Attention: Acute Care Hospitals, Critical access Hospitals, ASCs

Please share this announcement with:

  • Facilities managers

The Centers for Medicare & Medicaid Services (CMS) has released a memo stating it will allow a Categorical Waiver to allow Corrugated Medical Tubing (CMT) meeting the copper standard under NFPA 99, 2018 edition, section 5.1.10 for Category 1; 5.2.10 for Category 2; and 5.3.1. for Category 3 piped systems. CMS has determined that corrugated medical tubing (CMT) can be an efficient, safe, and economical means of distribution for Category 1, 2, and 3 systems. While this option was not available under the 2012 edition of NFPA 99 Health Care Facilities Code, CMS is using its authority to allow a Categorical Waiver for its use based on the provisions of the 2018 edition of NFPA 99.

To take advantage of this Categorical Waiver, an organization must take the following actions:

  • The facility must be able to meet all the requirements for CMT under NFPA 99, 2018 edition, and as outlined by CMS in QSO-20-40-LSC.
  • The facility should be able to demonstrate, by location description or plan, where medical gas systems complying with the CMT standard are located, or provide a notation that it applies throughout a facility.
  • The facility must declare the adoption and use of a Categorical Waiver for CMT on an official letter; this letter must reference all pertinent guidance and list the means of complying with all waiver requirements.
  • The facility must declare the adoption and use of a Categorical Waiver for CMT on the Facility Demographic Report (FDR) and make it available for review at all times.
  • The organization shall make a declaration of the adoption and use of a Categorical Waiver for CMT at the opening conference of any survey activity.
  • If an organization is in compliance with all CMS and HFAP requirements for use of this Categorical Waiver, submittal and approval from CMS is not required.  Compliance with CMS and HFAP shall include installation, maintenance, testing, and any required documentation related to the medical gas system.

Additional instructions for utilizing CMS Categorical Waivers will be posted at under Resources/Tools.

Note: This process is similar to the Categorical Waivers CMS allowed under the 2000 edition of NFPA 101, the previous governing Life Safety Code.  Prior to adopting the 2012 edition of NFPA 101, CMS determined some allowances from this edition provided means of compliance that were both safe and beneficial to healthcare organizations, but which the 2000 edition could not provide.

Effective date: September 25, 2020

Read the entire memo here.

If you have any questions, please contact