Regulatory Roadmap - Navigating NC s Healthcare Code Landscape

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1 Regulatory Roadmap - Navigating NC s Healthcare Code Landscape October 11, 2017 Royal Banquet and Conference Center Raleigh, NC

2 The Presenter Project and Client Manager 20+ years experience 8+ years in Healthcare Facility Engineering Former North Carolina Division of Health Services Regulation Inspector Old Dominion University B. S. Engineering Technology Graduate U.S. Navy Nuclear Power Operations Veteran Alex Harwell, EI Dewberry Engineers Inc. 2 Triangle Chapter Meeting October 11, 2017

3 Topic Summary The Big Picture NFPA 99 & 101 The Hospital Licensure Rules & FGI The NCSBC Recap and Review For Your Reference 3 Triangle Chapter Meeting October 11, 2017

4 The Big Picture Codes & Standards Generally legislated requirements (non-optional rules) Codes are broad based requirements for all aspects of construction (e.g. life safety code) Standards are specific detailed requirements for a single aspect (e.g. fire alarm systems) Guidelines Generally optional reference material for best practices. May be legislated, but language typically does not support enforcement 4 Triangle Chapter Meeting October 11, 2017

5 The Big Picture Codes & Standards Applicable to NC Hospitals Codes & Standards Development Agencies Enforcement & Interpretation Agencies NCSBC NFPA 10A NCAC 13B FGI/ASHRAE NC BCC NC MCC ICC FGI NFPA NC DOI NC DHSR CMS TJC (AO) Local AHJs 5 Triangle Chapter Meeting October 11, 2017

6 The Big Picture NFPA 70 (NEC) Hospital Electrical Req. General Electrical Req. NFPA 101 Building Types Occupancy Classifications Means of Egress Fire Protective Construction Special Requirements for Occupancies & Hazards NFPA 99 Hospital Electrical Req. Hospital Medical Gas & Plumbing Req. Hospital System Maint. & Testing Req. Hospital I.T. Req. Hospital Licensure Rules & FGI Architectural Req. Electrical, Mechanical, Plumbing, Med Gas Req. NCSBC Building Types Occupancy Classifications Means of Egress Fire Protective Construction Special Requirements for Occupancies & Hazards Construction Components Plumbing & Mechanical Req. 6 Triangle Chapter Meeting October 11, 2017

7 Enforce 2000/2012 Edition Enforce 2000/2012 Edition & EC Enforce & Interpret 2000/2012 Edition The Big Picture Enforce & Interpret Current Edition Enforce Indirectly Enforce & Interpret FGI/ASHRAE Guidelines NC State Licensure Rules NC State Building Codes NFPA Codes Code Edition Referenced by NCSBC (1 Cycle Behind Current) Enforce & Interpret Enforce & Interpret Interpret & Enforce NC Department of Insurance (DOI) DHSR Licensure Plan Review & Inspection Local Inspections Departments (AHJ) 7 Triangle Chapter Meeting October 11, 2017 DHSR Federal Life Safety Surveyors CMS Accreditation Organizations (TJC) Federal CMS Inspections Enforce & Interpret*

8 NFPA 99 & 101 Who writes it: NFPA National Fire Protection Association Standards issued on a 3-year cycle Provides interpretation assistance Anyone can participate in the code process CMS Amends and modifies requirements via CFR 42 CFR 482 Conditions of Participation 8 Triangle Chapter Meeting October 11, 2017

9 NFPA 99 & 101 Who interprets it: CMS (official interpretive authority) NFPA (reference interpretations) De Facto Interpreters Accreditation Organizations (AO) NC DHSR Construction Section NC DHSR Federal Life Safety Surveyors (SA) 9 Triangle Chapter Meeting October 11, 2017

10 NFPA 99 & 101 Who enforces it: CMS via State Agencies (NC DHSR Federal LS Team) Deemed Status Accreditation Organizations (AO) 2000/2012 editions NC DHSR Construction Section Current edition by hospital rule reference (2015) 2000/2012 editions to correlate with CMS 10 Triangle Chapter Meeting October 11, 2017

11 The Hospital Licensure Rules Who writes it: Model Code/Standard: 1996 AIA Guidelines for Hospitals 1996 ASHRAE HVAC Applications PENDING FGI Adoption 1/1/18: 2014 FGI Guidelines* incl. auto-adoption & amendments ASHRAE incl. auto-adoption & amendments Amendments: NC Medical Care Commission (MCC) NC Legislature 11 Triangle Chapter Meeting October 11, 2017

