CMS Memo QSO 20-39-NH: Nursing Home Visitation – COVID-19 (Revised 11-12-2021)

CMS has issued updated visitation guidance for visitation in nursing homes. The new guidance includes that visitation is now allowed for all residents at all times. DHSS will be updating its guidance as well and it will be consistent with the CMS guidance. Long-term care facilities certified for Medicare and Medicaid are required to follow the CMS memo. All long-term care communities (SNF, ICF, ALF and RCF) may utilize the CMS guidance until the DHSS guidance is updated.

Please see the full memo at https://www.cms.gov/files/document/qso-20-39-nh-revised.pdf.

General Licensure Requirements – REGULATION UPDATE NOTICE

19 CSR 30-82.010 General Licensure Requirements

The Department of Health and Senior Services, Section for Long-Term Care Regulation has drafted emergency and proposed amendments for regulation set 19 CSR 30-82.010 in order to create a temporary closure procedure for those Medicare and Medicaid federally certified facilities (intermediate care facilities and skilled nursing facilities) licensed in Missouri which experience staffing shortages from the COVID-19 vaccine mandate issued by the United States Department of Health and Human Services, Centers for Medicare and Medicaid Services emergency regulation 42 CFR part 483.

The emergency amendment for 19 CSR 30-82.010 was filed on November 10, 2021, with an effective date of November 29, 2021, and expiration of May 27, 2022. The emergency amendment can currently be viewed at: https://www.sos.mo.gov/CMSImages/AdRules/main/EmergenciesforInternet/19c30-82.010IE.pdf. The proposed amendment covering this same material will also be published in the same issue of the Missouri Register. The Register publication date is December 15, 2021 for the emergency and proposed amendments and can be found at: http://www.sos.mo.gov/adrules/moreg/moreg.asp.

NOTE: The public comment period for the proposed amendment will be from December 15, 2021 – January 14, 2022. The Department will be accepting comments during the comment period by mailing the comments to: Carmen Grover-Slattery, Regulation Unit Manager, Section for Long-Term Care Regulation, Division of Regulation and Licensure, PO Box 570, Jefferson City, MO 65102-0570 or by emailing to: RegulationUnit@health.mo.gov.

The proposed amendment can be reviewed on our website at: https://health.mo.gov/about/proposedrules/.

2021 Annual SLCR Provider Meeting

The 2021 Annual Section for Long-Term Care Regulation Provider Meeting was held virtually on November 10, 2021.

The recorded videos are available at https://missouri.qualtrics.com/jfe/form/SV_ehWffJkM2r7WSHk.

 

Many questions asked during presentation were asked and have been compiled into a document with answers in the attached Provider Meeting Q&A.

In response to some specific questions, please see this medical marijuana presentation that was given by SLCR.

 

Please see the agenda here.

PowerPoint Handouts
1. Welcome & Section Updates
2. Division Introductions
3. Nursing Home Discharges
4. The New CNA Testing Process
5. Immediate Jeopardy and Past Noncompliance
6. Psychosocial Impact
7. Oral Health
8. ICAR Project
9. Life Safety Code Presentation

 

Level of Care Transformation (webinar posted)

Exciting transformation is coming for the Level of Care (LOC) process effective 10/31/2021! Our current LOC Process (many of us have referred to as the DA124 A/B forms) is undergoing major changes!

Here are some of the highlights:

The application process will all be ELECTRONIC. You will fill out and submit forms online on the COMRU website at https://health.mo.gov/seniors/nursinghomes/pasrr.php. For example, the forms will be able to be sent from the hospital to the nursing home to COMRU, all in one system. This electronic link will be available starting October 29, 2021. COMRU will not process these application until November 1, 2021.

The process of evaluating Level of Care will also change. New areas will be evaluated and previous areas will be changed in order to provide the best assessment for determining Level of Care. You can read about the new process in the proposed Regulation at 19 CSR 30-81.030, https://health.mo.gov/about/proposedrules/, which will go into effect on 10/31/2021.

