CMS S&C Memo on Power Strips
by Brad Keyes, CHSP, on May 15, 2020 12:00:00 AM
Q: Our company provides nursing home services. Now that the 2012 LSC has been adopted, does the CMS Survey and Certification Letter 14 - 46 still apply? In reviewing the 2012 LSC, the NFPA 99-2012, and the NFPA 70-2011, I don't see all of the specific requirements called out that are present in the 14 - 46 S & C Letter. Also, for power strips outside of a resident room, does it only need to be UL listed or is there a specific UL listing that is required?
A: Well, yes and no. Since the bulk of S&C memo 14-46 dealt with the categorical waiver process to use NFPA 99-2012 and the 2012 LSC, the answer would be: No, it no longer applies since we are now on the 2012 editions of NFPA 99 and LSC. But the S&C memo also identifies CMS’ interpretation on which UL listed power strip to use in what situation so that part continues to be applicable. CMS took this power strip issue further when the revealed their new K-Tags that applies to the 2012 LSC and the 2012 NFPA 99. Take a look at K-Tag 920 that summarizes the content of the S&C memo 14-46 into a ‘standard’ (i.e. K-Tag) that surveyors can enforce. So, the content of S&C memo 14-46 still applies today through the K-Tag 920. Power strips used in non-patient care rooms must meet ‘other’ UL standards, according to CMS K-Tag 920. Since they do not specify what UL listing they must meet, then the UL listing must be appropriate for its use.