12 The Hospital Licensure Rules Who interprets it: NC DHSR Construction Section Who enforces it: NC DHSR Construction Section 12 Triangle Chapter Meeting October 11, 2017

13 The NCSBC Who writes it: Model Code/Standards: ICC (All chapters excepting the NEC) NFPA (Standard 70 NEC et. al.) Does NOT include NFPA 101 or 99 Does include 70 (NEC), 13, 72, etc. NC Amendments: NC DOI Building Code Council 13 Triangle Chapter Meeting October 11, 2017

14 The NCSBC Who writes it: ICC International Code Council Established in 1994 from BOCA, SBCA, & ICBO User group committees develop codes Standards issued on a 3-year cycle Provides interpretation assistance Anyone can participate in the code process Standard model code for NC all other 49 states 14 Triangle Chapter Meeting October 11, 2017

15 The NCSBC Who writes it: NFPA National Fire Protection Association The National Electric Code Sprinkler & Fire Alarm Codes, other specifics Standards issued on a 3-year cycle Provides interpretation assistance Anyone can participate in the code process 15 Triangle Chapter Meeting October 11, 2017

16 The NCSBC Who writes it: NCDOI Building Code Council Develops amendments to the model codes Ratifies and issues standards as the NCSBC 17 member board appointed by the governor Holds public hearings on code changes Provides vehicles for formal interpretations & appeals 16 Triangle Chapter Meeting October 11, 2017

17 The NCSBC Who interprets it: NCDOI (official interpretive authority) ICC/NFPA (reference interpretations) De Facto Interpreters Local AHJ (County and Municipal Code Enforcement) NC DHSR 17 Triangle Chapter Meeting October 11, 2017

18 The NCSBC Who enforces it: Local AHJs (official enforcement authority) NC DOI (special case authority) High Rise & I-2 over 3-stories or 10K SF Excepting approved jurisdictions (i.e. Wake/Raleigh) NC DHSR (indirect enforcement) 18 Triangle Chapter Meeting October 11, 2017

19 Navigational Aids New Renovation & Construction Local AHJ: NCSBC, NFPA 70 Plan Review, Inspection, Occupancy Approval NCDOI: NSCBC, NFPA 70, 13, 72, et. Al. Interpretation Assistance DHSR Construction Section: Licensure Rules, NFPA 99, 101 Plan Review, Inspection, Healthcare Use Recommendation CMS AO/SA: 2000/2012 NFPA 101 Post-Occupancy Recurring Inspections 19 Triangle Chapter Meeting October 11, 2017

20 Navigational Aids Existing Facilities DHSR Construction Section: Federal Survey Team Recurring & complaint Inspections CMS AO/SA: 2000/2012 NFPA 101 Post-Occupancy Recurring Inspections 20 Triangle Chapter Meeting October 11, 2017

21 Enforce 2000/2012 Edition Enforce 2000/2012 Edition & EC Enforce & Interpret 2000/2012 Edition Recap DHSR Licensure Plan Review & Inspection Enforce & Interpret Current Edition Enforce Indirectly Enforce & Interpret FGI/ASHRAE Guidelines NC State Licensure Rules NC State Building Codes NFPA Codes Code Edition Referenced by NCSBC (1 Cycle Behind Current) Enforce & Interpret Enforce & Interpret Interpret & Enforce NC Department of Insurance (DOI) Local Inspections Departments (AHJ) 21 Triangle Chapter Meeting October 11, 2017 DHSR Federal Life Safety Surveyors CMS Accreditation Organizations (TJC) Federal CMS Inspections Enforce & Interpret*

22 Thank You! Questions? 22 Triangle Chapter Meeting October 11, 2017

23 For Your Reference ICC Code Development Process ICC Becoming a Participant ICC Obtaining Interpretation Assistance ICC Online Codes Available NCDOI Formal Interpretations NCDOI Public Code Hearings NCDOI Online Codes Available 23 Triangle Chapter Meeting October 11, 2017

24 For Your Reference NCDOI Approved Jurisdictions NCDOI Approved 3 rd Party Testing Agencies NCDHSR Plan Review Guidelines NCDHSR Online Hospital Rules NCMCC Rule Review Schedule CMS Online Link to 42 CFR Rules 24 Triangle Chapter Meeting October 11, 2017

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