To help facilities prepare for these changes, COMRU hosted a webinar on 10/28/2021. The recorded version of the New LOC Webex Training may be found on the COMRU webpage. A Q & A document from this webinar is also available.

Additionally, COMRU will be hosting a follow-up Webex training for the LOC Transformation. Details below:

November 19, 2021 at 10:00 a.m.

When it’s time, join your Webex meeting here – Join meeting

Join from the meeting link
https://stateofmo.webex.com/stateofmo/j.php?MTID=m0f8dc5933c03862f60654e49cfb9a1dd

Join by meeting number
Meeting number (access code): 2466 296 8040
Meeting password: A2CaeX3FZP9

Join by phone
1-650-479-3207 Call-in toll number (US/Canada)
+1-312-535-8110 United States Toll (Chicago)

Abbott BinaxNOW Expiration Dates

You can access the most information related to Abbott of BinaxNOW tests that have been authorized to have their expiration dates extended by accessing information directly from Abbott’s website.  Use the instructions to see the letter and listing of BinaxNOW™ COVID-19 Ag Card lots which qualify for this expiry extension. Please pay close attention to the lot number, currently labeled kit expiry, and new kit expiry date. The image below helps you to locate the lot number of the Abbott BinaxNOW test kits.

Evaluation and Assessment Measures for Title XIX Recipients and Applicants – REGULATION UPDATE NOTICE

The Department of Health and Senior Services, Section for Long-Term Care Regulation has drafted emergency and proposed amendments regarding adding the level-of-care evaluation and assessment requirements back that were effective prior to October 31, 2021, in order for those individuals who would have qualified for Title XIX funded services prior to October 31, 2021, to be eligible to receive services funded through the American Rescue Plan Act (temporary enhanced federal medical assistance percentage). Therefore, a second level-of-care determination will be utilized from October 29, 2021, until the funding from the American Rescue Plan Act has been expended.

The emergency amendment for 19 CSR 30-81.030 was filed on October 15, 2021, with an effective date of October 29, 2021, and expiration of April 26, 2022. The emergency amendment can currently be viewed at: https://www.sos.mo.gov/adrules/EmergenciesforInternet/emergency. The proposed amendment covering this same material will also be published in the same issue of the Missouri Register. The Register publication date is November 15, 2021 for the emergency and proposed amendments and can be found at: http://www.sos.mo.gov/adrules/moreg/moreg.asp.

NOTE: The public comment period for the proposed amendment will be from November 15, 2021 – December 15, 2021. The Department will be accepting comments during the comment period by mailing the comments to: Carmen Grover-Slattery, Regulation Unit Manager, Section for Long-Term Care Regulation, Division of Regulation and Licensure, PO Box 570, Jefferson City, MO 65102-0570 or by emailing to: RegulationUnit@health.mo.gov.

The proposed amendment can be reviewed on our website at: https://health.mo.gov/about/proposedrules/.

Level of Care Transformation

Exciting transformation is coming for the Level of Care (LOC) process effective 10/31/2021! Our current LOC Process (many of us have referred to as the DA124 A/B forms) is undergoing major changes!

Here are some of the highlights:

The application process will all be ELECTRONIC. You will fill out and submit forms online on the COMRU website at https://health.mo.gov/seniors/nursinghomes/pasrr.php. For example, the forms will be able to be sent from the hospital to the nursing home to COMRU, all in one system. This electronic link will be available starting October 29, 2021. COMRU will not process these application until November 1, 2021.

The process of evaluating Level of Care will also change. New areas will be evaluated and previous areas will be changed in order to provide the best assessment for determining Level of Care. You can read about the new process in the proposed Regulation at 19 CSR 30-81.030, https://health.mo.gov/about/proposedrules/, which will go into effect on 10/31/2021.

To help facilities prepare for these changes, COMRU will be hosting a webinar. Additional trainings to follow.

