CMS Issues Facility Requirements to Prevent Legionella Infections

By on 7:49 AM

The Centers for Medicare & Medicaid Services (CMS) has released a memorandum requirement intended to help reduce legionella risk in healthcare facility water systems and prevent cases and outbreaks of Legionnaires' disease.

The requirement is directed at hospitals, critical access hospitals and long-term care facilities. Specifically, CMS expects such Medicare-certified facilities to "develop and adhere to policies and procedures that inhibit microbial growth in building water systems that reduce the risk of growth and spread of legionella and other opportunistic pathogens in water."

Legionella disease, a severe and sometimes fatal pneumonia, occurs when persons inhale aerosolized droplets of water contaminated with the bacterium legionella. A recent review of outbreaks in the United States between 2000-2014 report that 19% of outbreaks were associated with long-term care facilities and 15% with hospitals.

The rate of reported cases of legionellosis, which comprises both Legionnaires' disease and Pontiac fever (a milder, self-limited, influenza-like illness) has increased 286% in the United States during that time period, with approximately 5,000 cases reported to the Centers for Disease Control and Prevention (CDC) in 2014. Approximately 9% of reported legionellosis cases are fatal.

Those at risk include persons who are at least 50 years old, smokers or those with underlying medical conditions such as chronic lung disease or immunosuppression. Outbreaks have been linked to poorly maintained water systems in buildings with large or complex water systems, including hospitals and long-term care facilities. Transmission can occur via aerosols from devices such as showerheads, cooling towers, hot tubs and decorative fountains.

Healthcare facilities identified in the memo should expect surveyors to review policies, procedures and reports documenting water management implementation results to verify that organizations perform the following:
  • Conduct a facility risk assessment to identify where legionella and other opportunistic waterborne pathogens could grow and spread in the facility water system.
  • Implement a water management program that considers the ASHRAE industry standard and the CDC toolkit, and includes control measures such as physical controls, temperature management, disinfectant level control, visual inspections and environmental testing for pathogens.
  • Specify testing protocols and acceptable ranges for control measures.
  • Document the results of testing and corrective actions taken when control limits are not maintained.

Infection Control Consulting Services (ICCS) assists facilities, including hospitals and long-term care facilities, with maintaining CMS and accreditation compliance. To learn more about ICCS survey preparation, plan of correction and other services, contact ICCS today.

Phenelle Segal, RN, CIC, FAPIC

Phenelle Segal, RN, CIC, FAPIC, is the founder and president of Infection Control Consulting Services LLC (ICCS). Phenelle has more than 30 years' experience providing customized comprehensive infection control and prevention services to healthcare facilities nationwide. Her services focus on assisting hospitals, ambulatory surgery centers, dental office and oral surgery practices, doctor's offices, nursing homes and other organizations with implementing and maintaining an infection control program that: complies with The Joint Commission, AAAHC, Centers for Medicaid and Medicare Services (CMS) and other regulatory agencies; respond to situations of noncompliance; and improve the processes for reducing risk.