Tuesday, April 30, 2019

Changes to the NFPA 99 that you need to know about today!

NFPA 99 Healthcare Facilities code provides performance criteria for healthcare facilities that follow a risk-based approach, where it is the risk posed to patients, staff or visitors, that defines safety guidelines. The main criteria of the Code's scope is to keep healthcare facilities up-to-code with its occupants safe.

"What Applies to My Facility"? 



Understanding and interpreting an NFPA code can often leave facility manager’s
scratching their head. Requirements are not always so black and white and
determining which edition of the NFPA code applies to your facility can be a
frustrating endeavor.
 
Moreover, once the correct interpretation of the code has been established, there is still the question of its application to your individual scenario. Risk assessments must be performed to determine the correct category and level of care provided and the corresponding application.
 
Applying NFPA 99 varies depending on the level of care required and provided. 

NFPA 99 (Recent History 

Since July 5, 2016 the Centers for Medicare and Medicaid Services (CMS) has
adopted the 2012 edition of NFPA 99. From a medical gas compliance perspective, this is the edition to which facilities are held accountable.
 
However, since NFPA 99 is not intended to be a retroactive code, only select portions of NFPA 99-2012 shall apply to systems existing prior to the July 5, 2016 adoption. Specifically, the inclusion of NFPA 99-2012 Tentative Interim Amendment (TIA) 12-4, outlines the sections that apply to both new and existing construction.
 
Similarly, much of the criteria in TIA 12-4 can also be found in The Joint Commission Hospital Accreditation Standard, EC.02.05.09. It should be noted, however, that individual AHJ’s (authorities having jurisdiction) are permitted to adopt subsequent editions of NFPA 99 for the purposes of new construction.

Annual Evaluation of Medical Gas System 

When performing an annual evaluation of your medical gas system, it is important
to know which sections of NFPA 99 apply. This will require a thorough understanding of your risk category, as well as historical knowledge of your facility since any pipeline alterations, renovations or modernizations may impact the application.
 
For example, if an older facility had a portion remodeled and the pipeline is breached, the area in the immediate vicinity would need to be installed to the most recently adopted edition of NFPA 99 for that jurisdiction.
 
Conversely, the older portions of the systems not meeting the 2012 edition may still be acceptable to the AHJ as long as their continued use does not present a distinct hazard to life. In either scenario, a comprehensive understanding of your facility and its relationship with NFPA 99 is vital.
 
Knowing which sections of your facility may require upgrades can be beneficial for infrastructure budgeting, and ensuring the smooth operation of your medical gas system for years to come.

Current NFPA 99 HealthCare Facilities Code - 2018 Edition  

Changes in the 2018 edition help you work more efficiently to ensure healthcare safety.  
Here are some of the details that will be required under the NFPA 99-2018 code that are different from earlier versions. Cites are from the code currently.

1. Oxygen Concentrators

Chapter 5 includes requirements that now allow for the use of oxygen concentrators as central supply sources for piped medical gas systems. 5.1.3.5.11* Oxygen Concentrator Supply Units.
5.1.3.5.11.1 states Oxygen concentrator supply units for use with medical gas pipelines shall produce oxygen meeting the requirements of Oxygen 93 USP or Oxygen USP.
What it means...
The 2018 edition adds requirements for onsite oxygen production by a concentrator. Oxygen concentrators are and continue to be, limited in use for most facilities in the United States. Remote areas, such as Hawaii, Alaska, and other island territories implementing NFPA 99 will now have some guidance on their use.
Background on why that change has been made...
The technology behind these supply sources is nothing new and their use has previously been part of the ISO Standard, but is now addressed by NFPA.
How the change may impact the present or future design of medical gas and vacuum systems...

Ultimately, this addition to the 2018 code will have little to no impact on most facilities within the United States since a majority of hospitals are supplied by a traditional cryogenic fluid central supply system (previously referred to as a bulk cryogenic liquid system).

2. Vacuum Filtration 5.1.3.7.4

The detailed requirements for vacuum filtration are defined in the code. The filters are required to be as efficient as HEPA (0.3μ (microns) and 99.97% high efficiency)
What it means...
 
