3Preparation OutlineCurrent SOC and status of Previously Accepted RFI’s, any equivalencies or extensions granted.Survey team arrives after 7:30AM biographies are on internet; this starts your facilities team into action by calling a code “J” to scour the building within one and a half to two hours.The surveyor can opt to do the building tour or the document review first. Doing the document review has its advantages.
4LSCS surveyor will focus on: EC Fire DrillsEC Features of Fire ProtectionEC Emergency Power SystemsEC Medical gas SystemsHazard Vulnerability Analysis (HVA)Emergency Operations Plan
5LSCS surveyor will focus on: And may also surveyLD EP-4 Accountability (Leaders at the program, service, site, or department level create a culture that enables the hospital to fulfill its mission and meet its goals. They support staff and instill in them a sense of ownership of their work processes. Leaders may delegate work to qualified staff, but the leaders are responsible for the care, treatment, and services provided in their areas.)LD EP-2 Hi-Priority (Leaders give priority to high-volume, high-risk, or problem-prone processes for performance improvement activities.)LD EP-5 Resources (The governing body provides for the resources needed to maintain safe, quality care, treatment, and services)
6ScoringAll findings of less than full compliance are cited as RFI, RFI resolution is through Evidence of Standards Compliance (ESC).Score based on the number of times an EP is not met, i.e.: sample size is at least 10 items surveyed.Score of 2 is for 0-1 instance of non-complianceScore of 1 is for 2 instances of non-complianceScore of 0 is for 3 or more instances of non-compliance
7CriticalityImmediate threat to life (samples on next slide): Preliminary Denial of Accreditation (PDA) until resolved. PDA can only be issued by TJC President. Follow-up survey required.Situational Decision Rules: Contingent Accreditation and PDADirect Impact Requirements must be resolved within a short time (45Days)Indirect Impact Requirements must be resolved within 60 days, these generally do not impact the accreditation decision.
8Immediate threat to life Triggers (ITL) When these items are significantly compromised:Fire AlarmSprinkler AlarmEmergency Power Supply SystemMedical Gas Master PanelCompromised ExitsOther situations that place patients, staff, or visitors at extreme danger.Note:Any ITL will automatically trigger an RFI at LD EP-2. (The governing body’s ultimate responsibility for safety and quality derives from its legal responsibility and operational authority for hospital performance. In this context, the governing body provides for internal structures and resources, including staff, that support safety and quality.)
9NEW – Time Frequencies Defined: Daily, weekly, monthly are considered calendar references.Quarterly, is once every three months ± 10 days.Semi-Annual, is 6months from the last scheduled event month ± 20 days.Annual, is 12months from the last scheduled event month ± 30 days3 Years, is 36 months from the last scheduled event month ± 45 days.Note: Time frames do not apply to required frequencies such as emergency generator testing (see EC EP-4 and EP-8).Frequencies required by code may not be modified.
10Issues with ECEach device tested is required to be in an inventory.Lack of an inventory results in a finding at that EPDocumentation for a specific EP is not available at time of the survey will result in a finding for that EP.If a finding is clarified after the survey TJC will review and evaluate for compliance.But the finding for LD EP-4 (Staff is held Accountable) will remain
11EP.02.03.05 EP-25 Requires the following summary information Name of the ActivityDate of the ActivityRequired Frequency of the ActivityName, contact information, including affiliation, of person who performed the activityNFPA standard(s) referenced for the activityResults of the activity
12Interim Life Safety Measures (ILSM) Standard LSILSM’s are required for EP-1 (notify local fir dept., fire watch and document it) and EP-2 (post signage to ID exits) regardless of the ILSM policy.EP-3 must clearly define in writing the ILSM policy including; (No policy Conditional RFI)When to implementWhat to do to protect patients and other occupantsBoth construction related and non-compliance with the LSCEP-4 to 14 aligns with the policy and implementation strategies.
13Life Safety Assessment - SOC Current Statement of ConditionsBasic Building InformationPlan for improvementLadder and flashlightsAccurate Life safety Drawings with information that shall include. Life Safety Legend that clearly identifies features of LS. (next slide)
14Life Safety Assessment – SOC page 2 Identify:Areas that are sprinkleredHazardous storage areasAll Rated barriersAll Smoke barriersSuite boundaries include size, if sleeping (5,000 sq.ft.) or non-sleeping (max 10,000 sq.ft.)Locations of smoke compartmentsLocations of chutes and shaftsAny approved equivalencies or waivers
15Management PlansFacilities managers are usually responsible for at least three possibly more management plans.All plans should be consistent with the organizations Mission, Values, and Philosophy statements. One way to do this is have them approved annually by the Safety Committee.Your plan will be assessed base3d on its written program if it exceeds the minimum interpretation of the Elements of Performance.Your Policies and Procedures are the guidance that defines the programs responses.Your documentation will ensure the activities being carried out have been pre-planned.
