LeadingAge met with officials from the Centers for Medicare & Medicaid Services (CMS) on June 11 for a quarterly meeting to discuss Life Safety Code and Emergency Preparedness requirements. CMS representatives from the Life Safety Code and Division of Nursing Homes participated on the call along with representatives from American Health Care Association and Jensen Hughes, a shared Life Safety Code consultant.

A significant portion of time was spent discussing use of the Fire Safety Evaluation System (FSES) equivalency analyses and processing of waivers. CMS states that there is no timeline requirements for state agencies processing waivers and several factors, including the completeness of information provided for the FSES and other waivers, impacts timely processing. LeadingAge brought up the related issue of timely approval of Plans of Correction and completion of revisits, recently addressed by CMS through a memo to State Survey Agency Directors on June 6, and was able to follow up with CMS after the meeting with specific examples.

The “all hazards” approach was also discussed on the call due to reports from members that states seem to expect assessment of highly improbable hazards, such as planes falling from the sky. CMS noted the distinction between emergency assessments and emergency planning and explained that providers may not plan for all assessed emergencies. CMS recommended reaching out to local emergency management in determining which hazards should be included in assessment and which hazards are assessed at a high enough likelihood that they should be included in the emergency plan. CMS also noted that hazards vary depending on location.

LeadingAge’s next call with CMS Life Safety Code is scheduled for September 2024. Meanwhile, please email any Life Safety Code / Emergency Preparedness questions or concerns to Jodi Eyigor jeyigor@leadingage.org.