New Requirements for Water Management Plans for Health Care Facilities

Earlier this summer, on June 2nd, the Centers for Medicare and Medicaid Services (CMMS) released a memorandum detailing new requirements for water management plans for all health care facilities that receive any reimbursement from Medicare or Medicare (which is essentially all hospitals, clinics, and health care facilities). This memorandum references a recent industry standard from the American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) that calls for the development and implementation of water management programs in large or complex building water systems to reduce the risk of legionellosis. In 2016, the Centers for Disease Control and Prevention (CDC) and its partners developed a toolkit to facilitate implementation of this ASHRAE Standard. Environmental, clinical, and epidemiologic considerations for healthcare facilities are described in this toolkit.
Potential impacts to state primacy agencies could be an increased number of new water systems if these facilities decide to install secondary disinfection as part of these water management plans. It’s unclear at this point how many facilities might elect to install additional disinfection. One example is the state of Nevada, where 13 out of the 48 new water systems that were formed between 2012-2015 were several of the large hotels/casinos that installed their own disinfection system to better manage the water quality within their building plumbing.