16Equipment Survey Process ( 1 of 2 ) Documentation is completed for both Life Support and Non-Life Support devices on the inventory. You must have an inventory with time frames of PM work.Inventory must be accurate:All Life Support equipment must be on the inventoryPM frequencies must be clearly defined in writing.
17Equipment Survey Process (cont’d) Surveyor will confirm the work is done as per schedule activitiesEnsure appropriate work is scheduled based on maintenance strategies.Evaluate equipment failure and scheduled action. Do not forget to include ILSM consideration for equipment failures.Report equipment failures and all follow-up actions to the EOC committee.
19CMS LSC Waiver Conditions CMS is granting LSC waivers due to unusual hardships and no alternatives that provide an equal level of protection.Applications for the waiver is not required.Waivers elected for use must be documented and meet all conditions of the waiver.Notify the any LSC survey team and present the information at the entrance conference of waivers elected. Otherwise your waivers will be accepted.LSC survey team will review information and confirm you are meeting the circumstances of the waiver.
20CMS LSC Waiver Summary ( 1 of 7 ) Medical gas master alarms:Allows substitution of a centralized computer system for one Category 1 medical gas master alarm.Code RequirementNFPA , and compliance with all other applicable NFPA medical gas master alarm provisionsFacilities MustDemonstrate that it complies with all other applicable NFPA medical gas master alarm provisions, as well as with section of NFPA
21CMS LSC Waiver Summary ( 2 of 7 ) Openings in Exit EnclosuresPermits existing openings in exit enclosures to mechanical equipment spaces if they are protected by fire-rated door assemblies.Code ReferenceNFPA , (9)(c) and all other applicable NFPA exit provisionsMechanical Equipment Space MustBe in a building protected with an approved supervised automatic sprinkler systems.Be used only for non-fuel-fired mechanical equipment.Contain NO storage of combustible materials and,Be protected by a fire rated door
22CMS LSC Waiver Summary ( 3 of 7 ) Emergency generators and standby power systemsReduces the annual diesel-powered generator exercising requirement from two (2) continuous hours to one and a half hours.Code ReferenceNFPA , and all other applicable NFPA operational inspection and testing provisions.The annual load test is only required when the monthly diesel generator test does not comply with minimum loading requirements to avoid wet stacking.
23CMS LSC Waiver Summary ( 4 of 7 ) Door locking arrangementsAllows door locking arrangements in areas where there are clinical needs, security risks or specialized protective measures required for safety.Code ReferenceNFPA , 18/ through 18/ as well as all other applicable NFPA door provisions.Facilities staff must make adequate provisions in the rapid removal of occupants by means such as remote control locks or keys carried by the staff at all times.
24CMS LSC Waiver Summary ( 4 of 7 part two ) Multiple delayed egress locksAllows more than one delayed-egress lock in the egress path where the clinical needs require specialized security measures or when a patient requires specialized protective measures for safety.Code ReferenceNFPA , 18/ and compliance with all other applicable NFPA door provisions.Facilities Must also use compensating safety measures specified in those sections that facilitate rapid removal of occupants.
25CMS LSC Waiver Summary ( 5 of 7 ) SuitesAccommodates the use of suites by allowing: (1) one of the required means of egress from sleeping and non-sleeping suites to be through another suite, provided adequate separation exists between suites; (2) one of the two required exit access doors from sleeping and non-sleeping suites to be into an exit stair, exit passageway, or exit door to the exterior; and (3) an increase in sleeping room suite size up to 10,000 sq. ft.Code ReferenceNFPA , 18/ and compliance with all other applicable NFPA suite provisionsFacility must meet the corridor wall and door requirements for the outer boundary (perimeter) of the suite and meet the requirements for the smoke zone.One or more egress routes may be required, depending on the size of the suite. *
26CMS LSC Waiver Summary ( 6 of 7 ) Extinguishing requirementsAllows for the reduction in the testing frequencies for sprinkler system vane-type and pressure switch type water-flow alarm devices to semiannual, and electric motor-driven pump assemblies to monthly.Code ReferenceNFPA , 5.3 and 8.3 and all other applicable NFPA (as referenced in section of the NFPA )Facility must meet the code references stated.
27CMS LSC Waiver Summary ( 7of 7 ) Clean waste and patient record recycling containers.Allows the increase in size of containers used solely for recycling clean waste or for patient records awaiting destruction outside of a hazardous storage area to be a maximum of 96 gallons.Code ReferenceNFPA , 18/Facility must document that the container has passed an FM fire test.
28MiscellaneousFacilities that do not meet all the requirements of the waiver will be cited.Where do these waivers leave the 2012 LSC?ASHE believes the agency still wants to adopt the 2012 edition, but because the lengthy adoption process is contingent on other priorities, CMS wanted to give hospitals some relief from burdensome requirements in the meantime.I personally am skeptical!