Thursday, October 28, 2021 at 10:00 a.m.

Join from the meeting link
https://stateofmo.webex.com/stateofmo/j.php?MTID=m37d648b96f1c1d7176099f11c07b6185

Join by meeting number
Meeting number (access code): 2451 311 8637
Meeting password: 3YXgTsdkc37

Tap to join from a mobile device (attendees only)
+1-650-479-3207,,24513118637## Call-in toll number (US/Canada)
+1-312-535-8110,,24513118637## United States Toll (Chicago)

Join by phone
1-650-479-3207 Call-in toll number (US/Canada)
+1-312-535-8110 United States Toll (Chicago)

2021 Annual SLCR Provider Meeting – SAVE the DATE

Sponsored by the Missouri Department of Health and Senior Services, Section for Long-Term Care Regulation in partnership with MU Sinclair School of Nursing, this year’s SLCR Provider Meeting will be held virtually.

Wednesday, November 10, 2021

With the meeting being conducted virtually this year, registration will be required. The link to register along with session information will be coming soon. Please stay tuned to the LTC Information Update for more details.

CNA Testing Update

Beginning 09/01/2021 all full CNA tests are done through Headmaster D & S. Please see the information on Testing Updates In Missouri for clarification on how to proceed with setting up the final examination for students.

For up to date information or any questions, feel free to visit the Health Education Unit webpage or you may call 573-526-5686 or email at cnaregistry@health.mo.gov.

CMS Memo QSO-20-38-NH: Interim Final Rule (IFC), CMS-3401-IFC, Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency related to Long-Term Care (LTC) Facility Testing Requirements

Long-Term Care (LTC) Facility COVID-19 Testing Requirements (QSO 20-38-NH, revised 9/10/2021)

Please read the memo carefully. CMS has revised testing requirements for nursing homes including testing of symptomatic residents and staff, and routine testing of staff. Two major changes are:

  • Facilities now have two options to conduct outbreak testing, through either a contact tracing or broad-based testing approach. See Table 1.
  • Routine staff testing is now based on the facility’s county level of community transmission instead of county test positivity rate. The link to determine county level of community transmission is in the memo. The frequency of testing has also been updated. See Table 2.

 

Table 1: Testing Summary

Testing Trigger

Staff

Residents

Symptomatic individual identified

Staff, vaccinated and unvaccinated, with signs or symptoms must be tested.

Residents, vaccinated and unvaccinated, with signs or symptoms must be tested.

Newly identified COVID- 19 positive staff or resident in a facility that can identify close contacts

Test all staff, vaccinated and   unvaccinated, that had a higher-risk exposure with a COVID-19 positive individual.

Test all residents, vaccinated and unvaccinated, that had close contact with a COVID-19 positive individual.

Newly identified COVID- 19 positive staff or resident in a facility that is unable to identify close contacts

Test all staff, vaccinated and unvaccinated, facility-wide or at a group level if staff are assigned to a specific location where the new case occurred (e.g., unit, floor, or other specific area(s) of the facility).

Test all residents, vaccinated and unvaccinated, facility-wide or at a group level (e.g., unit, floor, or other specific area(s) of the facility).

Routine testing

According to Table 2 below

Not generally recommended

 

Table 2: Routine Testing Intervals by County COVID-19 Level of Community Transmission

Level of COVID-19 Community

Transmission

Minimum Testing Frequency of

Unvaccinated Staff+

Low (blue)

Not recommended

Moderate (yellow)

Once a week*

Substantial (orange)

Twice a week*

High (red)

Twice a week*

+Vaccinated staff do not need to be routinely tested.

 

Please see the full memo for complete details at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/interim-final-rule-ifc-cms-3401-ifc-additional-policy-and-regulatory-revisions-response-covid-19-0.

New Enrichment Booklet for Residents

National Consumer Voice for Quality Long-Term Care has a NEW Enrichment Booklet offers residents a variety of activities to keep them entertained and active. This book includes puzzles, word searches and crosswords; prompts for residents to write about the connections in their lives; trivia questions, which can be done alone or with others; and more!