Medical-Surgical Vacuum Central Supply Systems now require inlet filtration on
the patient side of the vacuum producer.
 
Background on why that change has been made...
 
While the science is still out and more data is required, there has been a
concern that infectious or other hazardous materials may be transmitted from
the patient terminal back to the supply source. The addition of this filtration is
to alleviate some of those potential concerns.
 
How the change may impact the present or future design of medical gas and vacuum systems...
 
Manufacturers will need to incorporate these filtration requirements into the
design of their new vacuum systems. 

3. Corrugated Medical Gas Tubing

5.1.10.1.4 Corrugated medical tubing (CMT) is now a permitted material for medical gas and vacuum systems.
What it means...
The additional inclusion of corrugated medical tubing will allow installers another piping option, particularly for difficult installations. Ease of installation, reduced cost, and less chance of contamination are benefits that are invaluable for healthcare facilities. CMT is a fabricated tubing with flexibility making it ideal for retrofits and new construction.
Kevin Hoben, OmegaFlex® CEO, a global manufacturer of metal hoses, says
"Copper tubing has always been costly to install with countless brazed sections that make a system vulnerable to leaks and contamination. MediTrac comes in one, long length to eliminate hotwork, and its unique design makes it easy to bend as needed to fit a space." 
MediTrac is fully compliant with NFPA 99 (2018) code. 
Background on why that change has been made...
This is a new technology for medical gas piping.
How the change may impact the present or future design of medical gas and vacuum systems...
Corrugated medical tubing's usage can be beneficial, particularly for the installation of positive pressure piping in pre-existing construction. It can reduce the number of installed joints and aid in installations where space or brazed joints can be difficult.
How to implement the change...   
Contact your installer to see if CMT tubing would be beneficial to your next project.

4. The Addition of Chapter 15: Dental Gas and Vacuum SystemsThis chapter was added specifically to dental gas and vacuum systems to address their precise needs.  

What it means...
With the previous changes to NFPA 99, particularly as it relates to the change from an occupancy-based document to a risk-based standard, there were some issues with requirements for dental facilities, which were historically addressed as a Category 3 system.
Background on why that change has been made...
 
Since Category 1 procedures can be performed in a dental setting,
the need for an expanded chapter was necessary. Now, within a dental setting,
NFPA addresses Categories 1-3.
How the change may impact the present or future design of medical gas and vacuum systems...
This change will allow for a more detailed understanding and implementation of NFPA 99 for all manner of dental system installations.  

5. "Governing Body" Wording

In addition, we are seeing a global change in the 2018 edition. 

In addition, we are seeing a global change in the 2018 edition. 
The term "governing body" is changed to "healthcare facility's governing body". This is to help clarify or highlight the intent. Governing body represents the people who are responsible for the operation of the healthcare facility.   

Sunday, April 21, 2019

Nursing Shortages in the hospital will soon hit the ambulatory surgery centers, are you ready?

In Denver, 78-year-old Mary Heidenreich died when a nurse who had
flunked a medication competency test accidentally gave her a fatal dose of
intravenous drugs.

In Wichita, Kan., 38-year-old Deedra Tolson bled to death after an
emergency hysterectomy when her nurse, busy caring for 12 other patients,
failed to hear her feeble cries for help.

In Alliance, Ohio, 30-year-old Lisa Vitale was waiting to give birth when she
felt searing pain rip through her abdomen. An overworked nurse misread
Vitale's fetal monitoring strip and failed to notice that her baby was in
acute distress. Born hours after an emergency cesarean section could have
saved his health, Vitale's son suffered severe brain damage that left him
unable to drink from a bottle and required round-the-clock medical care.

In Florida, William T. Fain, 80, fell, hit his head, suffered brain damage and
died two weeks later, an autopsy report said all while under the care of an
agency nurse at Westside Regional Medical Center. Fain came to the ER
after a seizure on Super Bowl Sunday in 2006, his family said in a
negligence suit filed last month. Doctors ordered nurses to send Fain to the
ICU and, in the interim, take steps to prevent him from falling from his bed,
the suit said. They were to put up bedrails, lower the bed and check him
more often. The agency nurse on his case did none of those steps, the suit
said. After he spent 12 hours in the ER, and shortly after his family left for the
evening, nurses found Fain on the floor. He fell, hit his head, suffered brain
damage and died two weeks later, an autopsy report said.

