than one fire death per year occurred in hospitals and three fire deaths per year occurred in nursing homes.
In 2011, CMS announced it would update its CoP to the 2012 edition of NFPA 101, and the proposed rule was published in 2014. Some 350 public comments were elicited, which CMS addressed over a two-year period. The final rule was published this spring, with an effective date of July 5, and revised to a November 1 inspection and enforcement date.
CMS's move to enforce the 2012 edition of NFPA 101 was not made to further reduce life loss from fire in hospitals and nursing homes, but it’s still significant. The 2012 edition offers health care providers new options to make required fire and life safety features less obtrusive on the day-to-day goal of providing effective health care services, and to more accurately reflect the design and operation of these facilities.
For example, some of the fire and life safety protection options in the 2012 edition make for a more homelike and less institutional health care setting. Other changes provide more flexibility in delivering health care services, such as the increase in the maximum size of patient care sleeping suites from 5,000 square feet (460 square meters) to 7,500 square feet (700 square meters) and 10,000 square feet (930 square meters). The direct supervision by staff, as required for patient areas within sleeping suites, is permitted via automatic smoke detection. Where two exit accesses are required from a patient care sleeping suite, one of the exit accesses is permitted to be into an adjacent suite. Egress provisions for non-patient-care suites are permitted to be in accordance with the primary use and occupancy of the space.
Additionally, corridor clear width requirements have been modified for placement of wall-mounted equipment such as alcohol-based hand-rub dispensers; wheeled equipment and carts in use, wheeled emergency medical equipment not in use, and wheeled patient lift and transport equipment; and fixed furniture. Kitchens are permitted to be open to corridors to encourage residents to participate in supervised meal preparation. Additional options are offered permitting larger areas of walls to be covered with combustible decorations. Exemptions are offered to recognize use of direct-vent gas fireplaces and solid fuel–burning fireplaces. Requirements of a new chapter on building rehabilitation are applied incrementally in proportion to the complexity of the project so that not all rehabilitation work must follow the requirements of new construction.
As I get closer to retirement and to increased use of the health care system, my hopes are buoyed that health care facilities will remain safe while better accommodating the activities of daily life.