FGI Bulletin #2

Interpretations on AII Room Door and Functional Program and New Errata

The Facility Guidelines Institute regularly receives inquiries about Guidelines requirements. Recent interpretations and errata will be discussed in each edition of the FGI Bulletin.

Perhaps you’ve discussed whether the requirement to have edge seals on doors to an airborne infection isolation (AII) room means these doors must be equipped with door sweeps. FGI received a question asking if door sweeps are necessary to maintain the negative pressure that is a major characteristic of the AII room. The response was that a sweep is not necessary “if the negative pressure of the room can be maintained at a negative 0.01 inches of water column (negative 2.5 pascals) without a door sweep.” Additional discussion from a health care environment specialist, a facility manager who is a mechanical engineer, an infection preventionist, and a design (mechanical) engineer note that the room envelope is a more significant potential source of leakage from the room. Several ways of maintaining the negative air pressure are described in the interpretation.

Another recent query was, “Is it the intent of the [Guidelines] that an authority having jurisdiction regulate the content of the functional program for a health care project?” The response is “No, that is not the intent.” The primary purpose of a functional program is to communicate the functional planning assumptions and decisions of the owner to the project designers; the functional program is not part of the construction documents and is not a legally binding document. However, AHJs may choose to review the functional program to understand the purpose and goals of a project, and the owner may choose to flag aspects of the project that require review for alternate means of compliance.

An updated errata sheet for the 2014 Hospital/Outpatient Guidelines clarifies the requirements for hand-washing stations in outpatient facilities that serve more than one “patient care station.” The text in Section 3.1-3.6.5.3 is confusing as stated because a patient care station can be a bay, a cubicle, or a room, but the outpatient text already requires a hand-washing station “in each room where hands-on patient care is provided.” Thus, for clarity regarding hand-washing stations in pre- and post-procedure patient care areas that are rooms, Section 3.1-3.6.5.3 should be titled “Additional requirements for hand-washing stations that serve multiple bays or cubicles” rather than “…multiple patient care stations.”

The errata sheets for the 2010 and 2014 Guidelines are posted on the FGI website page for each document. Formal interpretations for the 2001 through the 2014 editions are posted on the interpretations page.

Introducing MADCAD

Beginning with the 2018 edition, the Guidelines for Design and Construction documents will be available for purchase exclusively through FGI’s new provider partner MADCAD (www.madcad.com), an online reference database for codes and standards. The 2018 Guidelines will be offered as a subscription-based service (SaaS), which will provide searchable electronic access to the documents online. FGI will no longer publish an e-book, but softcover paperback versions of the Guidelines will be available for purchase. Through this partnership, FGI hopes to create a better user experience for all Guidelines purchasers and subscribers.

At present, the 2010 and 2014 editions are available through MADCAD for organizations that have a MADCAD subscription and would like to add digital access to the Guidelines to their package. Individual digital copy subscriptions will be available by April 1. View the details here.

New Rules from CMS Prompt Review by FGI Residential Document Group

The chairs of the 2018 FGI Residential Document Group are closely following decisions affecting long-term care facilities made by the Centers for Medicare & Medicaid Services (CMS). On October 4, 2016, CMS published their final rule on the “Reform of Requirements for Long-Term Care Facilities,” CMS-3260-F. This updated rule revises the requirements that long-term care (LTC) facilities must meet to participate in the Medicare and Medicaid reimbursement programs. Phase 1 became effective November 28, 2016. Phases 2 and 3 will become effective in 2017 and 2019, respectively.

A small group, led by architect and senior living design expert Jane Rohde, AIA, FIIDA, ACHA, AAHID, LEED AP, reviewed and analyzed the final CMS rules for their impact on the content of the FGI Residential Guidelines and on LTC owners and operators. Of particular interest are rules made in the areas of quality of care, administration, and physical environment. FGI aims to offer guidance by publishing a position paper on how LTC operators can maintain CMS compliance with the new rules using the Guidelines and existing tools and resources. One rule has prompted an inquiry to CMS for interpretation: “…requiring facilities that are constructed, or newly certified, after the effective date of this regulation to have a bathroom equipped with at least a commode and sink in each room” (CMS §483.90, Page 68690 Federal Register/Vol. 81, No. 192/Tuesday, October 4, 2016/Rules and Regulations).

Knowing that existing LTC facilities have resident rooms in a variety of configurations, FGI seeks dialogue with CMS to ensure Guidelines requirements are aligned with the new rules and FGI is positioned to help LTC owners and operators comply. FGI will be following this issue and working to keep the Guidelines residential requirements current.

Two Residential Facility Types Added to 2018 Guidelines

The FGI Residential Document Group is adding guidance and minimum requirements for two facility types to the 2018 FGI Guidelines for Design and Construction of Residential Health, Care, and Support Facilities.

• Specific Requirements for Settings for Individuals with Intellectual and/or Developmental Disabilities. The goal of this chapter is to provide minimum standards for the development of facilities that support accountability and protection for individuals with intellectual and/or developmental disabilities. The chapter does not include larger residential health settings (nursing homes) or hospitals for residents or patients with intellectual and/or developmental disabilities. Instead, the standards are intended to cover intermediate care facilities, community residences, and personal care homes.
• Specific Requirements for Long-Term Residential Substance Abuse Treatment Facilities. This facility type provides care 24 hours a day, generally in non-clinical/acute care settings. This long-term residential treatment setting provides a therapeutic community for substance abuse disorders, which typically require 18 to 24 months of treatment although patients often receive only three months of treatment because of funding or insurance limitations. The focus of this environment is the resocialization of an individual using a program’s entire community as an active component of treatment.

