Legionella Update

CMS Requirement to Reduce Legionella Risk

In an effort to keep you informed on the latest developments in the water treatment industry, QualiChem has summarized what you need to know to educate yourself and your customer in regards to the recently released Center for Medicare & Medicaid Services (CMS) memorandum on Legionella Risk in Healthcare Facilities.


On June 2, 2017 the Director for the Center for Medicare & Medicaid Services issued Memorandum S&C 17-30 to State Survey Agency Directors requiring Medicare certified healthcare facilities “to have water management policies and procedures to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems.”

What does this mean for healthcare facilities?

The memorandum applies to Medicare certified healthcare facilities. Specifically, the memorandum calls for the facilities to:

  • Conduct a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens
  • Implement a water management program that considers ASHRAE Standard 188 and the toolkit developed by the CDC for helping develop a water management program
  • Specify testing protocols, acceptable ranges for control measures, and corrective actions when control limits are exceeded

Those facilities that are unable to demonstrate the requirements of the memorandum are “at risk of citation for non-compliance with the CMS Conditions of Participation.”

What does this mean for water treatment companies?

ASHRAE Standard 188 and the CDC toolkit provide guidance on managing building water systems and the minimum components of a water management program for minimizing the growth and spread of Legionella. The responsibility to perform a risk assessment, implement a water management program, and specify testing protocols falls to the healthcare facilities. Healthcare facilities may decide to take on the task of performing the risk assessment and forming a team to develop a water management program. Others will be looking to an external company for these services, possibly contacting their current water treatment provider, whether the provider manages the entire building water system or just the cooling and boiler water systems. It will be up to the individual water treatment company to decide if they have the expertise and are willing to take on the responsibility and liability of either performing the risk assessment and/or contributing to the water management team or program.

Where can I learn more?

There are many publicly available resources available regarding Legionella in building water systems, a few of which are linked below:

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