CMS issues additional change to CoPs that could affect HOPDs
Chad Beebe
Deputy Executive Director for the American Society for Healthcare Engineering of the American Hospital Association
The Centers for Medicare & Medicaid Services (CMS) is making a correction to its earlier rule, which was published in May and outlined new Conditions of Participation that adopted the 2012 editions of NFPA 101 and NFPA 99. The correction, which was published in the Federal Register on June 30, states that Part 482.41 of the Conditions of Participation is being changed so that all (new and existing) hospital based outpatient surgical departments must meet provisions of NFPA 101 applicable to Ambulatory Health Care Occupancies, regardless of the number of patients served. Under NFPA 101, outpatient departments may fall under the business occupancy chapter if the facility has less than four patients rendered incapable of self-preservation, receiving anesthesia, or needing assistance for self- preservation. CMS has said that hospitals will have until November before surveys begin on the new CoPs.
The change could affect small hospital-associated medical office buildings that are providing minimally invasive surgical procedures.
ASHE is trying to gauge the effects of this correction on hospitals. Please take this short survey for each outpatient building in your hospital system to let ASHE know how this change will affect your facilities.