Download and print the Enrichment Booklet for free or purchase hard copies of the booklet from the online store.

10-Digit Mandatory Dialing Changes

10-Digit Mandatory Dialing Changes Will Impact Fire Alarm Panel Automatic Dialing

The Federal Communications Commission (FCC) has adopted an order approving the designation of “988” as the 3-digit abbreviated dialing code for the National Suicide Prevention Lifeline. As a result of this designation, beginning October 24, 2021, a 10-digit telephone number (area code + phone number) will be required to complete all local calls from area codes 314, 417, 660, and 816. All licensed long-term care facilities in Missouri are required to have a fire alarm panel that dials a monitoring company during a trouble call or fire signal. It is imperative that facility staff verify or reprogram the fire alarm panel to ensure it will dial out with the area code. This will need to be confirmed with the fire alarm and/or monitoring company. For additional information regarding 10-digit mandatory dialing changes, please refer to the FAQs About 10-Digit Dialing document developed by the Missouri Public Service Commission.

Monoclonal Antibody Infusion Medication Information

There has been a significant change in the ordering process for monoclonal antibody infusion medications. If you are currently utilizing these medications, please review the attached notice and plan on attending the webinar tomorrow. Also attached is information on reporting usage through the Teletracking system. Reporting through this system is highly encouraged as the usage reported will determine future amounts allocated to the state.

 Status Update re: Monoclonal Antibody (mAb) Infusion Medication Ordering:

Missouri Department of Health and Senior Services (DHSS) was notified by U. S. Department of Health and Human Services (HHS) yesterday, September 14, 2021, that effective immediately the states are responsible to review and approve all monoclonal antibody medication orders. This includes orders for REGEN-COV (casirivimab and imdevimab) and the Eli Lilly cocktail of bamlanivimab/etesevimab through AmeriSource Bergen. This was DHSS’ first notification of this change. We had no prior information to allow for planning, development of platforms for ordering/approvals or procedures, or messaging. Thus, all of this is occurring currently and as quickly as possible. Information on this change is still forthcoming from HHS, thus we may have process implementation delays at the state level as a result.

mAb Request Process Implementation and Timeline:

DHSS will host a webinar to introduce the state’s new mAb request process, details are below:

Friday, September 17, 2021

10:30-11:30 a.m.

Join from the meeting link

https://stateofmo.webex.com/stateofmo/j.php?MTID=mcb62b527fff05778bd574584e06c8b6d

 

Join by meeting number

Meeting number (access code): 2462 582 1044

Meeting password: pcGjudFE679

 

Tap to join from a mobile device (attendees only)
+1-650-479-3207,,24625821044## Call-in toll number (US/Canada)
+1-312-535-8110,,24625821044## United States Toll (Chicago)

Transfer and Discharge Procedures – REGULATION UPDATE NOTICE

The Department of Health and Senior Services, Section for Long-Term Care Regulation has drafted emergency and proposed amendments affecting the transfer and discharge hearings referenced in regulation set 19 CSR 30-82.050.

The emergency amendment for 19 CSR 30-82.050 was filed on September 1, 2021, with an effective date of September 16, 2021 and expiration of March 14, 2022. The emergency amendment can currently be viewed at https://www.sos.mo.gov/adrules/EmergenciesforInternet/emergency. The proposed amendment covering this same material will also be published in the same issue of the Missouri Register. The Register publication date is October 1, 2021 for the emergency and proposed amendments and can be found at http://www.sos.mo.gov/adrules/moreg/moreg.asp.

NOTE: The public comment period for the proposed amendments will be from October 1, 2021 – October 31, 2021. The Department will be accepting comments during the comment period by mailing the comments to: Carmen Grover-Slattery, Regulation Unit Manager, Section for Long-Term Care Regulation, Division of Regulation and Licensure, PO Box 570, Jefferson City, MO 65102-0570 or by emailing to: RegulationUnit@health.mo.gov.

