Notice: Requirement to Reduce Legionella Risk in Healthcare Facility Water SystemsIn early June 2017, the Department of Health & Human Services, Centers for Medicare & Medicaid Services (CMS) released a memo which gave a summary of the state of Legionella and how it is affecting health-care facilities.

Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)

Some of the data pulled from the report includes:

  • In the United States from 2000-2014, 19% of outbreaks were associated with hospitals and long-term care facilities.
  • The rate of Legionella related infections (legionellosis and Pontiac Fever), has increased 286% in the US during 2000-2014.
  • Approximately 5000 cases were reported to the Center for Disease Control (CDC) in 2014.
  • Approximately 9% of legionellosis cases are fatal.

The report states that the CMS knows the threat of Legionella and the recent outbreaks.

Legionella can be found in common areas that have a water reservoir and interaction between humans and water, such as showers, cooling towers, hot tubs, and decorative fountains. Places where the water is aerated and is present in small particles in the air. Less common, Legionella spread by aspiration of drinking water or ice, and only one case of person-to-person transmission has been reported.

The populations most at risk are, those who are at least 50 years of age, smokers, and those with underlying medical conditions such as chronic lung disease or immunosuppression. Due to Legionellas tendency to grow in areas of building water systems that are continually wet, and can spread contaminated water through usage of certain devices that aerate the water upon usage. It stresses the importance of regular testing and strict adherence to regulations pertaining to Legionella. Some of the common areas and devices that the bacteria can be present are: 

  • Hot and cold water storage tanks
  • Water heaters
  • Water-hammer arrestors
  • Pipes, valves, and fittings
  • Expansion tanks
  • Water filters
  • Electronic and manual faucets
  • Aerators
  • Faucet flow restrictors
  • Showerheads and hoses
  • Centrally-installed misters, atomizers, air washers, and humidifiers
  • Nonsteam aerosol-generating humidifiers
  • Eyewash stations
  • Ice machines
  • Hot tubs/saunas
  • Decorative fountains
  • Cooling towers
  • Medical devices (such as CPAP machines, hydrotherapy equipment, bronchoscopes, heater-cooler units)

CMS set forth a set of regulations and expectations for their Healthcare facilities and Surveyors.

In order to mitigate and minimize the risk of Legionella they are being asked to abide by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE), 2015 published  “industry standard” calling for the development and implementation of water management programs in large or complex building water systems to reduce the risk of legionellosis. In 2016 the CDC and its partners developed a toolkit to facilitate this industry standard.

The surveyors through an understanding of what procedures and policies must be met, are to work with the healthcare facility ensuring that their facility has: 

  • Conducted a facility risk assessment of the water system.
  • Implement a water management program that considers the ASHRAE industry standard and CDC toolkit, and includes control measures, such as testing, visual inspection and disinfectant level control.
  • Specify testing protocols and acceptable parameters, and document the results of testing and corrective actions taken when control limits are not maintained.

Healthcare facilities must meet the CMS requirements or are at risk of citation for non-compliance with the CMS Conditions of Participation.

This memorandum was published on June 02, 2017 and was revised on June 09, 2017. The revision was to clarify the provider types affected.

Update: This policy memorandum applies to Hospitals, Critical Access Hospitals (CAHs) and Long-Term Care (LTC). However, this policy memorandum is also intended to provide general awareness for all healthcare organizations.

Effective Date: Immediately. This guidance should be communicated with all survey and certification staff, their managers and the State/Regional Office training coordinators within 30 days of this memorandum.

We have much more information about Legionella and Legionnaires disease check out more information here and to learn more about water testing and analysis you can find more information here.

If you have questions or concerns on how this memorandum affects your business or healthcare facility you can call us at (877) 648-9150 or contact us here and we can help you learn more about Legionella testing and how you can take measures to ensure that you comply with these regulations.