Installation of Automatic Sprinkler Systems in Nursing Homes

CMS has issued a revised S&C letter outlining potential enforcement actions in the event of non-compliance with the sprinkler requirements that became effective Aug. 13, 2013. In Feb. 2013, CMS proposed a rule that would have allowed it to grant a time-limited extension of sprinkler system installation for a facility that is building a replacement or undergoing major modification. At the present time, that rule has not been promulgated and in the absence of the rule, CMS does not have the authority to grant an extension. As a result, non-compliance with the requirement, at the time of survey, would result in some type of enforcement action. The letter outlines some non-compliant scenarios and offers some possible enforcement actions that would be considered. It delineates steps that a nursing home may implement to reduce the scope and severity of a citation when non-compliance is identified. The S&C letter contains a Q&A document, as well as an attachment noting the number of facilities, by state, that are either non-sprinklered or only partially sprinklered. NYS, according to the CMS document, has the highest number of partially sprinklered buildings with 180 facilities identified.

Contact:  Elliott Frost, efrost@leadingageny.org, 518-867-8832