The proposed amendment can be reviewed on our website at: https://health.mo.gov/about/proposedrules/.

LTC Bed Availability Portal Reminder

Reminder: After submitting the initial survey, a confirmation email will be provided for a link to update your survey each day (instead of submitting a new survey). Submitting a new survey results in multiple surveys showing on the map with different bed numbers. This makes it difficult to know which totals are current. Please use the link emailed after the initial submission to edit facility bed availability. Please do not submit an “initial” submission more than once. If information does not change from day to day, the submitter can simply update the date and submit – the prior day’s information will populate.

The survey information will populate an accompanying dashboard that will be available to hospitals to use as a tool in finding placement for those patients who would be best served in a long-term care setting. This dashboard may be accessed at https://mophep.maps.arcgis.com/apps/opsdashboard/index.html#/f1e0745f93fe46b482d8ff4585f821bf. To view instructions on utilizing the dashboard, click on ‘Instructions’ under the map for information.

DHSS COVID-19 Vaccination Booster Doses Survey

The Department of Health and Senior Services is planning for the upcoming approval of booster COVID-19 vaccination doses and long-term care facilities will be a priority. The federal pharmacy program used to administer first and second doses will not be available, so it is important to ensure long-term care facilities receive the needed support for the administration of booster doses. We are asking for your feedback regarding your facility’s readiness to administer booster doses. https://www.surveymonkey.com/r/VTT296F

For those SNFs (Medicaid/ Medicare certified) that already completed the NHSN survey, we already have your results no further action is needed.

For questions regarding this survey, please contact Lana Hudanick at Lana.hudanick@heatlh.mo.gov or 314-982-8260. Please reply by September 15, 2021.

COVID-19 After Action Report (AAR) Survey – Deadline Extended

The deadline to complete the DHSS COVID-19 After Action Report (AAR) Survey has been extended to Friday, September 3, 2021. Your assistance in helping us gather this important data is greatly appreciated. Please feel free to share the link with your state, regional, and local partners in the following categories:

  • Public Health/LPHA
  • Hospital
  • EMS
  • Emergency Management
  • Behavioral Health
  • Healthcare Coalition Leadership
  • State Agency Partners

https://survey123.arcgis.com/share/d20126ad3a05496d87dbf3b4b65d7592?portalUrl=https://mophep.maps.arcgis.com

Please let us know if you have any questions or difficulties with the survey.
John Whitaker – John.Whitaker@health.mo.gov
Brendan Bagby – Brendan.Bagby@health.mo.gov

Changes to Missouri’s Adult Abuse and Neglect Hotline Hours of Operation

The Department of Health and Senior Services (DHSS) is revising the hours of operation for the Missouri Adult Abuse and Neglect Hotline to 7:00 a.m. to 8:00 p.m., 365 days a year, effective September 1, 2021. The Hotline’s former hours of operation were 7:00 a.m. to midnight, 365 days a year. This change will allow the Department to better serve those who need to report concerns of abuse, neglect, and exploitation of vulnerable individuals 60 and older and people with disabilities between 18 and 59.

During fiscal year 2020, DHSS received and investigated 40,714 community and facility reports of abuse, neglect, bullying, and exploitation, involving seniors and adults with disabilities. That amounts to an average of over 111 reports every day. The number of cases continues to rise, but still vastly understates the extent of the problem as experts believe that for every case of adult abuse or neglect reported, as many as 23 cases go unreported.

