Presentation on theme: "“Categorical CMS Waivers”. Health Care Hierarchy Who is in charge? “Centers for Medicare & Medicaid Services” - AKA: CMS Who is the babysitter? “The Joint."— Presentation transcript:
“Categorical CMS Waivers”
Health Care Hierarchy Who is in charge? “Centers for Medicare & Medicaid Services” - AKA: CMS Who is the babysitter? “The Joint Commission” - AKA: TJC (formerly JCAHO) Use their own standards based on CMS regulations “Det Norske Veritas” - AKA: DNV Use the ISO:9001 quality principles Is anyone else in charge, or just CMS? At Kaweah Delta, we must meet the regulations of: CMS, TJC, CDPH, State of CA Fire Marshal (via OSHPD), local authority having jurisdiction (in Visalia, this is the Fire Marshal), OSHA, etc. Whose rules do we have to follow? Whoever is most strict
Health Care “Bibles”
It’s never okay to break the rules, except sometimes.
Relative humidity in anesthetizing locations Medical gas master alarms Openings in exit enclosures Emergency generators and standby power systems Door locking arrangements Multiple delayed egress locks Suites Extinguishing requirements Clean waste and patient record recycling containers Items in the corridor Kitchens open to the corridor Gas fireplaces in common areas Installation of combustible decorations Bending the Rules – Categorical Waivers
Relative Humidity in Anesthetizing Locations NFPA 99, 1999 edition: § Why is it important? Current requirement is ≥ 35% relative humidity Waiver decreases to ≥ 20% relative humidity UPDATE: S&C: Hospital, CAH & ASC Issued by CMS February 20, 2015 What do we do? Monitor relative humidity levels in anesthetizing locations, take action when needed to ensure that levels remain at or above 20%. Document, Document, Document.
Emergency Generators and Standby Power Systems NFPA 110, 1999 edition: § Why is it important? Shorter run times on the annual generator load bank tests equate a lower cost for testing, reduction in the use of diesel and reduced negative environmental impacts. What do we do? Ensure that you are in compliance with ALL other applicable NFPA 110, 1999, operational inspection and testing provisions and § of NFPA 110, Document, Document, Document
Door Locking Arrangements NFPA 101, 2000 edition: § 18/ – 18/ Why is it important? Previously, we were not allowed to have doors that remained locked in the event of a fire alarm or power outage (if on magnet locks). In units where the clinical needs of the patient (i.e. psychiatric, Alzheimer, dementia, neonatal, pediatric) require specialized security measures for their safety, door locking arrangements are permitted. What do we do? Ensure that you are in compliance with ALL other applicable NFPA 101, 2000 door provisions, as well as §18/ – 18/ of NFPA 101, Document, Document, Document
Suites NFPA 101, 2000 edition: § 18/ Why is it important? Prior to the waiver, every habitable room was required to have an exit access door leading directly to an exit access corridor. Only allowed exit through another suite under certain circumstances. Limits the size of sleeping room suites to 5,000 sq. ft. What do we do? Meet with your local AHJ to ensure that they approve of the changes. Document, Document, Document One of the two required exits can be: exit stair, exit passageway, or exit door to the exterior. Can now exit through another suite. Allows suite size up to 10,000 sq. ft.
Clean Waste and Patient Record Recycling Containers NFPA 101, 2000 edition: § 18/ Why is it important? Increases the can size of clean waste (bottles, cans, paper) from 32 gallons to 96 gallons. Reduce the number of receptacles, which creates more room in the corridor. What do we do? Must be compliant with NFPA 101, 2012 §18/ e.g. 96 gallon containers shall be labeled and listed as meeting the requirements of FM approval standard 6921, Containers for Combustible Waste.Containers for Combustible Waste. Document, Document, Document
Items in the Corridor NFPA 101, 2000 (Several Sections) Why is it important? 2000 edition of the Life Safety Code mandates 8 feet of unobstructed with in Hospital corridors. With today’s technological advancements and the inception of Electronic Medical Records, we have more equipment that is used in the course of patient care. What do we do? Ensure that you are in compliance with ALL other applicable NFPA 101, 2012 §18/ standards are met. This includes compliance with §7.3. Meet with your local AHJ to ensure that they approve of the changes. Document, Document, Document The 2012 code will allow previously restricted items to be in the corridor. CANNOT USE CORRIDOR FOR STORAGE
Installation of Combustible Decorations emicalList.pdfhttp://osfm.fire.ca.gov/licensinglistings/pdf/flameretardant/chemical/Ch emicalList.pdf NFPA 101, 2000 edition: § 18/ Why is it important? Previous code had severe restrictions on furnishings, mattresses and decorations. “Combustible decorations shall be prohibited in any health care occupancy unless they are flame-retardant.” What do we do? Meet with your local AHJ to ensure that they approve of the changes. Document, Document, Document Waiver permits following NFPA 101, 2012.
How to bend the rules 2.Document your decision to use a categorical waiver(s). Most commonly done during an Environment of Care meeting. 4.Notify surveyors (CMS, TJC, DNV, CDPH) at the beginning of the survey that they have chosen to declare a categorical waiver. THIS IS CRITICAL. 1.Gather and prepare documentation along with a Categorical Waiver Declaration. 3.Prepare a binder or file of Categorical Waivers with back up documentation and a summary to have at the ready.
B.there was no bulb in the lamp. “An administrative assistant called in a work request stating that her desk lamp did not work. When the technician responded to the request he discovered that: A.the desk lamp was not plugged in. C.the admin had brought the lamp from her home.”
“Tenant: When the fire alarm goes off, please send a quick to let everyone know if it is a false alarm or if they should actually start evacuating.” “Tenant Request: “Can the speed bumps be shaved down? They are too high. I have to go too slow to go over them.””
“This occurred last week on the first day of the year to exceed 80 degrees. The occupants of one office complained they were too hot. I addressed it myself due to the political expediency of the issue. Upon arriving, the occupants expressed their dissatisfaction of our department and how we can’t get anything right. The space has two windows. In one of them is mounted a window A/C. It was set for 60 degrees, and was working beautifully. The other window was wide open. I informed them that the unit can’t cool the entire outdoors. I then noticed that one of the occupants had a small portable heater on under the desk. I asked why it was running, and she complained that her feet were cold.”
“I was on call one night when at 3 a.m. my pager goes off. I call in to the hospital and was connected with a nurse who had worked (there) for 30 years. She says, “I have a patient in room 21 and the lights don’t work.” I crawl out of bed, get dressed, and drive the eight miles. I go to the room and turn on the light switch, and all the lights go on. Puzzled, I step in the hallway and asked her what was I missing. She said, “I didn’t try the switch. I just thought that as it was dark in there that the lights must be burnt out.” I didn’t say any bad words until I was in my car on the way back home.”
“We once received an emergency work order (highest priority) to turn around the toilet paper roll because it was installed backwards. Our response was, “Toilet paper roll direction is a matter of personal preference and may depend on multiple critical life safety issues such as whether or not you have a kitten on the loose.””