By Dan Hounsell, Senior Editor

Few aspects of healthcare facilities come under greater scrutiny these days than the Environment of Care as defined and enforced by the Joint Commission. Environment of Care refers to any site where patients are treated, including inpatient and outpatient settings. The main objective of the EOC is to provide a safe, functional and effective environment for patients, staff members and others. But today’s environment of care has shifted its focus in the last two decades. 

“The Joint Commission is moving toward legislation addressing the quality of the Environment of Care and away from building-related issues,” says Douglas King, national healthcare sector lead with Project Management Advisors, adding the shift began around 2000, when the commission realized about 85,000 people had died due to infection-control issues in healthcare facilities while its focus had largely been on issues such as fire safety. 

"They recognized at that time that they were misguided worrying about penetrations emitting a little bit of smoke and things that were relatively rare,” King says. “Staring them straight in the face was a huge, horrific challenge of addressing the quality of the Environment of Care.” 

Spotlighting changes 

The evolution of the Joint Commission’s Environment of Care guidelines showed up most recently in revisions to its guidelines. The Environment of Care is enforced through guidelines in these areas: environmental safety; security; hazardous materials and waste; fire safety, medical equipment; and utility systems. 

The commission in October 2022 issued revisions to the Environment of Care and Life Safety chapters of the Comprehensive Accreditation Manuals for Hospitals and Critical Access Hospitals. The revisions took effect Jan. 1, 2023, and include three changes to Environment of Care elements of performance, two of which are clarifications of current standards. 

King points to two changes that might affect healthcare facilities manager the most. The first change involves interim life safety measures (ILSM), which mitigate potential, unexpected fire and smoke conditions at all times when features of life safety are deficient, compromised or removed from service due to construction, maintenance, breakdown or repair. 

"The first one was they actually took the ILSM and mandated those as a method of communication by the provider,” King says. “When the Joint Commission goes on site and does an inspection, they'll find deficiencies. In the past, you'd write, 'We'll take care of that.' What they do now is they mandate the ILSM features. Are they going to increase fire protection? Are they going to increase the fire watches? Are they going to do further education of the staff in the event of an emergency? 

"That's important because that places the facility in a position of having to do interim measures between the time that it got cited and the time it gets resolved. That's huge. It was something that most responsible facilities probably were doing anyway, but now it documents it and captures the cost to fix that deficiency.” 

The second change involves healthcare facilities that also include non-healthcare spaces.  

"Hospitals have different occupancies," King says. “For example, there's a hospital we did where the first two floors were public spaces. We designated those as business occupancy. The third floor of that hospital had a large conference center-cafeteria. We denoted that floor as assembly. The fourth floor and above were hospital, or institutional. 

“The problem we have had in the past is that areas that are denoted as business occupancy have relatively low requirements from the Joint Commission. Their requirements are low because they assume open healthcare is not taking place in those areas. The problem we had was the Joint Commission inspectors didn't always honor those boundaries. They would say, 'The whole thing is a hospital as far as we’re concerned.' Now the Joint Commission has clarified the requirements and attitude toward non-healthcare areas.” 

The change marks an important shift for the Joint Commission. 

“For the first time, they acknowledge that hospitals aren't always responsible for the business occupancy areas that they're in because they might be leasing that space,” he says. “That's a big deal because it shows that not only are they willing to do that for utilities, but now you could take that argument to other systems and aspects of a design.” 

King says he gives healthcare facilities managers credit for being proactive in some key areas the Joint Commission addressed in the most recent changes. 

"I'm going to guess that most hospital facility managers are incorporating these changes already," King says. “Some of them were minor modifications to language that was misleading. Some of them were things like the ILSM being applied to corrections, which I'm sure other facility managers were doing because they would have defined projects that would have had ILSM requirements. 

“I would give a lot of credit to the facility management community for already undertaking a number of these things. In fact, that's probably why these things got changed.” 

Dan Hounsell is senior editor of the facilities market. He has more than 30 years of experience writing about facilities maintenance, engineering and management.