There are many instances when hospitals have off-site spaces or on-campus buildings physically separated or separated by rated construction where they provide ambulatory surgery or a variety of outpatient services. There are occasions when inpatients are transported to one of these buildings for services or treatment not available in the hospital. Does the occupancy designation change because some inpatients are being treated? What chapter(s) of the Life Safety Code® should be applied? In a July 30, 2008 e-mail to CMS regional personnel, the Centers for Medicare & Medicaid Services (CMS) Life Safety Code Specialist, James Merrill, P.E., provided the “Survey Process” criteria below that summarize the Life Safety Code® chapters to be applied to off-site buildings owned or leased by hospitals for outpatient department services, ambulatory surgical services, nursing homes, etc. This reconfirms and updates a Health Care Finance Administration (HCFA) directive written in March of 1993. This criteria may be used as a first step in determining appropriate LSC application for those instances when hospitals have off-site spaces or those separated by one-hour or two-hour construction between occupancies where they provide ambulatory surgical or other outpatient services.
Survey Process:
1. If inpatients receive treatment or services routinely, on a 24-hour basis (sleeping in the building), then Chapter 18/19 (Health Care Facilities) should be applied.
2. If outpatients (and/or inpatients, but the inpatients do not sleep in the building overnight) receive treatment or services in the outpatient building (a separate building), and if they are incapable or are rendered incapable, of self-preservation or receive general anesthesia, then Chapter 20/21 (Ambulatory Health Care) should be applied.
3. If outpatients receive treatment (and/or inpatients, but only on an occasional basis and they do 3. not sleep in the building overnight), and if they are capable of self-preservation and do not receive general anesthesia, then Chapter 38/39 (Business Occupancies) should be applied.
4. If there is more than one occupancy in a building without a two-hour separation between occupancies, the most stringent occupancy chapter applies.
While the above-listed CMS survey process for occupancies outside of a healthcare occupancy is summarized, the nature of the medical services provided and to whom they are rendered must be considered as should the LSC definitions provided in the 2000 NFPA 101® Life Safety Code®.
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