Skilled nursing facilities are compelled by regulatory compliance to provide residents, staff and visitors with a safe environment of care.  Providers occasionally receive deficiencies for conditions in their buildings that are completely avoidable with a good Life Safety Code management program.   Beyond the regulations, it is simply the right thing to do to ensure that the vulnerable residents of long-term care facilities around the nation are safeguarded from harm.

Codes, standards, regulations and protocols focused on fire prevention and life safety are designed to provide occupants of healthcare facilities with the operational safety elements they expect and deserve.  Compliance with regulations equates to a safe and prepared operation.

Developing and sustaining a safe environment of care does not happen by accident. Facilities management and environmental services professionals are given the monumental responsibility of ensuring life safety in a building. While many of the tasks associated with the Life Safety Code (NFPA 101, 2012 edition) and the requirements of the Health Care Facilities Code (NFPA 99, 2012 edition) are managed by “in-house” staff, some tasks are outsourced to qualified vendors who possess the technical expertise needed to manage some of the more complex areas of operation. These include required testing of medical equipment and other electrical appliances that come in contact with residents.

A common deficiency issued by Life Safety Surveyors in every state is K-921 for failing to comply with the requirements of the Health Care Facilities Code section 10.3 as enforced by the Centers for Medicare & Medicaid Services and its contractors. This finding often takes providers by surprise and is easily avoidable through the development of a good preventative maintenance program.

Due to the sophisticated nature of electronic medical equipment and electrical appliances present in skilled nursing facilities, the Centers for Medicare & Medicaid Services and the National Fire Protection Association (NFPA) require specific regimens of inspection, testing and maintenance (ITM) of patient care-related electrical equipment (PCREE). 

This includes all electronic medical equipment and even items like electric beds, as well as other electrical appliances directly related to patient/resident care.  

Testing frequency of PCREE should be based on the manufacturer’s guidelines.  Because of the wide range of ITM frequencies cited for different types of equipment and appliances from different manufacturers, many facilities will develop a policy and procedure requiring annual activities for all items in question.

 It is common for providers to engage a third-party vendor who has the technical expertise to inspect, test and maintain PCREE as the requirement for those responsible for these functions states that they must receive “continuing training” (see highlights below).

Skilled nursing facilities should develop and maintain a policy and procedure for this process in alignment with the requirements of K-921, as cited in the Health Care Facilities Code, section 10.3 and associated references.  Additionally, providers are required to develop and maintain documentation for all PCREE inspections, testing and maintenance to demonstrate compliance.  Again, good Life Safety Code management and preventative maintenance programs can help facilities avoid this type of deficiency.

Here are the highlights of the requirement cited in The Health Care Facilities Code (NFPA 99, section 10.3, 2012 edition):

  • PCREE must be tested at intervals established by the facility’s own policy and procedures (based on manufacturer’s guidelines)
  • Inspection and testing include the following for fixed and portable PCREE:
    • Physical integrity
    • Resistance
    • Leakage current
    • Touch current tests
  • All PCREE used in resident rooms is tested before being put in service and after any repairs or modification
  • Service manuals and manufacturer’s guidelines must be considered in the development of an electrical equipment maintenance program
  • Instructions and maintenance manuals are readily available
  • Safety labels and condensed operating instructions are legible
  • Documentation is maintained of all tests, repairs and modifications in accordance with the facility’s PCREE policy and procedure
  • Personnel responsible for the testing, maintenance and use of electrical appliances receive continuing training

This important area of facilities management requires a great deal of commitment and technical expertise to safeguard building occupants from harm. Protecting vulnerable residents and the LTC workforce from injuries caused by electrical shock or other electrical hazards should be a high priority at every SNF in the country.  Compliance with the requirements of K-921 will also promote Life Safety Code survey success.

Stan Szpytek is the president of the national consulting firm, Fire and Life Safety, Inc. based in Mesa, Arizona. He is a consultant for the American Assisted Living Association (AALNA) and is the Life Safety/Disaster Planning Consultant for the Arizona Health Care Association, California Association of Health Facilities (CAHF) and Utah Health Care Association. Szpytek is a former deputy fire chief and fire marshal with more than 40 years of experience in life safety compliance and emergency preparedness. For more information, visit www.FLSafety.org or e-mail Szpytek at [email protected].

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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