meeting the cms requirements simply, easily and cheaply patrick lynch global medical imaging...

Meeting the CMS Requirements Simply, Easily and Cheaply

Patrick LynchGlobal Medical Imaging

plynch@gmi3.com

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Who am I?• CBET, CCE, CPHIMS, CHTS-PW, fACCE• 40 years in Biomed• Managed large In-house, ISO and corporate Biomeds• Active in certification of BMETs and CEs• 1st Pres of NCBA (North Carolina branch) - 1980• President, HTMA-SC• Treasurer – HTMA-GA• Member of all Biomed Associations (honorary NC, KY, Utah)• Board Member – META, SC, GA• Advisor – OH, KY, TN, UT, VA, NC, Texas• Writes monthly for TechNation and BI&T (AAMI) - Heineman

Medical Foundation (Guatemala)• Currently, works for GMI is sales development, who

sponsors my activities

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An operating room with at least 10 overhead booms. No cords on the floor.

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A small, but typical OR.

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The Problem

• Extension Cords and Multiple Outlet Strips (Relocatable Power Taps - RPTs)

• Nobody had assigned responsibility for them.• Nobody tests them regularly.• Many low-quality RPTs may compromise the

safety of otherwise safe medical equipment.• Comingling of medical devices and consumer

items may trip breakers, removing power to necessary medical equipment.

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CMS’s reaction• Ban RTPs and extension cords totally.• Well, not really, we were premature in our

total ban.• Here is what you need to do to use them:

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Problems with Outlet Strips• Daisy Chaining• Overloading• Wound or knotted cords• No UL label• Plug is hanging out of the receptacle• Device is HOT to the touch• Melted, frayed, discolored wires• It is used as permanent wiring (over 90 days)• Ground pin missing

Ref – www.nachi.org.power-strips.htm

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• Short Power cords will not reach an available outlet.– Patient areas - little problems, lots of outlets.– Large ORs do not allow power cords from tables to

reach the wall.– If a cord reaches an outlet, it is already used by

other items.• Non-medical devices compete with medical

devices for power.

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• Too few wall outlets exist– The quantity of medical devices has

multiplied since the electrical designs were made for existing building.

– As the uses for medical spaces change, outlets are often in the wrong place, not where needed.

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• Home-made and WalMart outlet strips are often of poor quality.

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The Real Problem

• Sometimes the extension cords are to mate dissimilar plug to one another.

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Worst Case Homemade

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• Everybody overlooks the Outlet Strips and extension cords.– Facilities test the outlet in the wall annually.– Biomed tests the equipment to the end of its

power cord.– Nobody inventories, monitors, tests, or

documents anything regarding RPTs or extension cords.

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• Too many items plugged into a single wall outlet or RPT can trip breakers.– Patients use hair driers, and

other consumer electrical devices.

– These can affect the electrical supply, or increase leakage to important medical equipment.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

CMS is permitting a categorical waiver to allow for the use of power strips in existing and new health care facility patient care areas, if the provider/supplier is in compliance with all applicable 2012 LSC power strip requirements and with all other 2000 LSC electrical system and equipment provisions.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

• Power strips may be used in a patient care vicinity to power rack-, table-, pedestal-, or cart-mounted patient care-related electrical equipment assemblies, provided all of the following conditions are met, as required by section 10.2.3.6:

• 1) The receptacles are permanently attached to the equipment assembly.

• 2) The sum of the ampacity of all appliances connected to the receptacles shall not exceed 75% of the ampacity of the flexible cord supplying the receptacles.

• 3) The ampacity of the flexible cord is suitable in accordance with the current edition of NFPA 70, National Electrical Code.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

• 4) The electrical and mechanical integrity of the assembly is regularly verified and documented through an ongoing maintenance program.

• 5) Means are employed to ensure that additional devices or nonmedical equipment cannot be connected to the multiple outlet extension cord after leakage currents have been verified as safe.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

• Power strips providing power to rack-, table-, pedestal-, or cart-mounted patient care-related electrical equipment assemblies are not required to be an integral part of the manufacturer tested equipment.

• Power strips may be permanently attached to mounted equipment assemblies by personnel who are qualified to ensure compliance with 10.2.3.6.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

• If power strips are used in any manner, precautions as required by the LSC and reference documents are required, including, but not limited to: 1. installing ground fault and over-current protection

devices; 2. preventing cords from becoming tripping hazards;3. connecting devices so that tension is not transmitted to

joints or terminals; 4. no “daisy chaining” power strips” using power strips that

are inadequate for the number and types of devices, and 5. no overloading power strips with high-load devices.

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CMS WaiverRef S&C:14-46-LSC 9-26-2014

• Power strips providing power to patient care-related electrical equipment must be Special-purpose Relocatable Power Taps (SPRPT) as listed in UL 1363A or UL 60601-1.

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Action Plan

• 1. Replace all detachable power cords with 15 to 20 foot long ones.– Buy a bunch of them from a commercial company.– Increase wire size from original gauge to 16 or 14

gauge to reduce voltage drop due to longer length, as needed.

– As you sweep the hospital, remove all RPTs that become unnecessary due to these longer cords.

– Especially focus on Surgery, Critical Care and NICU.This step should eliminate 80% of all RPTs.

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• For items with hard-wired power cords (video carts, OR tables, exam tables, etc.)1. Purchase male and female twist-lock plugs.2. Cut the power cord about 6 inches from the machine.3. Install a male twist-lock to the equipment cord.4. Make a new power cord, 15 to 20 feet long, with a

straight-blade male plug and a female twist lock.Now you have a longer power cord, and have not

had to take the time to actually go inside the unit to make time-consuming changes.

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ORIGINAL CORD

Medical Equipment with standard power cord.

6 or 10 foot cord

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Medical Equipment with modified power cord.

15, 28, 20 or 25 foot cord

Male and female twist-Lock connectors

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Easily purchased from Lowes or Grainger.

Quickly installed without opening the equipment.

Now you have a modified power cord, NOT an extension cord.

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• Where you legitimately

need RPTs:– Purchase Special RPTs from

AIV or Tripp Lite– They meet extra standards

and have long power cords.– Inventory them, – risk-rank them, – put them on your PM

schedule, as per their risk ranking.

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How to comply

• Extra steps required for Special RPTs:– Measure current draw to RPT when all

connected devices are fully operational.• Current may not exceed 80% of capacity.

– Plug all unused outlets to prevent the addition of other equipment which could increase the current draw, or increase leakage current.

– Use child-proof outlet protectors• Tripp Lite makes one that is unremovable

except with a special tool.

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Label all High-Current or Life-Support Device Cords

• Plastic• White on Red• Engraved• approx. 2”x4”• tie-wrapped to cord• near electrical plug.

Important for Ventilators and Anesthesia Machines

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How to test current draw of an SPRPT

1.Must have all equipment plugged in and turned on.2. Use clamp-on ammeter and line cord splitter.

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How to comply

• Collect all unapproved outlet strips and send them to Biomeds Without Borders for distribution to third world countries.

www.BiomedsWithoutBorders.com

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• Long Power Cords, detachable– AIV, 18 or 25 feet long, 16 or 14 gauge

• Twist Lock electrical plugs– Lowes, Hubbell, L5155PZ and L5155CZ

• Clamp-On Ammeter– Lowes, Southwire, 21060T

• AC Line Splitter– Extech 480-172

• Outlet Plugs, unremovable– Tripp Lite, HGOUTLETCVR

• SPRPT – AIV –Powwermate www.aiv-inc.com – Tripp Lite – PS-415-HGULTRA www.tripplite.com

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Pat Lynchplynch@gmi3.com704-941-0116

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