In November of 2019, DHSS implemented the Adult Abuse and Neglect Hotline online reporting system allowing concerned citizens and mandated reporters to electronically submit reports of abuse, neglect, and exploitation in an efficient, secure, and confidential manner on a web-based platform. The online reporting portal is available 24 hours a day, 7 days per week and provides an alternative to calling the Adult Abuse and Neglect Hotline both during and outside of normal business hours. Since the implementation of online reporting, approximately one-third of all reports are submitted this way. While online reporting has helped to ease the Adult Abuse and Neglect Hotline’s call volume demands, additional efforts are still needed to ensure that no call goes unanswered. The new operational hours for the Hotline will allow for increased staffing during times of highest call volume. This will help reduce wait times for those reporting and make it easier to reach a trained intake professional between 7:00 a.m. and 8:00 p.m. Please note that 9-1-1 should be accessed for emergencies as the Adult Abuse and Neglect Hotline online reporting system is not intended for emergency response.

If you suspect abuse, neglect or financial exploitation of the elderly or an adult with a disability, you may call the Adult Abuse and Neglect Hotline toll-free at (800) 392-0210 or visit www.health.mo.gov/abuse/ to make a report online.

If you have any questions regarding the change in the hours of operation for the Adult Abuse and Neglect Hotline, please reach out to the Department at 573/526-3625 or DSDSOfficeofConstituentServices@health.mo.gov.

Public Health: Better Health. Better Missouri.

Onsite Clinical and On the Job Training for Students Entering Health Care (Nurses, Nurse Aides, Therapy)

SLCR has received questions regarding whether or not Skilled Nursing Facilities can be a clinical or on the job training sight for students entering health care fields. The quick answer is YES! Long-term care facilities can use the guidance from CMS memo QSO 20-39-NH and DHSS visitation guidance as a way to say “YES” to hosting schools who are training our next workforce in long-term care. Students can be considered health care workers who are not employees of the facility but provide direct care to the facility’s residents. They can be permitted to come into the facility as long as they are not subject to a work exclusion due to an exposure to COVID-19 or showing signs or symptoms of COVID-19 after being screened. Facilities should work with the schools to ensure they are aware of infection control policies and procedures and to whom questions can be addressed.

The most recent visitation guidance from CMS and DHSS can be accessed on our website: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/professionals.php.

For questions related to this, please contact Angela.Duvall@health.mo.gov.

Updated Standing Orders and Affidavits for Third Dose of COVID-19 Vaccine

Following recent announcements from the US Food and Drug Administration and the Centers for Disease Control and Prevention, certain immunocompromised individuals can begin receiving third doses of COVID-19 vaccine in Missouri.

A third dose of the PfizerNBioTech or Moderna vaccines may be administered to moderately to severely immunocompromised people due to a medical condition or combination of immunosuppressive medication or treatments including but not limited to the following:

  • Immunocompromised due to solid organ transplant and taking immune suppressing medications
  • Immunocompromised due to active treatment for solid tumor and hematologic malignancies
  • Immune compromised due to Receipt of CAR-T cell or hematopoietic stem cell transplant (within 2 years of transplantation or taking immunosuppression therapy)
  • Moderate to severe primary immunodeficiency (eg., DiGeorge, Wiskott-Aldrich Syndromes)
  • Immunocompromised due to Advanced or untreated HIV infection
  • Immunocompromised due to “Active treatment with high-dose corticosteroids or other drugs that may suppress immune response: high dose corticosteroids (ie.,≥ 20 mg prednisone or equivalent per day), alkylating agents, antimetabolites, transplant-related immunosuppressive drugs, cancer chemotherapeutic agents classified as severely immunosuppressive, tumor-necrosis (TNF) blocker or other biologic agents that are immunosuppressive or immunomodulatory”

Individuals who do not meet the criteria for “moderately to severely immunocompromised” do not need a third dose at this time.

In line with federal guidelines, Missouri will use a self-attestation model for people who are moderately to severely immunocompromised. Individuals will not be required to provide documentation of their health status, and they can get third doses at all venues where first and second doses are available.

This guidance does not apply to those who received the Janssen/Johnson & Johnson vaccine. For people who received either Pfizer-BioNTech or Moderna’s COVID-19 vaccine series, a third dose of the same mRNA vaccine should be used. A person should not receive more than three mRNA vaccine doses at this time. If the mRNA vaccine product given for the first two doses is not available or is unknown, either mRNA COVID-19 vaccine product may be administered. Individuals should wait at least 28 days between their second and third doses.

