Given all the steps taken to keep people safe and healthy, healthcare facilities have the most nuanced variables in terms of regulatory compliance. Whether it’s federal, state, or local law, there’s significant overlap that directly impacts signage requirements. From the Americans with Disabilities Act (ADA) and the ICC A117.1 to the NFPA Life Safety Code and alternative local building codes, there are a lot of different rules regarding healthcare regulations, some of which are seemingly contradictory. The biggest question then becomes which signage rules are the most authoritative.
The CMS and the Life Safety Code
The first variable to discuss is the Centers for Medicare and Medicaid Services (CMS), an administrative arm of the Department of Health and Human Services (DHS). CMS cites NFPA 101, the Life Safety Code, as the applicable fire code for healthcare facilities. Due to most healthcare facilities receiving some measure of federal payments under a Medicare structure, the CMS may assign certain mandates, including the NFPA 101. Therefore, federal law is an indirect but important way to regulate nursing home and assisted living facility fire codes.
Just like other areas of the law, however, there are exceptions to the general rule. CMS declares an exemption for comparable state laws by noting: “The Life Safety Code… is not applicable where CMS finds that a state has in effect a fire and safety code imposed by state law that adequately protects patients in healthcare facilities.” The exemption depends on (1) whether codes are in effect in the first place and (2) the adequacy of those state codes. In other words, a jurisdiction must have formally codified relevant fire safety codes and its adoption must meet the presumed minimum standards of the NFPA 101, Life Safety Code.
Beyond the CMS directive, your local jurisdiction will still apply its building code where warranted. Alternating from the fire safety issue, the building code is usually standard for the general built environment, categorizing healthcare-type facilities under Institutional Group I with various subcategories. This means any standards relevant to Group I must be followed and all signage rules apply. Typically, building and fire codes will expressly mandate egress signage for all groups, but there are implied sign standards for these healthcare facilities as well.
How the SfAD and ICC Affect Healthcare Facility Codes
Most specifications within the building codes simply state what a sign means, whether numerically, verbally, or visually, though a few sections of the respective code affirmatively prescribe accessibility compliance. Accessibility standards are found under two different areas of law. First, the 2010 ADA Standards for Accessible Design (SfAD), which govern all public accommodations and commercial facilities. The SfAD will certainly apply to those facilities, namely areas that receive guests or foster guest enjoyment, such as a recreation room or common area. Conversely, areas of your facility restricted to permanent residents will not have to conform to the SfAD. This fact, however, may be difficult to avoid in a practical sense, as many residents host friends and family in their units. Due to these practical concerns, it is prudent to discuss minimum requirements with your jurisdictional authority. The second, and probably the most rigid of the two areas, is the International Code Council (ICC) A117.1. Its rigidity is due to the adoption by reference in nearly every building code around the country. In terms of building codes, however, A117.1 is merely a standard prepared for adoption by any nation around the world. It lacks the regulatory framework built into the SfAD and does not stand as law until a government adopts it formally. This makes it merely a mirror image of the SfAD, since as adopted, A117.1 does not apply strictly to public accommodations and commercial facilities like the SfAD.
As with all conflicts issues, it will all ultimately come down to where federal and state laws contradict each other. Although federal law generally supersedes state law, adequately equivalent state codes may be followed in lieu of federal versions. As always, talk thoroughly with your local inspectors to better understand what your jurisdiction requires, and then make the best choice for your healthcare facility and thus, your patients.
We understand signage codes and guidelines can be confusing, but Healthcaresigns.com does the heavy lifting for you. Every sign we build comes with our Regulatory Compliance Guarantee so you can rest assured your facility is up to code.
Have questions or concerns? — Contact Mike Kelly at mikekelly@healthcaresigns.com for more information.