Circle the wagons—the changes are coming, the changes are coming!
One if by land and two if by January 2026. Well, at least the "official" announcement came in 2025. If you had an increase in the importance of the risk assessment process on your compliance bingo card, you might just be a winner.
It will be interesting to see how things unfold next week during the ASHE Health Care Facilities™ Innovation Conference. If I hear anything useful, I will be sure to kick it your way. At first blush (and perhaps second and third blushes), I suspect that the impact on the management of the physical environment is going to very much mirror those halcyon days of CMS' adoption of the 2012 edition of the Life Safety Code®, which, upon reflection, were rather more anticlimactic than anything.
That said, I expect a wee bit of chaos in the field as surveyors are educated to the substance of the changes even though the existing survey process is "supposed" to reflect an assessment of compliance with the Conditions of Participation (CoP), so the "bones" of the survey process should be present and accounted for. Where things are likely to get a little funky is that the CoPs have typically been the basis for a wide-ranging set of interpretations—compliance will continue to be, as it always has been, in the eye of the (surveyor) beholder. At this point, I think that what I am most interested in is how the Frequently Asked Questions and Perspectives advisories will be applied during survey. There does appear to be some vagaries relative to the Interpretive Guidelines in the CMS manuals and whether they constitute the establishment of regulatory requirements outside of the rule-making process.
If we have learned nothing over time, it is that compliance comes in every manner of shape, color, number, etc. and is as variable as snowflakes. Compliance looks different in every organization because every organization is different and the compliance strategy has to reflect the operational complexities. As I am fond of saying, the easiest thing to police is an absolute (usually prefaced with a big, fat "no"), but all too often the absolute becomes a challenge to devise a workaround. There are ways to work around the workarounds, but we shall leave that conversation for another time.
At any rate, we've got a little time (though I imagine the next 6 months will fly by at close to lightspeed) to figure out how this will all work.
PS: Beyond this, I am going to refrain from pointing out that anything that rotates 360 degrees ends up right where it started...
About the Author: Steve MacArthur is a safety consultant with The Chartis Group. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is an advisory board member for Accreditation and Quality Compliance Center. Contact Steve at stevemacsafetyspace@gmail.com.