Remote Power Tap (RPT) Part 2

I wrote about RPTs back in April of 2021, after our last Joint Commission (JC) inspection.  That blog is available on MedWrench in case you are interested in reading it.  In summary, CMS sent a letter in September of 2014, Subject: Categorical Waiver for Power Strips Use in Patient Care Areas that stipulated requirements regarding the use of RPTs.  One of the requirements is, “The RPT must be permanently attached to the equipment assembly.”  

Fast forward to November 2022, when our facility went through a mock-survey in preparation for our next inspection.  The mock-inspectors cited three different issues regarding the use of RPTs.  One of them was legitimate as the users had a table (not part of the assembly) plugged into an RPT that was attached to an IV pole.  I would like to share the other two findings with you.  

Case 1 - In OR 4, there was a SPRPT that was permanently attached to an IV pole, however, it was not serving any equipment.

Certainly, this must be an oversight by the inspector.  Not taking any chances I posed this situation to the JC: 

Me - “During a recent mock survey, we were cited for having an RPT permanently attached to an IV pole, however there wasn't an IV pump attached to that particular IV pole at that time. Can an RPT be attached to an IV pole without an IV pump attached to it?”

JC - Per NFPA 101-2012 10.2.3.6 RPTs must be permanently attached to a movable piece of equipment, along with any equipment that is plugged into it, so that it is an assembly. If an IV pole is being used as the piece of movable equipment, any item that is connected to the RPT that is permanently mounted to this IV pole must also be mounted to the IV pole. If for example, an IV pump was plugged in, then the IV pump would have to be attached to the IV pole. These RPT assemblies must then be maintained as such.  

(This raised another question as IV pumps cannot be permanently attached to the IV pole.  They must be removed from the IV pole when the patient is transferred to the gurney for transport in order to continue IV therapy.  Cleaning is another reason why permanently attaching would not be reasonable. For the record, the NFPA does not state, “along with any equipment that is plugged into it, so that it is an assembly.”) 

Me - NFPA 99-2012 10.2.3.6 states that the "The receptacles are permanently attached to the equipment assembly".  It does not state that the equipment must be permanently attached to the cart, rack table, or pedestal.  IV pumps attached to IV poles are regularly removed for cleaning. Accordingly, there will be times when an IV pole, with a permanently mounted RPT, may not have an IV pump attached to it.

JC - The reference in NFPA 99-2012 10.2.3.6 refers to an assembly, and in order to control the modes of utilizing a relocatable power tap (RPT), both the receptables and the equipment must be attached to the movable item that is being used, so that control over what equipment connected to this RPT assembly can be managed. Since the qualified personnel assembling this assembly must take into account the ampacity of connected equipment, there must be a means to control how equipment is being added and removed to these RPT assemblies.  It is understood that equipment will be removed for cleaning and movement of these assemblies, and this process should be managed by your organization. When these assemblies are modified after cases or use, they should be removed from the patient vicinity until reassembled by qualified personnel.

Case 2 - Code cart 52 was attached to an RPT that was not permanently mounted to the code cart.

This particular code cart was not in the “Patient care room” or the “Patient care vicinity”.  However, the defibrillator and the aspirator were connected to an RPT.  I posed the question to the JC and here are the details of our communication.

Me - “A crash cart, not located within the "patient care vicinity" or the "patient care room", had the defib and the aspirator connected to an RPT that was not attached to the crash cart. Is this practice prohibited?”

JC - “If an RPT is being used on the crash cart to power this medical equipment, the RPT would have to be mounted to the crash cart to meet the RPT requirements of NFPA 99-2012 10.2.3.6. If the RPT was not mounted to the crash cart, it would be considered an extension cord, which is not allowed in healthcare, and these medical devices would need to be plugged into a fixed electrical receptacle.”

Me - “My question specified that the crash cart was outside of the patient care vicinity and patient care room. In the answer I was given, it stated that if the RPT was not permanently attached to the crash cart, it would be considered an extension cord. The person cited NFPA 2012 10.2.3.6.  After reviewing CMS's letter, Categorical Waiver for Power Strips Use in Patient Care Areas, Ref: S&C: 14-46-LSC. It states on page 4: "Power strips may be used outside of the patient care vicinity for both patient care-related electrical equipment & non-patient-care-related electrical equipment."  

JC - Crash carts have medical equipment on them, and while they are stored in the corridor, when needed they are brought into the patient care vicinity, and therefore need to meet the requirements of NFPA 99-2012 10.2.3.6.

There you have it, our mock survey findings and the thoughts from the JC.  Prior to our mock survey, I believed our RPT program was correctly aligned with CMS’s requirements, NFPA99 and the JC.  We are not in our inspection window yet, but in the meantime I am continuing my efforts to ensure that we are meeting the standards.  

Let me know your thoughts, processes, or JC findings regarding RPTs at: grits.citrus_0a@ilcoud.com.