At Life Safety Enterprises Inc., we believe being prepared can make the difference between life and death.
LSE is dedicated to providing top-rated Consulting, Certification, Inspection and Firestop/Construction programs designed to provide organizations with superior services meeting the most stringent national safety requirements of the NFPA, The Joint Commission, Centers for Medicare & Medicaid(CMS) and Code Officials.
Life Safety Enterprises Inc.
A word of caution...
If you plan to use the 1135 Waiver, make sure you read the Waiver to fully understand what you can/can not do. There is a misconception that since the 1135 waiver exists with CMS, any healthcare facility can use it. However, it doesn't work that way. There are specific guidelines that must be followed.
1. You must submit a request to CMS to adopt the 1135 Waiver. This documentation includes specific criteria that must be included such as why the waiver is needed, the specific requirements to be waived, duration, etc.
2. CMS must approve your use of the 1135 Waiver. This is not a blanket waiver that will include all areas within the waiver. An example is the ITM portion of the Life Safety EOP.
3. If approved, you must update your EOP (Emergency Operations Plan) to address how you are going to adopt the Waiver and how this may change your Policies and Procedures during the emergency.
4. The 1135 Waiver is a federal document, and does not necessarily apply to individual state requirements. Be sure to check with you local AHJ (Authority Having Jurisdiction) for approval on a state level.
We are seeing facilities that are
assuming because the 1135 Waiver is available, they are assuming they can adopt it. Please don't put your staff, patients and/or visitors at risk because you are not following the proper protocol of the 1135 Waiver. Remember - if you do implement the 1135 Waiver, be sure you have documented proof that you have done a Risk Assessment and are implementing proper ILSM's.