Now, perhaps more than ever, the embrace of advocacy

We chatted about advocacy as a specific a while ago (2-plus years, if you're counting, which I tend to do) and I think it's time to take a look at what the good folks at the American Society of Health Care Engineering (ASHE) are doing—and asking you to do. ASHE recently held its 2025 Health Care Facilities Innovation Conference. I am hopeful that advocacy in general was a highlight of the conference for those in attendance. I'm thinking that, given the tenor of the times, as an industry, we are probably going to have to fend for ourselves to a greater extent than in recent memory. Fortunately, the folks at ASHE have come up with a list of concerns/considerations for our attention.

The list has a little bit of something for everyone involved in managing the healthcare physical environment, including:

• Convincing CMS to update its CoP editions. I don't know that there are many folks who feel that the current Conditions of Participation (CoP), which include compliance with the 2012 edition of the Life Safety Code® (LSC), is keeping up with the times and complexities of managing the healthcare environments. You could probably even make the case that we should be considering an LSC edition change that at least mimics the shift from the 2000 to the 2012 (so, hello 2024 LSC!)
• The Joint Commission’s consolidated standards. I guess this one is going to be in the mix for some time to come as the survey process rolls out. The ASHE article highlights the importance of having a good working knowledge of the nuances of the applicable codes—I think you know which ones are in play! As has often been the case, the devil is in the details, and the details can be quite devilish in the hands of a surveyor. We know compliance will start with the standards and performance elements that have been "retired," but where it ends up? I guess we'll find out.
• American Society of Heating, Refrigerating and Air-Conditioning Engineers and ASHE Guideline 43 now available. I was excited about this one; ASHRAE/ASHE Guideline 43 provides operational guidance relative to ventilation in healthcare facilities. I don't know of anyone who hasn't struggled with trying to operationalize compliance as a function of Standard 170, which was ever only intended as a design guide. Guideline 43 will help your work in establishing an operational approach to ventilation that can be sufficiently flexible, practical, sustainable—all those good qualities we want in an operational approach. I'm sure this will become an ongoing topic of conversation as it unfolds in the industry and (of course) the survey process.
• Facility Guidelines Institute (FG) Guidelines scope expansion. One of the time-honored challenges in any of this is trying to "marry" codes, guidelines, regulations, etc., that sometime conflict with each other. And then you have Authorities Having Jurisdictions (AHJ) who work with different versions or different codes all together. It sounds like FGI is doing some work in this regard and will split their guidance into a code that can be enforced by an AHJ and a handbook that will describe methods for compliance, etc. Hopefully this marks a move towards a more common understanding of compliance. 
• Groups pushing for overly “qualified” damper inspections. I suppose there are always going to be instances in which the definitions (or re-definitions) of concepts like "qualified" and/or "competent" can become a revenue-generating opportunity for someone pushing a certification or similar program. As noted previously in this space, self-determination of what makes someone qualified is an important "freedom" that we need to protect to the extent possible. Just as compliance can have many looks, how we achieve compliance is also as varied as our organizations. Cookie cutters may make delicious sweets, but they don't work so well in figuring out how best to operationalize compliance.

Definitely stuff worth checking out—and hopefully a means of furthering the importance of home-grown compliance. We know what works best in our house; as long as we can "frame" that work as a function of compliance, then that should be enough to pass muster during survey—don't you think?

About the Author: Steve MacArthur is a safety consultant with The Chartis Group. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is an advisory board member for Accreditation and Quality Compliance Center. Contact Steve at stevemacsafetyspace@gmail.com.