As SNF providers should know by now, CMS officially adopted the 2012 editions of NFPA 101 (The Life Safety Code) and NFPA 99 (The Health Care Facilities Code) on July 5, 2016. To help ensure that surveyors are trained on the new editions of these codes prior to enforcement, the official enforcement date is set for November 1, 2016. This means that providers are currently being surveyed under the previously adopted editions of the codes until the first of next month. Once surveyors have been trained and start enforcing the new editions of the codes, it is speculated that they may focus on new and updated elements of the codes. Why wouldn’t they? They have just been “trained” on these changes.
It will be essential for providers to be prepared for new enforcement “challenges” that they will likely encounter with the 2012 editions of the codes. Significant changes have been integrated into each of the editions (v. the 2000 edition of The Life Safety Code and 1999 edition of the Standard for Health Care Facilities previously adopted) that are designed to enhance life safety conditions in facilities through new code concepts that focus on the capabilities of technology (fire protection and life safety systems) and the use of risk assessment. But, it must be understood that the 2012 editions are not the newest editions of the codes. The National Fire Protection Association (NFPA) currently has 2015 editions of both of these codes in publication. Providers must reference and utilize the proper editions of the codes (2012) to help ensure compliance in CMS-regulated facilities.
Providers will also need to “strap-in” and see how surveyors approach enforcement of the new editions of the code. Facilities management team members should obtain as much education as possible through reliable resources like state associations, trusted vendors and other organziations that may offer training opportunities on these new requirements.