By Rick Joslin, Senior Advisor, Healthcare Strategy & Senior Solutions Architect, Healthcare

COVID-19 has drastically expanded the demand for additional hospital beds and the need to separate COVID-19 infected patients from non-infected patients.

Current projections exceed the standard capacity by two to three times. As a result, healthcare organizations are looking to re-purpose other spaces for patient use as quickly as possible. Repurposed spaces, however, must still meet NFPA 101 Occupancy requirements as referenced in CMS Conditions of Participation (CoPs).

Understanding occupancy regulations for healthcare institutions.

Centers for Medicare & Medicaid Services (CMS) is the primary foundation for regulatory compliance and financial reimbursement for healthcare providers in the US. To qualify for reimbursements, healthcare organizations must meet or exceed CoP requirements.

The National Fire Protection Agency (NFPA) has published over 300 codes and standards for buildings in the US. Two major codes affecting the patient care areas are the NFPA 101 Life Safety Code and NFPA 99 Healthcare Facilities Code.

Every space is classified for primary use (occupancy) and the regulations vary from one to another. When using a non-hospital space for patients, the Healthcare Facilities Management (HFM) director must ensure that the features of the space meet requirements for healthcare occupancy (e.g., door opening and corridor widths, swing force, firewall ratings, emergency power supply, and egress requirements, etc). Missing any one of these requirements could cause complications.

Flammable materials storage and their related regulations, such as NFPA 30 (Flammable and Combustible Liquids Code), must also be met. Consider hand sanitizer—this is classified as a combustible liquid, as is alcohol, most disinfectants and the waste materials generated from using them.

Using conference or convention space for healthcare brings other challenges, such as distance to exits, the number of exits, the accessibility of power outlets, use of extension cords, proper emergency power and the placement of fire fighting equipment. Constructing dividers to separate patient spaces will introduce issues that exacerbate the regulatory challenges.

Effective planning for occupancy changes.

On April 3, 2020, CMS issued a set of waivers that may help in determining how spaces can be created or modified and still qualify under their CoPs. However, the language is vague (“certain requirements”), does not contain specifics of what is waived, and all waivers still require meeting state-level regulations found within their emergency preparedness or pandemic plans. Due to the vagueness of the waiver, a comprehensive approach to occupancy changes is needed.

The first step in planning occupancy changes is to connect with state and local Authorities Having Jurisdiction (AHJs) to ensure the new space allocation is allowed and can fulfill its purpose. The earlier they are involved, the more successful the occupancy change will be. When reaching out to them, consider the following:

  • Ask them for input on the requirements you may have missed.
  • Be very clear on where you want to expand, what services are planned to be delivered there and the current occupancy assigned to that space.
  • Make a list of everything you think might be involved in the new space. The more detailed the list, the more insight you get into the regulatory needs. Ask yourself these questions:
    • Will there be just outpatient procedures or overnight stays?
    • Will the patient(s) need medical equipment?
    • Will the staff need to store solvents and cleaners in the space?
    • How will soiled linens and waste be managed?
    • How will the regular and emergency power requirements be met?
    • Does the space provide the necessary line of sight requirements between staff and patients?
    • What type and size of air management systems will I need?
    • What negative pressure spaces (like isolation rooms) will I need?
    • What Portable HEPA filtration systems will I need?
    • What supply and return fans and air exchange rates are needed?
  • Review and implement Interim Life Safety Measures as needed.
  • Identify every requirement you cannot meet, as even one missed regulation could have dire consequences.

To meet the demands of the anticipated patient load, we must adopt new, unconventional use of space. Proper planning and full consideration of regulatory needs will help ensure that the goal is met safely. Failure to do so will put patients and staff at greater risk.

For more information on COVID-19 tools and best practices visit

About the Author

For more than 18 years with Accruent, Rick Joslin has helped healthcare systems navigate the ins-and-outs of managing maintenance activities within their organizations. With over 30 years in maintenance management industry, at levels from technician, to director, to inspector/compliance surveyor, he is known for promoting continuous improvement, driving operational efficiency, increasing resource utilization, and ensuring regulatory success. As the Senior Advisor, Healthcare Strategy and as a Senior Solutions Architect, Healthcare, Rick leverages LEAN thinking and Six Sigma processes to guide our customers in the development of short- and long-term goals for measurable, continuous results across a wide variety of healthcare environments, while also helping them to identify gaps and inefficiencies in business processes and driving operational excellence. His broad knowledge of Healthcare operations and regulatory requirements, coupled with an intimate knowledge of the TMS systems, allow him to assist customers in developing easily-implemented solutions to unique, and changing, business needs.

Using Managed Services, and putting the administrative needs for utilizing Accruent Professional Services personnel on a fast-track, Rick can assist your organization to quickly identify opportunities for operational improvements, automation for repetitive processes, KPI and metrics analysis, and resource utilization enhancements.