The history behind CMS’s high-rise sprinkler rule
When the Centers for Medicare & Medicaid Services adopted new requirements for fire and life safety in 2016, it included a new requirement that all high-rise health care facilities (those over 75 feet) be fully sprinklered.
The rule was part of CMS’s update to the 2012 editions of the National Fire Protection Association’s NFPA 101, Life Safety Code, and NFPA 99, Health Care Facilities Code. In conjunction, CMS provided a 12-year grace period for high-rise health care facilities to comply with the demand for full sprinkler coverage.
The extended compliance window was successfully advocated for by the American Society for Health Care Engineering (ASHE) in 2010, as leaders there recognized early signs that a requirement for fully-sprinklered high-rises was likely on the horizon. Knowing that complying with the rule would involve significant capital and planning for health care facilities, ASHE pushed for the 12-year grace period. Which means CMS’s adoption in 2016 pushed the deadline to comply with the rule to July 5, 2028.
After winning that grace period, ASHE has since been sounding the alarm that all high-rise health care facilities must be fully sprinklered in accordance with the CMS requirement by that deadline.
Although that date to comply is more than two years into the future, it takes a significant lift in time and capital to transition older facilities into being fully sprinklered, which is why ASHE’s Regulatory Affairs Team strongly encourages facilities that haven’t made that transition to start the process today (see related article above).
Background on the CMS rule
CMS adopted the requirement as part of recommendations from the 9-11 Commission Report. The changes were incorporated into the International Fire Code, International Building Code (IBC) and National Fire Protection Association codes that were then adopted by CMS in 2016.
“ASHE successfully advocated for the 12-year grace period on this requirement back in 2010 — without that, full sprinkler compliance would have been enforced over a decade ago,” says Chad Beebe, AIA, CHFM, CFPS, CBO, FASHE, deputy executive director at ASHE. “The change has already been implemented in the IBC with overwhelming support. During the advocacy process, our members provided very limited evidence of hardships or unique circumstances to being able to accomplish this requirement, which contributed to the strong consensus for adoption.”
In fact, requiring all high-rise buildings to be equipped with complete fire suppression systems was one of the recommendations with the strongest backing from the 9-11 Commission Report. Fire suppression systems are critical because they provide occupants valuable time for relocation or evacuation during a fire event.
In health care settings, these systems also enable a defend-in-place strategy, allowing patients to remain safely in their compartments during a fire. However, a key prerequisite for a defend-in-place policy is to have full sprinkler coverage throughout the facility, regardless of whether the building is classified as a high-rise facility or not.
To ensure patient safety and CMS compliance, ASHE recommends that health care organizations that fall into the high-rise category and are not yet fully sprinklered to start the process today.