Complying with CMS Risk Management of
Waterborne Opportunistic Pathogens
Hospitals and nursing homes have the inherent potential for housing immunocompromised patients who have an increased susceptibility to many infectious agents, including those bacteria that may be present in potable water. In response to this, the memorandum from the Centers for Medicare and Medicaid Services (CMS) of June 7, 2018 requires that healthcare facilities establish and implement a Water Management Plan (WMP) in accordance with ANSI/ASHRAE 188-2018 that controls the risk for colonization and spread of Legionella, as well as other Waterborne Opportunistic Pathogens.
ANSI/ASHRAE Standard 188-2018 drove the need to perform Legionella testing as validation of an implemented and verified WMP. However, there are additional waterborne pathogens that may be present that also need to be kept under surveillance. In the above-mentioned memorandum CMS listed six additional pathogens to keep watch for in patient populations, especially the immunocompromised. In response, EST developed a new combination Waterborne Pathogen Panel for Pseudomonas aeruginosa, Acinetobacter species, Burkholderia cepacia complex, Stenotrophomonas maltophilia, Nontuberculous Mycobacteria species, and Fungi (Molds and Yeasts). If dictated by the WMP these organisms may also be screened for individually. In addition, EST can perform screens for other pathogens that may be of importance to a facilities’ infection control program, including Elizabethkingia meningoseptica, Ralstonia pickettii, Serratia species, and others.
Because these other CMS pathogens have been overshadowed by the regulatory and legal focus on Legionella, these waterbone pathogens are sometimes referred to as the “Forgotten Six”: