Finally! The Life Safety Code and CMS

It only took fours years. CMS announced this month that they have fully adopted the 2012 version NFPA 101. This version opens the door to more home-like environments along with some other changes.

We published an article on before the formal announcement that summarized the opportunities and challenges for senior living providers as it relates to the code.


We recently passed the two-year anniversary of the Centers for Medicare & Medicaid Services announcing that they would be adopting the 2012 Life Safety Code. Although they still have not done so, word is that the official adoption rule passed a major regulatory hurdle last week and it is likely to be reality soon. Assuming it was not modified in its review, it would be good to dust off the differences between the 2000 version and 2012.

In this summary I will simplify the impact of each item by noting whether I consider it to be more (M) or less (L) restrictive than the 2000 version. Any Life Safety issue should be evaluated with an architect and/or Life Safety specialist and reviewed in light of your residents and building(s). My shorthand is only an opinion.


CMS has allowed for selectively using parts of the 2012 code by a waiver process. In some ways this makes the formal adoption less significant. But the bigger picture is that the 2012 LSC moves in favor of household, small-house type designs. It's not a great leap to assume that state licensing and regulatory bodies will follow promptly. To the extent that the industry is looking to make skilled nursing and assisted living ever more residential in feel, CMS will be less of a barrier.

Projects in planning that will be permitting and licensed in the second half of this year can likely assume that the 2012 LSC will be the governing code per CMS. Your design and construction team can help investigate whether local bodies are already on 2012 (a 2015 version has been released and CMS skipped the 2009 version). Using the list above in the context of your project will help you understand, if you have a choice which to follow, whether 2012 will be advantageous to you or not.