CMS Proposes 4-Hr Generator Test Every 12 Months for Health Care Facilities

The Department of Health and Human Services has published a 120-page proposed rule dated Dec. 27, 2013 (Vol. 78, No. 249). Within the proposed rule on pages 79173-4 at Section 482.15(e) “Generator Testing,” the Center for Medicare and Medicaid Services (CMS) has proposed a 4-hr generator test be performed EVERY 12 months. There is no mention of a minimum percentage of nameplate rating, minimum exhaust temperature, or a requirement that all automated transfer switches be transferred during the test.

Not only does the proposed rule apply to 4,982 hospitals across the country, but it also applies to 15,157 long-term care (LTC) and 1,322 critical access hospital (CAH) facilities. But the cited economic impact is flawed in each case.

  1. In each case, 72 gal per hr, per facility is used for assumed fuel consumption. This equates to an approximate 960kW generator load per facility.
  2. Six man-hours are used for the amount of time it would take to conduct the annual test (supporting clinical and facility staff time not included).
  3. The figures used for economic impact, not including the "Information Collection Requirements (ICR) burden," are underestimated by 45% even using CMS figures. Math error.

The proposed rule flies in the face of established NFPA 99 and 110 standards for triennial tests, as well as those published by accreditation organizations. The triennial 4-hour test has been tried and proven; plus, there has been no empirical evidence that more frequent tests are necessary.

MGI maintains this is total overkill without basis, and the interpolated $68,000,000 annual expenditure, not counting the “ICR burden,” could be used for loftier purposes…like breaking even at year-end.

The comment period ends at 5 p.m. on Feb. 25, 2014. There are four ways to submit your opinions (see page 79082). Download a copy of the proposed rule or access the forms directly to submit a comment.

It might sound odd, but I have advocated that an annual 24-hr generator test could uncover issues that would not have been discovered in a monthly 30-min. test. My background of more than 40 years testing and maintaining 10,000+ generators and EPSSs in health care facilities and data centers have made me a believer that a “well-tested EPSS is a healthy EPSS.” The question becomes, “what is the minimum time — and frequency — an EPSS should be exercised to guarantee reliability?” I submit that the answer is not universal and that different combinations of EPSS components dictate the protocol — one size does not fit all.

The members of the NFPA 110 Technical Committee spent several hours interviewing service companies and manufacturers before crafting the triennial test of 4 hr at 30% of nameplate rating, and transferring of all automatic transfer switches (ATSs). I think the CMS should accept the fact, notwithstanding any empirical evidence to the contrary, that these figures are sufficient. I sincerely believe the CMS didn’t interview the proper individuals before drafting their proposal.

If a facility has been performing annual tests for extended periods, then the proposed rule shouldn’t have any effect on them.

To measure the economic impact on individual budgets, you only have to multiple the measured kW load of each generator x .075 x the cost of a gallon of diesel x 4 hr. Add to that your estimated labor costs, and then multiple both totals by two additional years.

In Houston — and other areas — there are environmental issues, plus heavy fines, to consider. Demand response (DR) events and running EPSSs during emergencies should be taken into consideration in any final rule.

The CMS needs input from the “governed” and the manufacturers.

Chisholm, president of MGI Consulting, Orlando, Fla., has provided emergency power supply systems (EPSS) consulting services and education to more than 1,500 health care facilities. He serves as a member of the National Fire Protection Association's Technical Committee responsible for NFPA 110, Emergency and Standby Power Systems and the Electrical Section of NFPA 99, Health Care Facilities. He also serves as a primary emergency power consultant to the U.S. Army Medical Department (AMEDD) and the Department of Defense.

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