Realizing all of these incidents were Acute Care related, how long can we dodge
this National Nursing Shortage in the Ambulatory Care setting?

• No matter what your historical staffing vacancy rates have been, it
is time we all begin to plan for the inevitable. Fewer nursing students are entering the field than vacant positions are needing to be filled. According to the Nurses Coalition, only one spot
out of ten vacancies are being filled by nursing graduates, leaving a 90% vacancy rate that often times than not, they are filled by temporary staff, agency staff, or just left with an open schedule and no nursing hours to give to the patient as they deserve.

Let's put together our great minds, let's join together to think outside this box we've known to achieve the unknown, and unchartered territory.  Ideas, thoughts, out there thoughts, please leave them for us in the comment sections of this blog.  Thank you. 

Friday, April 19, 2019

The checklist for patient and staff safety, do this every morning before the first surgical case.

  • OR temps and humidity levels are within acceptable ranges.
  • Medical gases levels are adequate.
  • Refrigerators and freezers where medications are stored maintained their temperatures overnight.
  • OR doors are fully closed, not propped open.
  • Electronic access doors are functioning properly.
  • Hallways are clear of obstructions.
  • Fire extinguishers are easily accessible.
  • Crash carts have been tested and are fully stocked.
  • All lights within the department are on and are working properly.
  • Cords in ORs are out of walking pathways or safely covered.
  • Sharps containers aren't filled to capacity.
  • Headcovers, shoe covers, face masks and eye shields are readily available.
  • Hand soap and antiseptic dispensers are full.

By doing these simple rounds of items that should be checked before the beginning of every surgery day, you add an enormous amount of patient safety and staff safety to the layer of work that is worth its weight in gold.

Friday, April 5, 2019

California has removed the Moratorium on new Durable Medical Equipment Companies Enrollment!

Discontinuation of the Moratorium on the Enrollment of Durable Medical
Equipment Providers Located Outside of California and in Los Angeles, Orange,
Riverside and San Bernardino Counties.

The Department of Health Care Services (DHCS) ended the moratorium on the
enrollment of durable medical equipment (DME) providers located outside of California
and in Los Angeles, Orange, Riverside and San Bernardino Counties on
February 23, 2019.

This bulletin provides information for DME applicants in the affected
counties applying for enrollment in the Medi-Cal Fee-For-Service Program during the
six-month period following the expiration of the moratorium.


Title 42, Code of Federal Regulations (CFR), Section 455.450(e)(2), and Welfare and
Institutions Code (W&I), Section 14043.38(b)(4), specify that a provider that would have
been prevented from applying for enrollment due to a moratorium that has been lifted in
the past six months, be screened at the “high” categorical risk level.

In addition, the Centers for Medicare and Medicaid Services (CMS) currently designates
all newly enrolling DME suppliers as a “high” categorical risk, subjecting all new DME
applicants to fingerprinting for criminal background checks. (Title 42, CFR §§ 424.518,
455.434, and 455.450).

A “high” risk screening requires a provider or applicant to submit proof that fingerprints
for all the required individuals have been submitted to an authorized State Identification
Bureau (Bureau of Criminal Information and Analysis, Department of Justice [DOJ] in
California). Providers and applicants must attach a copy of a prefilled DOJ Request for
Live Scan Service (BCIA 8016) form for each required individual with their application,
date stamped and show verification that all fees have been paid, by either a “PAID”
stamp from the public Live Scan operator or a receipt of payment.

For more detailed information on which individuals are required to submit fingerprints,
please review the Information Bulletin Regarding Medi-Cal Requirement to Submit
Fingerprints for a Criminal Background Check.

If you are a currently enrolled DME provider that is not located out-of-state or in one of
the counties that were subject to the moratorium, you do not need to be screened as
“high” risk.

Additionally, if you are a currently enrolled DME provider and you would have met one
of the exemptions listed below, you do not need to be screened as “high” risk but you
must submit a cover letter with your application advising which exemption you meet and
include any necessary supporting documentation.