Announcements from federal health officials came after the analysis of studies demonstrating that immunosuppressed people are more likely to get severely ill from COVID-19, are at higher risk for prolonged infection, are more likely to transmit the virus, and experience lower vaccine effectiveness.

Additional information regarding this guidance can be found on the CDC website at https://www.cdc.gov/coronavirus/2019-ncov/vaccines/recommendations/immuno.html.

Interim clinical considerations for use of COVID-19 vaccines can be found at https://www.cdc.gov/vaccines/covid-19/clinical-considerations/covid-19-vaccines-us.html.

Missouri’s revised standing orders can be found at https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/statewide-orders.php.

DHSS COVID After Action Report Survey

Below is a link to the Missouri Department of Health and Senior Services COVID-19 after action survey. This survey is designed to gather feedback from a variety of healthcare and public health partners and organizations. Please respond by selecting the discipline that reflects your organization and submit one survey per organization, excluding state agency partners. Your responses to this survey should be based on your organizations role and perspective of the COVID response. Receiving input from a variety of stakeholders, at all levels of the response, will help us better identify our strengths and weakness of the public health and medical services emergency Support function.

https://survey123.arcgis.com/share/d20126ad3a05496d87dbf3b4b65d7592?portalUrl=https://mophep.maps.arcgis.com

Please see this FAQs for more information. Thank you in advance for your participation!

Smoke Zones vs. Fire Zones

 

We have recently noticed several facilities that have used their fire alarm zones as part of their evacuation plan. The fire alarm zones are the zones on the fire alarm panel used to help staff identify the location of the fire. These are different from smoke zones, which are the zones in the building created to prevent the spread of smoke and fire and allow staff time to complete a full evacuation of the building. Many facilities have fire alarm zones that do not match the smoke zones in the facility. Often times there are more fire zones to help staff identify the location of a fire.

To start a smoke zone evacuation, it may be necessary to evacuate multiple fire alarm zones at the same time. The evacuation plans need to have these smoke zones clearly labeled and all staff need to know where they will move the residents in the event of a fire. The facility cannot base their evacuation plans on the fire alarm zones.

In this example, the facility has eight fire alarm zones (Fire Zones 1-8). The facility has a smoke barrier wall that divides the facility into two smoke zones (Smoke Zones A and B). The facility also has a secured unit, but the controlled egress doors (locked keypad doors) are not a part of the smoke barrier wall, so the secured unit is part of Smoke Zone A.

If a fire occurs in Fire Zone 4, it means that an evacuation of all residents would need to occur throughout Smoke Zone B, which would include all residents in Fire Zones 3, 4, and 5. The evacuation plan may mention things like room number, dining rooms, etc., but should avoid using fire zones to describe the smoke zones. Although it is important to know which smoke zone activated the fire alarm system, staff cannot move the residents from Fire Zone 4 to Fire Zone 5, as they are still within Smoke Zone B. Staff must completely move the residents out of Smoke Zone B.

In addition, it is significant to note if a fire occurred in Smoke Zone A (i.e. Fire Zones 1 or 6), the staff would need to move residents in the secured unit from Smoke Zone A. Staff cannot leave the residents in the secured unit since a smoke barrier wall does not protect the secured unit and it is not its own smoke zone.

The facility must have the evacuation plans posted on at least every floor of the facility [19 CSR 30-85.022 (33)(B)(2)] which directs all staff, residents, and visitors where to go in the event of a facility evacuation. The policy and procedure for evacuations also needs to be in the emergency preparedness manual.

NFPA 99, 2012 edition
15.7.4.3.1: Where buildings are required to be subdivided into smoke compartments, fire alarm notification zones shall coincide with one or more smoke compartment boundaries or shall be in accordance with the facility fire plan.