CMS Clarifies Occupancy Classification

On December 17, 2010, the Centers for Medicare and Medicaid Services (CMS) issued a memorandum to its State Survey Agency Directors titled, “Hospital and Critical Access Hospital (CAH) Facility Life Safety Code (LSC) Occupancy Classification Update”. The memorandum caused confusion because, as written, it did not clearly distinguish between requirements for various occupancies. As originally issued, all clinics providing health services would have been required to comply with all Ambulatory Health Care requirements in NFPA 101, 2000 edition, Chapters 20, 21 and additional referenced chapters. The ambiguous standards could have triggered millions of dollars in renovation costs to clinics and hospital buildings in California alone.

CHA’s Joint Committee on Accreditation and Licensing and several other associations and provider groups, contacted CMS with its concerns. As a result, on February 18, CMS sent out a revised memorandum to State Survey Agency Directors making the requirements much more acceptable to the provider community. Click here to view memorandum. If a hospital was cited due to a deficiency based on the original December 17 memorandum, please contact your Regional CMS office.

Contact: Roger Richter at (916) 552-7570, rrichter@calhospital.org