# Proper Occupancy Classification / B / I-2 (?)



## Big Mac (Feb 4, 2010)

Three-story 88,000 square foot medical building. Medical Offices open 24-hr a day and an emergency room that by the tenants statement is expected to serve approximately 35,000 patients a year.  The emergency deapartment has 18 patient rooms.  By the way, the emergency department encompasses the entire first floor of the structure.  The two upper floors are "normal" medical care offices.

The language in the Commentary to the Building Code is “An occupancy classified in Group I-2 is characterized by four conditions.  It is a health care facility (yes), the occupant load is greater than 5 (yes), there is 24-hour a day medical supervision (yes), and there are some occupants who are incapable of self preservation (i.e. some or all of the occupants require physical assistance by staff to reach safety in an emergency situation) (yes).  If folks are being treated in an emergency room, they already have issues with self preservation and if they are undergoing surgery they are also very likely to be incapable of self preservation."


----------



## Coug Dad (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Under IBC, if more than 5 patients do not sleep there (24 hour care) it is not an I-2 occupancy.  The 24 hour issue is patient sleeping, not hours of operation.

The rules under NFPA 101 are different and NFPA 101 would apply if they want Medicare / Medicaid reimbursements under CMS.


----------



## JBI (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Is there a question in there somewhere? Sounds like you made the right call....


----------



## Gene Boecker (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

I've never heard of medical offices being open 24 hours a day.  Usually medical offices are open during "business hours" only.  It doesn't sound like a medical office building but more or an urgent care or emergency care facility.    If it's solely to treat then transport, it's not.  I'd have to argue a Business occupancy.  If the patients can be moved then to more permanent rooms within the facility, it's an I-2.

Regardless, if there is a portion of the building that is used for offices with access 24/7 but no people there except during business hours, that woudl be a business designation.  It's up to the designer how to address the two distinct occupancies.


----------



## Big Mac (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Coug Dad, how did you arrive at the conclusion that the 24-hr period is for the same patient.  I'm pretty sure that isn't written anywhere.  I pretty sure it just says 24-hour a day medical supervision.  I don't see anywhere that would indicate it has to be 24-hour care for the same patient.  Would your opinion be changed if they made the statement that they will only keep patients there for 23:59 minutes?  Do you really think the code is that concerned with a 1-minute differential?


----------



## Big Mac (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Gene, I don't believe the entire facility will be open on a 24-hr basis just the first floor that houses the emergency department.  As alluded to in the last post, they have made the statement that they will only house patients for up to 23:59 hours.  Sounds like they have discovered the proper terminology to use to avoid "buzz" words.


----------



## Gene Boecker (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Then it's a "B" - treat & transport!

There are additional NFPA requirements that will kick in to address the additional safety needs assuming they get licenses for the facility.


----------



## Coug Dad (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

The simple answer is yes.  Heathcare (Group I-2) under the IBC is more than 5 patients who receive care on a 24 hour basis.  The real issues tie back to their classification under the rules established by CMS.  These are not building code issues per se, but have a direct correlation.  If a facility is CMS classified as a doctor's office, then it is an IBC Group B occupancy.  If it is CMS classified as Ambulatory Care (an NFPA 101  term, not IBC) then it would also be IBC Group B.  If it is CMS classified as Healthcare (again, NFPA definition) it would probably be IBC Group I-2 although a health care provider always has the option of meeting the higher CMS rules for greater reimbursements.  For example, a doctors office or clinic that complies with the CMS healthcare rules can apply for reimbursement as a healthcare facility.  The IBC would still look at it as a Group B occupancy.  Ask the owner and DP what CMS level they are desining for and that will help with the IBC occupancy classification.