1. DME applicants who for the purpose of the Medi-Cal Program choose to be
enrolled for medically necessary lactation aids. DME providers of lactation aids
shall be reimbursed for items mentioned in the Medi-Cal Provider Manual for
Lactation Management Aids [found in Durable Medical Equipment (DME): Bill for
DME (dura bil dme)];

2. DME applicants who for the purpose of the Medi-Cal Program choose to be
enrolled as Customized Wheelchair DME (CWDME) providers and/or Oxygen
and Respiratory Equipment DME (OREDME) providers;

a. CWDME providers shall sell, service, and/or repair customized
wheelchairs as medically necessary for Medi-Cal beneficiaries. An
enrolled CWDME provider shall be reimbursed for items authorized in the
Medi-Cal Provider Manual for wheelchairs, modifications and accessories.

b. OREDME providers shall sell, service, and/or repair Oxygen and
Respiratory Equipment. An enrolled provider shall be reimbursed for items
authorized in the Medi-Cal Provider Manual, under the Oxygen and
Respiratory Equipment Group and deemed medically necessary for
Medi-Cal beneficiaries.

3. Current Medi-Cal enrolled DME providers seeking to add a new business
location in the same county, so long as the DME provider enrolled in the program
after October 12, 1999 and is not adding new business activities, categories of
service or billing codes other than those approved for enrollment at its existing
location;

4. Applicants who will be enrolled solely for reimbursement of Medicare cost-sharingamounts;

5. An application that is submitted because an existing Medi-Cal enrolled DME
provider, which is part of a group of affiliated corporations (as defined by Cal.
Corporations Code, Section 150), is transferring its assets to an affiliated
the corporation that is a part of the same group of affiliated corporations;

6. An application that is submitted because an existing Medi-Cal enrolled DME
provider, who is an individual operating as an unincorporated sole proprietorship,
has incorporated that sole proprietorship, with all of the existing issued shares of
the new corporation is owned by that individual who is also the president of
the new corporation;

7. An application that is submitted because there has been a cumulative change of
50 percent or more in the person(s) with an ownership or control interest in an
existing Medi-Cal enrolled DME provider provided that the change only consists
of a reorganization or consolidation among existing person(s) previously
identified in the last complete application package that was approved for
enrollment as having an ownership interest in the provider totaling 5 percent or
greater;

8. Applications submitted pursuant to California Code of Regulations, Title 22,
Section 51000.55 or Section 51006, Subparts (a)(1), (a)(2), (a)(3) or (a)(5);

9. Applications submitted pursuant to California Code of Regulations, Title 22,
Section 51000.30(b)(3) provided that there is no change in the person(s)
previously identified in the last complete application package that was approved
for enrollment as having control or ownership interest in the provider totaling
5 percent or greater;

10. Applications submitted pursuant to California Code of Regulations, Title 22,
Section 51000.30(a) only because an existing Medi-Cal enrolled DME provider
has changed its location provided that its previous business was located in one
of the following counties: Los Angeles, Orange, Riverside, or San Bernardino and
is not adding new business activities, categories of service or billing codes other
than those approved for enrollment;

11. Applicants that are the only person or entity in the United States that provides
specific product or service that is a Medi-Cal covered benefit; or,

12. DME applicants who, for the purpose of the Medi-Cal program, choose to enroll
to provide only the services and/or replacement parts for a Medi-Cal covered
device for an enrolled Medi-Cal beneficiary, when those services and/or parts are
not available from an enrolled Medi-Cal provider on the date of application.
You are required to be screened at the “high” categorical risk level and submit
fingerprints for a criminal background check if any of the following apply:

1. If you are a newly enrolling DME provider;
2. If the Department determines that you do not meet an exemption; or
3. If you do not want to go through an exemption review.

Failure to submit fingerprints for a criminal background check when required will result
in the denial of the application package. (42 CFR § 455.416; W&I Code §
14043.26[f][4][E])

Additional information about the Medi-Cal requirements for submitting fingerprints is
available in the Information Bulletin Regarding Medi-Cal Requirement to Submit
Fingerprints for a Criminal Background Check.

If you have any additional questions, please contact the Provider Enrollment Message
Center at (916) 323-1945 or submit your question via e-mail to PEDCorr@dhcs.ca.gov.

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