CODING


Applying NFPA 99 to Your ASC The Health Care Facilities Code identifies provisions for maintaining building systems and equipment BY JONATHAN R. HART


Health care facilities, including ASCs, contain many building systems and equipment that are unique compared to other occupan-


cies. Those systems play a vital role in providing care to patients and are a key component in patient outcomes. Even those systems that are not unique to health care can have more importance in facilities that are occupied by the sick, weak or otherwise compromised (i.e., individuals who are sedated or under anesthesia). The continual upkeep of these systems and equipment is essential to providing safe patient care. The Health Care Facilities Code,


NFPA 99, includes requirements for many of these systems including medi- cal gas and vacuum systems, electri- cal systems, heating, ventilation and air conditioning (HVAC), as well as information technology (IT) and com- munications


systems, and plumbing


systems. The code also includes provi- sions for electrical and gas equipment commonly found in these facilities, emergency and security management, and hyperbaric facilities. As of July 6, 2016, ASCs participating in Medicare or Medicaid were expected to meet the requirements of the 2012 edi- tion of NFPA 99 as part of the Condition of Participation, per the Centers for Medi- care & Medicaid Services (CMS). The majority of NFPA 99 applies


to new construction only and any ASC whose plans were approved after July 6, 2016, will have to meet the entirety of the 2012 edition of code. Existing ASCs and newly constructed ASCs that have passed initial inspections and are now in opera- tion should refer to the complete text of NFPA 99 for specific requirements.


Application to Existing Facilities The code dictates in its application state- ments that construction and equipment requirements apply only to new con- struction and new equipment, except as modified in individual chapters, and to altered, renovated or modernized por- tions of existing systems. Those items specified by individual chapters are touched upon later but, for the most part, address only items that ensure safe daily operational use of systems or equipment and also routine inspection, testing and maintenance activities. Existing systems that do not meet all the requirements of the 2012 edition of the code are allowed to be continued in use unless an author- ity having jurisdiction (AHJ) determines a “distinct hazard to life.” A good way to know what survey- ors inspecting your ASC are going to be looking at is the CMS Fire Safety Sur- vey Report, Form 2786-U (www.cms. gov/Medicare/CMS-Forms/CMS-Forms/ Downloads/CMS2786U.pdf). Also reach out to your accreditation organization for specific guidance they have.


Risk Assessments


One of the big changes from prior edi- tions of NFPA 99 that were enforced by CMS is that the document is now orga- nized based on risk to patients and staff, rather than by the type of facility. Risk assessments are intended to be applied to new systems only and are not retro- actively applied by NFPA 99.


Piped Medical Gas and Vacuum Systems Medical gas, such as oxygen and medi- cal air, are intended for direct respiration by patients. Medical vacuum can be just as vital as gas in operating rooms where the loss of the vacuum would make many


20 ASC FOCUS APRIL 2018 |www.ascfocus.org


procedures incredibly difficult for sur- geons to complete. Piped systems are not required by NFPA 99 but, where installed, must meet the requirements. Where the design requirements are focused on min- imizing the chance of losing these sys- tems (through redundancies), those that are required for systems already in place are largely focused on the identification, labeling and operations of central supply locations and the operations and manage- ment of the systems themselves. Central supply locations for medical


gases include distinct hazards including the potential for mechanical damage to the cylinders, connecting the incorrect gas to the system and the possibility of oxygen enriched atmospheres. Several requirements for maintaining the rooms are specified for existing facilities to mit- igate these hazards. The code requires that all facilities


develop and document periodic mainte- nance programs for these systems. The maintenance program must include inven- tories,


inspection schedules, inspection


procedures and maintenance schedules. Specific timeframes are not stipulated but rather left to the facility to determine through their own risk assessment.


Electrical Systems Because electrical system failure can have a significant impact in health care facilities, backup power is required in facilities where the loss of power can pose risk to patients. The loads connected to this backup power can be of a much larger magnitude than for other facilities. NFPA 99 along with NFPA 110, Standard for Emergency and Standby Power Systems, provide many of the requirements for the generator sets, their supporting components and trans- fer switches. Inspection, maintenance and testing of these emergency power sys-


The advice and opinions expressed in this column are those of the author and do not represent official Ambulatory Surgery Center Association policy or opinion.


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