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CMS Categorical LSC Waiver Memo for Corrugated Medical Tubing

On September 25, 2020, the Centers for Medicare and Medicaid Services (CMS) published a memo describing instances where Medicare-participating ASCs may use Corrugated Medical Tubing (CMT). Currently, the CMS regulations require compliance with the 2012 NFPA 99 which requires medical gas and vacuum system distribution piping to be rigid copper tubing and does not include provisions for CMT. CMT is flexible copper tubing that is externally coated with a non-metallic fire-retardant sheath. The 2018 NFPA 99 added new provisions that allow for the use of CMT.

CMS has reviewed the provisions in the 2018 NFPA 99 and has determined that a Categorical Waiver can be obtained for facilities that wish to use CMT. Please see the CMS Memo (QSO-20-40-LSC) for the full discussion of this change and the process for obtaining a Categorical Waiver for the use of CMT.

Critical take-aways for the process includes:

  1. The facility must formally elect and document the decision to use a Categorical Waiver for CMT specifically;
  2. If the ASC has elected to use the Categorical Waiver, evidence of this formal decision must be presented at the beginning of any survey;
  3. Documentation of such a decision will not be accepted after a citation has been made; and
  4. The survey team will review the documentation decision to use the categorical waiver and confirm the facility is compliant with all applicable provisions.

For any questions or concerns related to this memo, please contact the CMS LSC Resource Mailbox at QSOG_LifeSafetyCode@cms.hhs.gov.