For those of us that work in healthcare, we are used to regular adjustments in regulatory and code compliance requirements. Starting July 1, 2021, hospitals that are accredited by The Joint Commission will face major changes related to business occupancies (typically Medical Office Buildings or outpatient clinics) that are tied to the hospital or health system accreditation. While there have always been requirements impacting business occupancies in the Environment of Care (EOC) Chapter, life safety requirements were not specifically referenced. These changes will impact both Hospital and Critical Access Hospital standards.
2012 NFPA 101 – Life Safety Code as currently adopted by Centers for Medicare & Medicaid Services (CMS) defines a business occupancy as “an occupancy used for the transaction of business other than mercantile.” In healthcare, business occupancies consist of occupancies/facilities where patients are capable of self-preservation (3 or less incapable of self-preservation allowed) and do not remain in the facility overnight. Typically, this is will include medical office buildings (MOB), outpatient facilities, and clinics.
Moving forward, there will be five new life safety (LS) standards focused on business occupancies:
These standards include a handful of Elements of Performance (EPs) focused on general life safety in business occupancies including means of egress, hazardous areas, fire sprinkler systems, fire alarm systems, and fire extinguishers. Additionally, all requirements that exist within LS.01.xx.xx apply to all three occupancies – healthcare, ambulatory healthcare, and business.
What does this mean?
Why is this happening?
Joint Commission has always been required to at least meet the minimum requirements of the Conditions of Participation (CoPs) set forth by CMS. They have always had the ability to increase the requirements beyond these minimum levels, which may be what is happening in this instance. While we have not seen an official position to date, some of these requirements may also be considered by some of the other accrediting organizations.