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The pipes are calling: CMS revises Legionella requirements

You can expect renewed interest in your water management program. This summer, CMS sent out a new memo updating its expectations on Legionella infections. The memo, QSO 17-30-Hospitals/CAHs/NHs, was published July 6. It supersedes the former S&C 17-30-Hospitals/CAHs/NHs, issued in June 2017, and adds more specific expectations for long-term care (LTC) facilities. The update also helps clarify expectations for hospitals and nursing homes.

The Legionella bacterium is responsible for legionellosis: a respiratory disease that can cause a type of pneumonia called Legionnaires’ disease, which kills about a quarter of the people who contract it. Legionellosis is especially dangerous for patients who are older than 50, who smoke, or who have chronic lung or immunosuppression conditions.

The bacterium breeds naturally in warm water and can usually be found in the parts of hospital systems that are continually wet. Poorly maintained water systems have been linked to the 286% increase in legionellosis between 2000 and 2014. The CDC says there were 5,000 reported cases of it in 2014 alone, with about 19% of outbreaks in long-term care facilities and 15% in hospitals.

While there are no new expectations for hospitals or critical access hospitals in the revised CMS memo, it does add a specific statement that “facilities must have water management plans” as well as a new note that testing for waterborne pathogens is left “to the discretion of the provider,” according to the letter to CMS’ Quality, Safety and Oversight (QSO) group, formerly the Survey & Certification (S&C) group.

“The terms ‘plans’ and ‘policies’ are sometimes confusing to hospitals,” warns Kurt Patton, the former director of accreditation services for The Joint Commission and founder of Patton Healthcare Consulting, now in Naperville, Illinois.

“The Joint Commission already requires a utilities management plan, and water is a component of that. The unknown will be if CMS surveyors say they don’t want to look at a utilities plan, they want to look at a water management plan,” explains Patton. “At a minimum, I would suggest accredited hospitals have a table of contents and a subject header for ‘Water Management Plan’ inside their overall utilities plan.”

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