Be prepared — your healthcare facility may have to enact water management policies to reduce Legionella

by Brianna Crandall — July 14, 2017 — To reduce cases of Legionnaires’ disease in health-care facilities, the U.S. Department of Health & Human Services’ (HHS) Centers for Medicare and Medicaid Services (CMS) announced that Medicare-certified healthcare facilities must develop and maintain water management policies and procedures to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems. The directive has an immediate effective date.

Legionnaires’ disease is a serious type of pneumonia caused by bacteria, called Legionella, that live in water. Legionella can make people sick when they inhale contaminated water from building water systems that are not adequately maintained.

The announcement was made in a recent memorandum to State Survey Agency Directors and includes hospitals, critical access hospitals and long-term care facilities.

Notably, CMS called for the utilization and compliance of ASHRAE Standard 188: Legionellosis: Risk Management for Building Water Systems, which was developed to assist designers and building operators in developing a water management plan that includes practices specific to the systems that exist in a particular building, campus or health care facility, noted global building technology society ASHRAE in an announcement about the CMS requirement.

The timing of CMS’ decision is significant as the U.S. Centers for Disease Control and Prevention (CDC) released a report last month (see FMLink article) stating more than 76 percent of Legionnaires’ disease cases acquired from Legionella exposure in health-care facilities can be particularly harsh, including possible fatal risks to patients.

Michael Patton, member of ASHRAE Committee SSPC 188, explained:

Incorporating good design, operations and maintenance procedures that prevent the growth and spread of Legionella is vitally important in all buildings, especially health-care facilities. These are regarded as the best methods for preventing this potentially fatal disease. ASHRAE has been at the forefront of establishing best practices through ASHRAE Standard 188. We are pleased that CMS is taking a strong stance on this issue.

The CMS memo calls on State Survey Agency Directors to conduct a facility risk assessment and implement a water management program that considers ASHRAE Standard 188 and the toolkit developed by the CDC entitled Developing a Water Management Program to Reduce Legionella Growth and Spread in Buildings: A Practical Guide to Implementing Industry Standards. The directive also requires facilities to specify testing protocols.

The CDC toolkit – initially released in 2016 and updated in June 2017 — is based upon ASHRAE Standard 188 and provides a checklist to help building owners and managers identify if a water management program is needed, examples to help identify where Legionella could grow and spread in a building, and ways to reduce risk of contamination.

Patton concluded:

With the release of both the CDC report and CMS memo, it is clear ASHRAE Standard 188 is the best resource available to help health-care facilities implement an effective water management program to Legionella infections.

To date, more than 5,000 copies of ASHRAE Standard 188: Legionellosis: Risk Management for Building Water Systems have been purchased. It can be previewed at no cost on the ASHRAE Web site.