CMS Memo Emphasizes Revisions on Portable Generators, Emerging Infections

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By A.J. Plunkett

Review and update your all-hazards risk assessment for emergency preparedness to insure it includes readiness to handle emerging infectious diseases such as Ebola, the Zika Virus or influenza. CMS recently emphasized such infectious outbreaks as a concern in a memo to state surveyors.

The memo also included clarifications on the use of portable emergency generators for alternate power as part of your emergency subsistence plan.

CMS’ Quality, Safety and Oversight (QSO) Group issued the memo, QSO19-06-ALL, “Emergency Preparedness—Updates to Appendix Z of the State Operations Manual (SOM),” on February 1. Appendix  Z is the interpretive guidelines for surveyors of all healthcare types in implementing the emergency preparedness Conditions of Participation (CoP) that took effect in 2017.

Most of the revisions outlined in the updates to Appendix Z focus on emergency power. However, the initial emphasis in the memo introducing the changes is on CMS’ concerns about adding “emerging infectious diseases” to the current definition of the all-hazards approach to planning

“After review, CMS determined it was critical for facilities to include planning for infectious diseases within their emergency preparedness program. In light of events such as the Ebola Virus and Zika, we believe that facilities should consider preparedness and infection prevention within their all-hazards approach, which covers both natural and man-made disasters,” notes the memo.

In the Appendix Z revisions, under Tag E-0004, concerning the requirement for healthcare organizations to use an all-hazards approach, CMS adds emerging infections diseases (EIDs) to examples of hazards it expects facilities to consider, and notes “these EIDs may require modifications to facility protocols to protect the health and safety of patients, such as isolation and personal protective equipment (PPE) measures.”

Permanent generators still required

The remainder of the memo primarily clarifies what it expects if a healthcare organization plans on using portable generators.

It is important to note that that hospitals and any facility that has patients sleeping overnight must still have permanently installed emergency power generators as the first line of defense against an electrical outage, writes David Stymiest, PE, CHFM, CHSP, FASHE, a senior consultant with Smith, Seckman, Reid, Inc., in a recent blog posting on the QSO memo for the compliance consulting firm headquartered in Nashville, Tenn.

The QSO memo states that “facilities should use the most appropriate energy source or electrical system based on their review of their individual facility’s all-hazards risks assessment and as required by existing regulations or state requirements.” CMS also emphasizes that whatever “alternate sources of energy a facility chooses to utilize, it must be in accordance with local and state laws, manufacturer requirements, as well as applicable Life Safety Code (LSC) requirements.”

However, the memo also goes on to state that if necessary to maintain temperatures, emergency lighting, fire detection and extinguishing systems, or sewage and waste disposal, the use of portable and mobile generators is allowed, if the facility has a risk assessment to back that up.

In those instances, while the “LSC provisions such as generator testing, maintenance, etc. outlined under the National Fire Protection Association (NFPA) guidelines requirements would not be applicable, except for NFPA 70 – National Electrical Code,” CMS emphasizes that these revisions to Appendix Z on emergency preparedness “do not take away existing requirements under LSC, physical environment or any other Conditions of Participation that a provider type is subject to (for example to maintain safe and comfortable temperatures).”

Feedback prompts revisions

The revisions and clarifications appear to be a response to questions “from organizations that were making use of portable generators as part of their overall response protocols,” notes Steven MacArthur, a former hospital safety officer and now a senior consultant with The Greeley Company in Danvers, Mass.

Healthcare facilities with buildings that do not need a permanent generator might want to use portable generators to “in order to keep things going. I think the question folks were asking was whether or not they would have to install permanent generators in all these ‘other’ locations,” says MacArthur, “which would result in a fairly significant financial burden – emergency power supply systems are typically very expensive to install.”

“The long and short of this is for folks who use portable/mobile generators, they’re going to have to be able to provide a risk assessment indicating that the arrangement is appropriate,” says MacArthur. “At the end of the day, CMS’s sole concern in all this is the safety of the patients.”

Portable expectations

Among the many revisions, outlined in red in the 56-page memo, were these expectations outlined under Tag E-0015 on the provision of a plan for subsistence for patients and staff, whether there is a plan to evacuate or shelter in place.

The revisions stated, in part, that according to the National Electrical Code outlined in NFPA 70, portable and mobile generators should:

  • Have all wiring to each unit installed in accordance with the requirements of any of the wiring methods in Chapter 3.
  • Be designed and located so as to minimize the hazards that might cause complete failure due to flooding, fires, icing, and vandalism.
  • Be located so that adequate ventilation is provided.
  • Be located or protected so that sparks cannot reach adjacent combustible material.
  • Be operated, tested and maintained in accordance with manufacturer, local and/or State requirements.

The revisions goes on to state that “extension cords or other temporary wiring devices may not be used to connect electrical devices in the facility to a portable and mobile generator due to the potential for shock, fire, and tripping hazards when using such devices.”

“The type of protection needed for the fuel stored by the facility for use by the portable and mobile generator will depend on the amount of fuel stored and the location of the storage, as per the appropriate NFPA standard,” according to the revisions. (For more tips on using portable generators, see p. xyxycmc).

As you review and update your emergency preparedness plans in light of the memo, also note that the CDC issued a special bulletin in early March to highlight the possibility one emerging infectious outbreak overseas could impact the U.S.

“The ongoing outbreak of Ebola virus disease (EVD) in the Democratic Republic of Congo (DRC) serves as a reminder for U.S. healthcare facilities to review their infection prevention and control processes to safely identify and manage patients with communicable infections,” states the bulletin.

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