----------



## Big Mac (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Coug Dad - I certainly wouldn't dispute that the facilties you describe would be I-2 occupancies.  However, I still see nothing definative that would indicate the the 24-hour care would be required to be continuous care for the same person.  The statement is costodial care on a 24-hour basis.  If the emergency room is open for 24-hours a day, seven days a week, they are certainly providing custodial care on a 24-hour basis, just not necessarily for the same individuals.  In addition, I am curious, is it possible that I am the only one that questions whether they will put the patient on the sidewalk outside to avoid having them there longer than 23 hours and 59 minutes?


----------



## Coug Dad (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

custodial care

[k?st??d?·?l]

Etymology: L, custodia, guarding, garrire, to chatter

services and care of a nonmedical nature provided on a long-term basis, usually for convalescent and chronically ill individuals. Kinds of custodial care include board, personal assistance, and room.

Mosby's Medical Dictionary, 8th edition. © 2009, Elsevier.

Follow the money.  How are they being paid?  As a doctor's office, ambulatory care facility or healthcare (hospital).  Why would they kick them out at 23 hours when the reimbursement for 24 hour care is much greater.

Visit your local pain clinic.  They are all set up to do surgical procedures.  They are also typically set up to keep people overnight if need---at a substantial cost to the individual since CMS and health insurance companies will not reimburse them as a healthcare occupancy.  They are not I-2's since it is only one of two patients.


----------



## Big Mac (Feb 4, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

definition of custodial care accepted.  The definition as it relates to I-2 however says much more than custodial care on a 24-hour basis.  The wordin is "buildings and structures used for medical, surgical, psychiatric, nursing OR custodial care on a 24-hour basis."  It seems quite certain the medical and nursing will be provided on a 24-hour basis.


----------



## Rick18071 (Feb 10, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

This is a real gray area. IBC 308.1 Instiutional Group I......in which people are cared for or live in a supervised environment........

Does not say anything about 24 hours here, so if must be an group I (since people are being cared for) and the only I close to this is I-2.

It's confusing because at the end of IBC 308.3 it says 5 or fewer persons shall be classified as R-3.

I don't know if this means the facility (a) has a occupancy load of 5 or less, or (b) 5 or less patients that are being cared for 24 hours.

Since you can use R-3 for less than 5, I would think that (b) is right.

304.1 Group B says clinics-outpatient. Doesn't say they can't be 24 hours.

IBC 102.1.........the most restrictive shall govern.


----------



## Big Mac (Feb 16, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

FYI - As I expected, this came down to a politically charged conclusion.  Of course it is a 'Use Group B' non-essential facility.  They said so.


----------



## Coug Dad (Feb 16, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

I would not take it personally or as a political decision.  Their Medicare and Medicaid reimbursements through CMS will therefore be based upon a Business Occupancy.  They could have requested healthcare reimbursement, but then they would have had to meet the higher healthcare occupancy requirements.  They are limited as to what procedures they can perform since they opted to go with the Business classification.  If they were to perform healthcare type procedures, they would not get the reimbursements.


----------



## kilitact (Feb 16, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Its an I-2, how can it be classified as a B, the fire marshall should be brought into the picture.


----------



## Coug Dad (Feb 16, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

No, it is not an I-2.  It is a B.  Get emergency treatment and either go home or sent to a hospital.

The 2009 IBC finally got around to getting up to date by adding a section on ambulatory care, a Group B occupancy.


----------



## kilitact (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

If the patients are incapable of self-preservation they are not ambulatory.

I-2 agree with Big Mac, this is an I-2 occupancy, no B(s)  :roll:


----------



## RJJ (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Kil: From the original OP the upper two floors are office use so they would be a B occ.

The tricky part is the first floor if it is I2 or B. There are quite a number of these out patient treatment centers being installed across the country. The attempt is to capture emergency patients that need some type of care and if the case warrants overnight stay they are shipped to a hospital that is connect for further treatment.

Yes some may need to be transported by ambulance, some may need assistance but this is not I2. Someone that has had a heart attack and is stabilized left on a stretcher and needs assistance to be transported is not staying over night with care. Some holds true for someone with a broken leg. The patient is stabilized and moved off for surgery. Is he/she assisted yes! Is it I2 no.


