Tuesday, June 28, 2016

CMS Adopts 2012 Edition of NFPA, LSC and HCFC

On June 20, 2016, CMS issued S&C: 16-29-LSC. The memorandum notifies State Agencies and Regional Offices that CMS has adopted the National Fire Protection Association (NFPA), 2012 Life Safety Code (LSC) and 2012 Health Care Facilities Code (HCFC), effective July 5, 2016.

Buildings constructed before July 5, 2016 can meet existing occupancy requirements, as can buildings that receive design approval or building permits for construction before July 5. All other building construction must meet new occupancy requirements.

The final rule continues to allow CMS to waive specific provisions of the LSC, which would result in an unreasonable hardship upon a facility, providing that the waiver would not adversely affect the health and safety of the patients.

Additionally, the final rule continues to allow a state to request that its fire safety requirements be used in lieu of the 2012 edition of the LSC and HCFC with CMS.

Survey Process
The memorandum explains that CMS will begin surveying for compliance with 2012 LSC and 2012 HCFC on Nov. 1, 2016, allowing CMS to train surveyors, revise fire safety survey forms and update the ASPEN program. Surveyors will continue to use the current process, tags, and forms until then. In instances where the survey process identifies deficiencies that would be compliant under the 2012 LSC, a facility may verify compliance with the 2012 LSC as an acceptable plan of correction and the deficiency will not be cited.

CMS also notes that the LSC shortened survey process outlined in S&C Letter 13-22 will no longer be able to be used after Oct. 31, 2016, until CMS is able to analyze new data to determine which facilities will be able to be surveyed using the shortened survey process. According to the letter, any state that believes losing the shortened survey process for a period of time will cause it staffing and/or scheduling difficulty should contact their Regional Office. CMS will notify state Survey Agencies if the determination is made to use the LSC shortened survey process again.

You may send questions concerning the memorandum to SCG_LifeSafetyCode@cms.hhs.gov.

To view the 05042016 Fire Safety Requirements Final Rule, see Federal Register.

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