ASHRAE 188 Compliance for Healthcare Facilities
When it comes to the issue of hospital accreditation most people know about The Joint Commission, but not as many are familiar with The Centers for Medicare and Medicaid Services (CMS). Both are bodies designed to enforce compliance with federal regulatory standards for hospitals with the end goal to ensure quality care and patient safety. The Joint Commission sets its standards and establishes elements of performance based on CMS standards – Joint Commission standards must meet or exceed the CMS established federal requirements. Therefore, a hospital that is accredited by The Joint Commission is by definition compliant with CMS.
The process by which hospitals are deemed to be in compliance by both organizations includes random, unannounced site surveys. There is a huge amount at stake for healthcare facilities to pass these surveys and demonstrate regulatory compliance: by achieving certification a hospital is deemed eligible to receive Medicare and/or Medicaid funding. Consider that in 2016 57.1 million people were enrolled in Medicare, and in fiscal year 2016 federal Medicare disbursements topped 615 billion dollars. If a hospital does not achieve certification they will not receive reimbursement from these federally funded programs which can make up a significant part of their annual revenue. The site surveys cover a myriad of different areas, including infection control and physical plant safety and maintenance, and a line item that falls within both of these particular areas is minimizing the risk of a Legionnaire’s Disease outbreak in the facility.
Hospitals are particularly high-risk buildings with respect to a potential Legionnaire’s Disease outbreak for two main reasons:
- The are heavily occupied by the very young, the very old, and sick people, all of whom have less than fully robust immune systems and are thus vulnerable to the legionella bacteria.
- They often have showers that are not used on a regular basis. This allows the legionella bacteria to grow in the stagnant water in the plumbing leading to the shower head, only to be released within a fine mist (for inhalation – the primary route for legionella exposure) when the shower is next turned on.
It is interesting to note that on June 2, 2017 the CMS released an official policy memorandum titled “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease” applying to CMS hospitals, critical access hospitals, and long-term care facilities. Within is emphasized that “CMS expects Medicare certified healthcare facilities to have water management policies and procedures [in place] to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems.” And the memo goes on to specifically cite the (fairly) recently released ASHRAE Standard 188 as a best practices template on which to base these policies and procedures.
ASHRAE Standard 188, titled ‘Legionellosis: Risk Management for Building Water Systems,’ was released in June 2015. ASHRAE Standard 188 put in place within the United States for the first time highly credible, scientifically peer-reviewed industry best practices for Legionella risk management. It is already the legal “standard of care” for the prevention of Legionnaire’s Disease in commercial buildings, and in 2016 the CDC and its partners developed a toolkit to facilitate implementation of the Standard including the environmental, clinical, and epidemiologic considerations for healthcare facilities.
Healthy Buildings offers a comprehensive and professional service which hospital owners and managers can utilize to develop legionella risk and water management plans to obtain compliance with ASHRAE Standard 188, and thus CMS accreditation as well. These plans include:
- Identification of Buildings and Program Team
- Water Process Flow Diagrams
- Water Assets Inventory
- Identification of Control Locations
- Written Management Plan
- Documentation & Verification of Processes
- Validation Procedures and Legionella Testing
For more information on ASHRAE 188 compliance for healthcare facilities, please contact us.