Life Safety Codes & Electrical Safety: How Fire & Electrical Standards Intersect in Skilled Nursing Facilities
The Life Safety Code (NFPA 101) and the Health Care Facilities Code (NFPA 99) work together to keep residents safe in skilled nursing facilities. NFPA 101 addresses fire prevention and building safety, while NFPA 99 sets requirements for Patient Care-Related Electrical Equipment (PCREE). Facilities that align both reduce survey deficiencies and create a safer care environment.
Why Life Safety and Electrical Safety Go Hand in Hand
In skilled nursing facilities (SNFs), fire and electrical hazards are closely linked. Faulty outlets, damaged cords, and equipment with excessive leakage current can all spark fires — and can also directly harm residents.
Surveyors from CMS often evaluate NFPA 101 (Life Safety Code) and NFPA 99 (Health Care Facilities Code) requirements at the same time because both standards address overlapping risks. Facilities that treat them separately often miss key connections.
NFPA 101: Life Safety Code in SNFs
NFPA 101 covers building design and fire protection standards in healthcare facilities, including:
Fire prevention: reducing ignition sources (electrical safety included).
Fire suppression: sprinklers, extinguishers, and suppression systems.
Egress routes: ensuring safe evacuation paths.
Resident protection: minimizing smoke spread and fire risks.
CMS enforces NFPA 101 as a condition of participation in Medicare and Medicaid programs.
NFPA 99: Health Care Facilities Code (Electrical Safety)
NFPA 99 focuses on minimizing electrical hazards that could harm residents or staff. For PCREE, this includes:
Leakage current testing with strict thresholds.
Ground resistance checks for proper current diversion.
Receptacle testing in patient care areas.
Qualified personnel for inspections and repairs.
NFPA 99 addresses the technical details of electrical safety, while NFPA 101 places them within the bigger picture of facility fire safety.
Where NFPA 101 and NFPA 99 Intersect
Electrical failures are fire risks. Frayed cords and overloaded outlets can start fires, violating both codes.
Receptacle testing matters for both. NFPA 99 requires polarity/ground testing; NFPA 101 requires proof that receptacles are safe as part of fire prevention.
Documentation serves double duty. Logs showing PCREE testing also prove compliance with Life Safety Code inspections.
Surveyors cross-reference standards. CMS inspectors look at NFPA 99 testing to verify that NFPA 101 fire prevention measures are effective.
Case Example: Missed Connection Leads to Citation
A facility tested beds and pumps annually but ignored outlets in patient care areas. During a CMS survey, surveyors cited them under NFPA 99 for skipped receptacle testing and under NFPA 101 because unsafe receptacles posed a fire risk.
Lesson learned: Fire and electrical codes are not separate silos — deficiencies often overlap.
Best Practices for Aligning Life Safety and Electrical Safety
Integrate NFPA 99 into Life Safety Programs
Treat electrical safety as part of your fire prevention plan, not a separate checklist.
Include Outlets and Cords in Fire Safety Rounds
Maintenance staff should check receptacles, power strips, and cords during monthly fire drills.
Document Electrical Testing in Your Life Safety Binder
Keep PCREE logs with fire inspection records for easy survey access.
Train Staff Across Departments
Nurses, maintenance, and compliance officers should all know how electrical hazards tie into fire safety.
Key Takeaways
NFPA 101 (Life Safety Code) and NFPA 99 (Health Care Facilities Code) must work together in SNFs.
Electrical failures = fire hazards = deficiencies under both standards.
Documentation and preventive testing serve as proof for both fire and electrical inspections.
Facilities that integrate PCREE testing into Life Safety programs avoid double citations.
Resources
NFPA 101 Life Safety Code
NFPA 99 Health Care Facilities Code
CMS State Operations Manual
OSHA Healthcare Electrical Safety
Reviewed by the PCREE Test Compliance Team
Last Updated: September 2025