Both new chapters were vetted through the formal public proposal and comment process and are currently undergoing final development. FGI is pleased to be able to respond to requests for more delineation of facility types with these chapters.

A Peek Inside the 2018 FGI Guidelines: What’s coming on acoustics and noise control?

by David M. Sykes, chair, FGI Acoustics Working Group and Acoustics Proposal Review Committee

Next November, FGI will release the three-volume 2018 edition—with independent volumes for hospitals, outpatient, and residential long-term care and support facilities. In developing these documents, all of FGI’s subgroups faced the same challenges:

1. Adapt and adjust comprehensive criteria for their technical specialty (e.g., acoustics, noise, privacy, and vibration control).
2. Ensure that measurement and mitigation methods are based on accepted standards and supported by third-party evidence.
3. Ensure the criteria are methodologically consistent across all three volumes.

The Acoustics Working Group (AWG), which contributed proposals to the 2010 and 2014 FGI Guidelines, is keenly aware that noise and acoustic conditions have become major concerns in health care facilities over the past decade. This attention has been impelled by national priorities, including HIPAA concerns, the Joint Commission’s National Patient Safety Goal (NPSG) on “alarm fatigue,” the mandatory ACA-HCAHPS patient survey (with its chronically lowest-scoring “night-noise” question), the LEED for Health Care rating system, and myriad technology changes that have yielded a host of new acoustic products and solutions. At the start of the 2018 Guidelines revision cycle, a new subcommittee—the 12-member Acoustics Proposal Review Committee (APRC)—was formed to refine and clarify the acoustic requirements in the Guidelines to better respond to these issues.

Here are some things to look for that have resulted from the AWG’s efforts in the last few years:

1. Regarding hospital criteria: Five AWG members were active on FGI’s behalf in the national task force that addressed “alarm fatigue,” which led to the Joint Commission’s January 2014 NPSG 06.01.01 on alarm safety.
2. Regarding residential criteria: In late 2014, the AWG was asked to undertake a post-publication evaluation of the acoustic criteria in the new Residential Guidelines and to compile new evidence from sponsored research, which led to significant adjustments that will appear in the 2018 residential volume.
3. In late 2015, the APRC was invited to begin work on the forthcoming outpatient volume, a sector in which several group members had been conducting research and developing standards related to HIPAA privacy for many years—expertise they were eager to implement.

These are just a few examples from an intense three-year period of activity that the Acoustics Working Group and Acoustics Proposal Review Committee look forward to seeing in print soon.

FGI on Track at MED|Ed Facilities Conference

FGI will be hosting six education sessions during the fourth annual MED|Ed Facilities conference at the Seaport World Trade Center in Boston, April 4-5, 2017. The two-day show is the premier conference for health care and educational facilities in New England.

The six FGI sessions are being presented by members of the 2018 Health Guidelines Revision Committee and will focus on the 2018 edition of the Guidelines, scheduled for release in November 2017. Topics to be presented are:

• A sneak peek at the 2018 Guidelines for Design and Construction documents
• The new Guidelines document dedicated to outpatient facilities
• Sterile processing department design and HVAC considerations
• Major revisions to requirements for procedure, operating, and imaging rooms
• Noise and acoustics: What’s new?
• Improving safety and security

If you would like to attend, the MED x Ed conference sessions run from 8 a.m. to 5:30 p.m. on  Tuesday, April 4, and Wednesday, April 5, 2017, with a networking reception Tuesday evening.

A 20 percent discount is being offered to FGI Bulletin subscribers with the promo code FGI. Conference registration and complete session descriptions are available at www.mededboston.com. We hope to see you there!

FGI at 2017 Conferences

Members of the Health Guidelines Revision Committee (HGRC) will be speaking at these upcoming conferences:

ASHE PDC Summit, Orlando, Fla., March 12-15

MED|Ed Facilities, Boston, April 4-5

Leading Age Annual Meeting and Expo, New Orleans, October 29-November 1

Healthcare Design Expo and Conference, Orlando, November 11-14

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About the Facility Guidelines Institute
Founded in 1998, the Facility Guidelines Institute is a not-for-profit corporation founded to provide leadership and continuity to the Guidelines revision process. FGI functions as the coordinating entity for development of the Guidelines series of documents using a multidisciplinary, consensus-based process and for provision of ancillary services that encourage and improve their application and use. FGI invests revenue derived from sales of the Guidelines to fund research and the activities of the next revision cycle.

About the FGI Guidelines for Design and Construction Documents
The FGI Guidelines for Design and Construction documents are updated every four years to keep pace with new concepts, capabilities, and technologies in the delivery of health care. The Guidelines documents are used by states to regulate health care facility design and construction, through adoption of the Guidelines as code, as a basis for state-written codes, as an adjunct to state codes, or for reference.

About the Health Guidelines Revision Committee
The Health Guidelines Revision Committee (HGRC) is a select multidisciplinary consensus body of about 100 clinicians, administrators, architects, engineers, and representatives from authorities having jurisdiction that is convened to revise and update the FGI Guidelines documents. As a group, HGRC members are experts on the many issues addressed in the Guidelines.