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Not-So-Micro Impact

A new QSO categorical waiver will allow healthcare facilities to use microgrid systems as a source of backup power.

By Ellie Stimmel

Healthcare facilities are required to have a normal electrical power system and an alternate emergency power source for certain equipment, systems and patient rooms where the loss of normal power is likely to result in injury or death. These facilities are currently operating under the 2012 National Fire Protection Association (NFPA) 99 and 101 codes, which requires a facility’s emergency power to be supplied by a generator or battery system. In order to obtain federal Medicaid and Medicare funds, facilities are required to comply with these codes.

Now, a new Quality, Safety & Oversight (QSO) waiver brought forward by the Centers for Medicare & Medicaid Services (CMS) will allow facilities to elect to use other forms of energy for an essential electrical system (EES). This categorical waiver acts as an addendum to federal law, allowing hospitals and other healthcare facilities to institute microgrid emergency energy systems while remaining in compliance with CMS’ Conditions of Participation (CoP). Facilities can use a healthcare microgrid system (HCMS) with this waiver as long as it is in accordance with the 2021 edition of NFPA 99 and the 2023 edition of NFPA 70. Microgrids allow healthcare facilities to customize their backup power systems to suit their specific needs, ensuring sustainable and reliable power.

HCMSs will be required to be routinely inspected, tested and maintained by qualified individuals, and these records must be maintained for five years. The waiver excludes long-term care facilities that provide life support, which are still required to have an emergency generator without exception under regulation 42 CFR 483.90(c)(2).

What is a Microgrid System?

The QSO statement pulls the definition from NFPA 99 2021 edition, which defines an HCMS as “a system including healthcare microgrid control functions that can manage itself, operate autonomously and connect to and disconnect from the utility for the exchange of power and the supply of ancillary services.” CMS adds that these microgrids can be “provided or supplemented by a combination of clean energy technologies, such as fuel cells, solar panels, wind turbines, energy storage systems and other alternate energy sources.”

This waiver only impacts facilities’ emergency energy sources, but HCMSs could have energy-saving advantages, as facilities could sell excess energy produced by the microgrid to the local power grid, providing an additional source of revenue for the facility.

Microgrid Advocacy

What drove this regulation to be adopted, and how will it impact the healthcare facilities industry?

Members of the American Society for Healthcare Engineering (ASHE), a subsidiary of the American Hospital Association (AHA), have been advocating for this QSO waiver and working alongside CMS to increase flexibility and resiliency in the healthcare facilities industry. This waiver comes alongside efforts to update the federal NFPA 99 and 101 healthcare safety codes to include the same microgrid allowances, which is a multi-year process.

Kara Brooks, ASHE
Kara Brooks, ASHE

“The policy department at the AHA really worked behind the scenes with CMS to help instigate this change,” said Kara Brooks, Senior Associate Director at ASHE.

Natural disasters can cause transportation delays, electrical grid outages and other unexpected events that impact a facility’s EES. Having multiple energy sources can be helpful and ensure that healthcare facilities are prepared in the event of an emergency.

“Healthcare facilities need to be resilient,” Brooks said. This waiver will “definitely increase resiliency and improve healthcare facilities’ ability to be dependent on themselves.”

Multifaceted Impact

Not only will this waiver allow for increased flexibility within the healthcare facilities management industry, but it will also allow facilities to move towards decarbonization and clean energy initiatives.

Joshua Brackett, Banner Health and Legacy FM
Joshua Brackett, Banner Health and Legacy FM

Joshua Brackett, System Regulatory Director, Facilities at Banner Health and Co-Founder at Legacy FM, articulated the impact that this waiver will have on healthcare facilities and their ability to be resilient, provide flexibility and institute sustainability practices.

“In healthcare, we need flexibility, especially if there is an extended power outage,” said Brackett. “This gives us the ability and the option to use clean energy sources.”

But there are some risks, as Brackett pointed out. “For example, when there was the big freeze down in Texas [in 2021], a lot of the wind and solar power generation stopped functioning,” he said. “But there are risks with any technology, and using a microgrid at least allows the opportunity to work toward decarbonization.”

“This is something that has been a thorn in the side of sustainability for a while,” Brooks said. “The life safety codes that have formed the conditions of participation for CMS are outdated, and there has been a push from a lot of different directions [to modernize them].”

A member of the ConnexFM Healthcare Council, Brackett is working alongside other Council members to create and distribute educational resources so healthcare facilities managers can better understand evolving codes and protocols for energy use. Healthcare facilities should consider their capacity for alternate energy sources and future sustainability goals when deciding to utilize the QSO waiver to implement an HCMS.

“[The Council] is getting information out there, like this QSO, and letting healthcare FMs know what they have the ability to do and use now for applicable facilities,” Brackett said.

The QSO declaration allowing the use of microgrids as a source of backup power will have significant impacts on the healthcare facilities industry. HCMSs offer a sustainable, reliable and customizable source of backup power that ensures continuity of care for patients. As healthcare facilities continue to face challenges and uncertainties, the use of microgrids can provide a secure and sustainable solution for the challenges ahead.

The ConnexFM Healthcare Council offers resources for facilities professionals in the healthcare field. To learn more, visit ConnexFM's healthcare resource page.

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