CMS Says It’s Working on Update to Maintenance Memo

The Centers for Medicare & Medicaid Services (CMS) says it is revisiting a memo sent out almost a year ago that reinforced strict limits on the ability of hospitals to deviate from manufacturer recommendations when it comes to equipment maintenance.

In an e-mail to AAMI President Mary Logan, CMS officials said they were “working on an updated memo” in the wake of getting comments from the field and after receiving a sweeping package of information about typical maintenance practices by healthcare technology management (HTM) professionals. The 244-page packet of information was submitted by AAMI and the American Society for Healthcare Engineering (ASHE). The two organizations have played a leading role in trying to find a resolution to an issue that has stirred heated debate within the HTM community.

That debate began when CMS sent a Dec. 2, 2011 memorandum to state survey agency directors that detailed and emphasized limits on what hospitals could do when it comes to the maintenance of medical equipment. The memo specified that hospitals must follow manufacturers’ recommendations when it comes to equipment maintenance “methods.” No alternates would be allowed. Also, the memo said that alternate maintenance “schedules” or frequencies would only be allowed with equipment that was not considered to be “critical to patient health and safety” and only after a “sufficient” maintenance history had been established.

HTM departments across the country objected, saying they had established their own “evidence-based” maintenance practices and routines that were just as safe and cost-effective. They argued that strictly following manufacturer’s recommendations would prove to be time and cost prohibitive, and would not yield any better safety results.

At the request of The Joint Commission, and to help provide information to CMS on the rigorous practices that are used by HTM professionals, AAMI and ASHE officials met with CMS representatives in June. They followed up by submitting the packet of information gathered from HTM departments, which provided great detail on what many have been doing. The packet also answered questions that CMS raised in the meeting about these practices.

For instance, CMS wanted to learn more about common algorithms and methodologies used to determine maintenance methodologies or frequencies; existing guidance in use by the field; examples of evidence-based maintenance and equipment history documentation; estimates of the impact of the CMS letter on the field; and other items.

The packet submitted to CMS—available at—addresses those and other related issues using documentation from hospital systems, published articles, guidance documents, and other resources, to demonstrate that evidence-based maintenance strategies employed in hospitals are safe and effective.

In their e-mail to Logan, CMS officials called that information “most helpful” and were looking anew at the memo. CMS officials provided no details on what an updated memo might look like, nor did they provide a timeline.

“There are a number of models for preventive maintenance that work well,” Logan said. “Some hospitals prefer to use industry service contracts. Some use an independent service organization to provide these services. And others do a fantastic job with their own in-house maintenance and repair services.

“It was clear in the June meeting with CMS that they didn’t realize the depth of the detailed policies and schedules used by the hospital in-house and independent service organization models. It was obvious that CMS is looking for standardization. It’s heartening that they are willing to consider the detailed data provided by the field to re-evaluate what standardization they can accept. “

On a related front, a new committee will meet during AAMI Standards Week to look at medical device maintenance and start the development of a recommended practice. Standards Week runs Dec. 3-7 in Daytona Beach, FL.

Posted: October 26, 2012