NFPA 99 vs. CMS: Which Rules Apply to Your Facility’s Electrical Equipment?
Both NFPA 99 (Health Care Facilities Code) and CMS (Centers for Medicare & Medicaid Services) regulate how skilled nursing facilities manage Patient Care-Related Electrical Equipment (PCREE). NFPA 99 provides the technical safety standards, while CMS enforces compliance through surveys and penalties. Facilities must meet both to avoid deficiencies — which means aligning testing, documentation, and risk-based procedures.
Why This Matters
Skilled nursing facilities often struggle with a key compliance question: “Do we follow NFPA 99 or CMS rules?” The truth is that you must comply with both — NFPA 99 sets the technical framework, and CMS enforces it through its survey process.
Surveyors frequently cite facilities not because they ignored CMS, but because they failed to apply NFPA 99 standards in a way CMS inspectors could verify.
What NFPA 99 Requires
The NFPA 99 Health Care Facilities Code is a national standard that focuses on patient safety in healthcare environments. For PCREE, NFPA 99 requires:
Routine testing of all patient care-related equipment.
Leakage current limits (≤100 µA in normal condition, ≤500 µA in single-fault condition).
Ground resistance checks to ensure safe current diversion.
Receptacle testing in patient care areas (polarity, grounding, retention).
Qualified personnel to perform all testing and maintenance.
NFPA 99 is highly technical — it spells out how testing should be done and what the pass/fail thresholds are.
What CMS Requires
The Centers for Medicare & Medicaid Services (CMS) enforces federal compliance through surveys of skilled nursing facilities. CMS requirements are:
Facilities must protect residents from harm, which includes safe electrical equipment.
Surveyors reference NFPA 99 when inspecting facilities for Life Safety Code compliance.
CMS expects documentation of testing, results, and corrective actions.
Deficiencies are issued if facilities cannot prove compliance with standards like NFPA 99.
CMS doesn’t define technical thresholds — it relies on NFPA 99 and other codes. Instead, CMS ensures facilities have an enforceable, documented program.
Key Overlaps Between NFPA 99 and CMS
Electrical safety is mandatory. Both require safe, functional PCREE in resident areas.
Testing frequency matters. NFPA 99 specifies intervals; CMS surveyors check your schedule.
Documentation is critical. Both emphasize keeping records that show compliance.
Qualified staff are required. Testing must be performed by trained personnel.
Key Differences
NFPA 99 (Technical Standard)CMS (Regulatory Enforcement)Defines testing methods & thresholds (leakage current, ground resistance, receptacle tests).Ensures facilities are actually following NFPA 99 through surveys.Focuses on how testing must be performed.Focuses on proving compliance with documentation.Applies nationally as a safety code.Applies specifically to CMS-certified facilities (SNFs, LTCFs).Written for engineers/technicians.Written for surveyors/administrators.
How to Stay Compliant With Both
Adopt NFPA 99 Standards as Policy
Use NFPA 99 testing intervals and thresholds as your baseline.
Document for CMS Surveyors
Maintain logs with date, test type, results, corrective action, and technician’s name.
Store at least 2 years of records electronically.
Train Your Staff
Ensure biomedical engineers, maintenance staff, or third-party vendors know NFPA 99 requirements.
Conduct Internal Audits
Review logs quarterly to make sure nothing is missing before CMS does.
Align Policies With Life Safety Code
CMS enforces the Life Safety Code, which references NFPA 99. Make sure your facility policies tie the two together.
Example: Where Facilities Get Cited
NFPA 99 Violation: A bed fails leakage current testing (>100 µA).
CMS Deficiency: The facility did not have documentation of the failed test or evidence that the bed was removed from service.
In this case, the technical failure was NFPA 99, but the citation came from CMS because documentation was missing.
Key Takeaways
NFPA 99 = the technical rulebook.
CMS = the enforcement agency.
Facilities must meet both by performing tests correctly and proving compliance with thorough documentation.
The safest path is to adopt NFPA 99 standards as your program and document everything for CMS surveyors.
Resources
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