The Centers for Medicare and Medicaid Services (CMS) issued memorandum S&C 17-30-Hospitals/CAHs/NHs “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)”. This policy applies to Medicare-certified Hospitals, Critical Access Hospitals (CAHs), and Long-Term Care (LTC). It establishes a requirement for each facility to conduct a facility risk assessment to identify where Legionella and other opportunistic pathogens could grow and spread in the facility water system. The memorandum also requires that facilities implement a water management program that considers ASHRAE 188-2018; including control measures and environmental testing for pathogens. Facilities should specify testing protocols and acceptable ranges for control measures along with results of testing and corrective actions.
The other opportunistic pathogens specified by CMS include: Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria; and fungi. These pathogens (excluding fungi) are bacteria that can be waterborne. An association with water may be one of the few similarities between these pathogens as their growth factors, survival outside of water, mode of transmission, and type of infection all differ. These differences are important considerations when assessing disease risk in a facility. It is also important to understand that because of these differences the control measures established for Legionella may not be effective for control of these other waterborne pathogens.
The following information provides general information on these other bacterial pathogens and should be used in conjunction with facility specific information from infection prevention to understand if the growth and spread of these organisms is a concern in the facility. Legionella is provided at the top as a reference to understand the differences in environmental sources, infection sites, and modes of transmission between Legionella and these other opportunistic pathogens. Information in the table was adapted from APIC’s Ready Reference for Microbes, 4th edition (Chachere, 2018) and Guidelines for Environmental Infection control in Health-Care Facilities (CDC, 2003) these and other resources on other opportunistic pathogens are provided in the Resource section at the end of this plan.