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The CMS Finding says 482.41, A‐710, but what are those notations under K‐Tags?! 
By Marty Piepoli, MSW, LISW/CP, HACP 
For those of us who have been through a CMS Validation Survey, it is long, arduous, frustrating;
add any other adjective of your choice!! When the survey is concluded and the regulatory staff
looks at the 2567 Findings Report, we are faced with the tasks of answering each finding with a
real time Plan of Correction (POC) within 10 calendar days of the formal receipt of the report
from CMS or your State Agency. So the pressure is on. You note a finding under A-710, which
is the Life Safety Code, NFPA-101, 2000 edition, which hospitals receiving Medicare/Medicaid
reimbursement must comply.
Accompanying this finding is reference to a K-tag and a form called a 2786 or 2786U (Fire
Safety Survey Report 2000 Code-Health Care Occupancy or Ambulatory Occupancy). So what
does this mean and how did the surveyors arrive at the findings? The 2786/2786U is the formal
document the CMS surveyor uses to complete his or her assessment of the building(s) that fall
under the healthcare or ambulatory classifications listed on your Facilities’ Life Safety Drawings.
Even though you maintain a Statement of Conditions (SOC), if accredited by The Joint
Commission, the CMS approach will be to look at the accuracy of your drawings, inquire about
the specific construction age of the building(s) and dates for new construction or renovation.
There have been occasions where the CMS surveyor has asked to view the SOC , so be prepared
to discuss these issues related to your plan to resolve deficiencies and any risk assessment done
to provide an ongoing level of fire and life safety during the repair of the deficiency.
So the K-Tags are broken down by New vs. Existing construction and specific components of the
building based on the LSC 101, 2000. The K-Tags are arranged to correspond to the various
chapters of the LSC code within the healthcare or ambulatory occupancy:
• Building Construction Type
• Interior Finish
• Corridor Walls and Doors
• Vertical Openings
• Smoke Compartmentalization & Control
• Hazardous Area
• Exit & Exit Access
• Exits & Egress
• Illumination & Emergency Power
• Emergency Plan & Fire Drills
• Fire Alarm Systems
• Automatic Sprinkler Systems
• Smoking Regulations
• Building Service Equipment
• Furnishings & Decorations
• Laboratories
• Medical Gases & Anesthetizing Areas
• Electrical
The K-Tag documentation concludes with Part IV, which addresses recommendations made for
waiver of specific LSC requirements. This is the area where a specific finding under the LSC, if
applied rigidly, could result in an unreasonable hardship on the facility. These hardships may
mean structural changes to a building or patient care area that can impact patient care delivery or
services provided by the organization in addition to financial impact. LSC waivers are not
routinely granted and the hardship identified must not adversely affect the health and safety of
the patients.
Once the 2786 is completed, it is integrated into the 2567 under the A-Tag 0710 that addresses
the Life Safety Code. Communication with your Facilities/Engineering department will be a
priority as you begin your Plans of Correction, since any of these findings may take an extended
period of time to correct. Hopefully, this review of the K-Tags provides some additional
information on what they mean within the CMS survey process. Included is a link to the actual
2786 form that can be used as a tool for ongoing fire and life safety assessment/rounds of your
facility.
 

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K tags

  • 1. The CMS Finding says 482.41, A‐710, but what are those notations under K‐Tags?!  By Marty Piepoli, MSW, LISW/CP, HACP  For those of us who have been through a CMS Validation Survey, it is long, arduous, frustrating; add any other adjective of your choice!! When the survey is concluded and the regulatory staff looks at the 2567 Findings Report, we are faced with the tasks of answering each finding with a real time Plan of Correction (POC) within 10 calendar days of the formal receipt of the report from CMS or your State Agency. So the pressure is on. You note a finding under A-710, which is the Life Safety Code, NFPA-101, 2000 edition, which hospitals receiving Medicare/Medicaid reimbursement must comply. Accompanying this finding is reference to a K-tag and a form called a 2786 or 2786U (Fire Safety Survey Report 2000 Code-Health Care Occupancy or Ambulatory Occupancy). So what does this mean and how did the surveyors arrive at the findings? The 2786/2786U is the formal document the CMS surveyor uses to complete his or her assessment of the building(s) that fall under the healthcare or ambulatory classifications listed on your Facilities’ Life Safety Drawings. Even though you maintain a Statement of Conditions (SOC), if accredited by The Joint Commission, the CMS approach will be to look at the accuracy of your drawings, inquire about the specific construction age of the building(s) and dates for new construction or renovation. There have been occasions where the CMS surveyor has asked to view the SOC , so be prepared to discuss these issues related to your plan to resolve deficiencies and any risk assessment done to provide an ongoing level of fire and life safety during the repair of the deficiency. So the K-Tags are broken down by New vs. Existing construction and specific components of the building based on the LSC 101, 2000. The K-Tags are arranged to correspond to the various chapters of the LSC code within the healthcare or ambulatory occupancy: • Building Construction Type • Interior Finish • Corridor Walls and Doors • Vertical Openings • Smoke Compartmentalization & Control • Hazardous Area • Exit & Exit Access • Exits & Egress • Illumination & Emergency Power • Emergency Plan & Fire Drills • Fire Alarm Systems • Automatic Sprinkler Systems • Smoking Regulations • Building Service Equipment • Furnishings & Decorations • Laboratories • Medical Gases & Anesthetizing Areas • Electrical
  • 2. The K-Tag documentation concludes with Part IV, which addresses recommendations made for waiver of specific LSC requirements. This is the area where a specific finding under the LSC, if applied rigidly, could result in an unreasonable hardship on the facility. These hardships may mean structural changes to a building or patient care area that can impact patient care delivery or services provided by the organization in addition to financial impact. LSC waivers are not routinely granted and the hardship identified must not adversely affect the health and safety of the patients. Once the 2786 is completed, it is integrated into the 2567 under the A-Tag 0710 that addresses the Life Safety Code. Communication with your Facilities/Engineering department will be a priority as you begin your Plans of Correction, since any of these findings may take an extended period of time to correct. Hopefully, this review of the K-Tags provides some additional information on what they mean within the CMS survey process. Included is a link to the actual 2786 form that can be used as a tool for ongoing fire and life safety assessment/rounds of your facility.