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CMS Releases Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease

On June 2, 2017 (revised on June 9, 2017 to clarify provider types affected), the Centers for Medicare and Medicaid Services (CMS) released a memorandum to require hospitals, critical access hospitals and long-term care centers to develop and adhere to policies and procedures that inhibit microbial growth in building water systems that reduce the risk of growth and spread of Legionella and other opportunistic pathogens.

Policies, procedures and reports documenting water management implementation results will be reviewed by CMS surveyors to ensure that facilities:

  • Conduct a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g. Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria, and fungi) could grow and spread in the facility water system.
  • Implement a water management program that considers the ASHRAE industry standard and the CDC toolkit, and includes control measures such as physical controls, temperature management, disinfectant level control, visual inspections, and environmental testing for pathogens.
  • Specify testing protocols and acceptable ranges for control measures, and document the results of testing and corrective actions taken when control limits are not maintained.

Healthcare facilities are expected to comply with CMS requirements to protect the health and safety of their patients. Those facilities unable to demonstrate measures to minimize the risk of Legionnaire’s disease are at risk of citation for non-compliance with the CMS Conditions of Participation. Accrediting organizations will be surveying healthcare facilities deemed to participate in Medicare for compliance with the requirements listed in this memorandum and will cite noncompliance accordingly.

Legionella is a pathogenic group of gram negative bacteria that can Legionnaire’s disease and Pontiac Fever (collectively known as Legionellosis). Although ubiquitous in nature, Legionella is commonly found in public water distribution systems, premise plumbing systems, cooling towers, hot and cold water holding tanks, pools/spas, and decorative water fountains. Legionella can be spread to humans through inhalation of aerosolized Legionella contaminated water. It is not spread from person to person. Overall, Legionella exposure is more likely to become serious in elderly people, those with diminished lung capacity, smokers, and people with weakened immune systems.

For more information on Legionella infections, other water borne pathogens and resources for risk assessments, water management plans, preventing, identifying or treating Legionella, please contact us at solutions@cogencyteam.com.

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