----------



## Coug Dad (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

Have some faith in the people who have the most skin in this game, the owner.  They know the reimbursable rules, the codes, and how to develop and run these types of facilities.  If this type of facility is classified as an I-2, don't ever complain about health care costs or your health insurance premiums again.  Just as store front urget care facilities (Group B) developed to save money, these large ambulatory care centers have the same goal. In and out care in a facility that does not have the extra costs associated 24 hour sleeping.


----------



## kilitact (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

From the op:



> The language in the Commentary to the Building Code is “An occupancy classified in Group I-2 is characterized by four conditions. It is a health care facility (yes), the occupant load is greater than 5 (yes), there is 24-hour a day medical supervision (yes), *and there are some occupants who are incapable of self preservation* (i.e. some or all of the occupants require physical assistance by staff to reach safety in an emergency situation) (yes). If folks are being treated in an emergency room, they already have issues with self preservation and if they are undergoing surgery they are also very likely to be incapable of self preservation."Three-story 88,000 square foot medical building. Medical Offices open 24-hr a day and an emergency room that by the tenants statement is expected to serve approximately 35,000 patients a year. The emergency deapartment has 18 patient rooms. By the way, the emergency department encompasses the entire first floor of the structure. The two upper floors are "normal" medical care offices.


Please read the op. This is I-2, the upper two floors are B. Again If the patients are incapable of self-preservation they are not ambulatory, hence no Bs.


----------



## Coug Dad (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

24 hour care is not related to the hours of operation.  It is related to how long a patient stays.  Check out the 2009, it adds clarity.


----------



## Dr. J (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)



> “An occupancy classified in Group I-2 is characterized by four conditions. It is a health care facility (yes), the occupant load is greater than 5 (yes), there is 24-hour a day medical supervision (yes), and there are some occupants who are incapable of self preservation (i.e. some or all of the occupants require physical assistance by staff to reach safety in an emergency situation) (yes). If folks are being treated in an emergency room, they already have issues with self preservation and if they are undergoing surgery they are also very likely to be incapable of self preservation."


The commentary should not be used for anything other than leveling out a construction trailer.  That paragraph has little to do with what the code says.  Occupant load has nothing to do with it, just the fact that there is 24 hour medical supervision has nothing to do with it, and "some occupants" - oh come on.

The 2 conditions listed in the code (not some work of fiction) are "medical, surgical, psychiatric, nursing or custodial care" (this building meets that), and "on a 24-hour basis for more than five persons who are not capable of self-preservation." (this building does NOT meet that condition).  The 24 hours mentioned is in reference to the people who are incapable of self preservation, not the building operation and there must be 6 or more people who fit that description, not “some occupants”.  There could be 37 people all incapable of self preservation for some time less than 24 hours, or there could be 5 people who underwent open heart surgery and are kept for 2 weeks, but this would still be a B occupancy.


----------



## kilitact (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)



> The emergency deapartment has 18 patient rooms. By the way, the emergency department encompasses the entire first floor of the structure. The two upper floors are "normal" medical care offices.


a reading of the entire post might help you all. I see more than 5, you see less than 5. more info needed. right now with the info submitted, I would go with I-2.

The commentary is a useful tool, like any tool if not used correctly...., but don't blame the tool.


----------



## Coug Dad (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)

The issue is not more or less than 5.  It is less than 24 hour care.  People would not be admitted to this type of facility for 24 hour care.  They either go home or are transported to a hospital.


----------



## kilitact (Feb 17, 2010)

Re: Proper Occupancy Classification / B / I-2 (?)



> The issue is not more or less than 5. It is less than 24 hour care. People would not be admitted to this type of facility for 24 hour care. They either go home or are transported to a hospital.


Say's who :?:  the op doesn't make this statement :!: I would err on the side of caution, not enough info to make a determination. Still I-2.


----------

