Mandated Edition of NFPA 99 for Health Care Facilities in Arizona

Key Points

• The 2012 edition of NFPA 99 remains the primary standard for hospitals and other health care facilities in Arizona, aligning with the Centers for Medicare & Medicaid Services (CMS) national baseline.
• Arizona has not adopted a newer edition statewide, such as 2021 or 2024, though local jurisdictions may reference updated codes for general building purposes.
• Compliance is required for CMS-certified facilities, with no major state-specific amendments or exceptions identified for new versus existing structures.
• No pending updates to align with recent NFPA editions are evident as of November 12, 2025, but ongoing national advocacy could influence future changes.
• Uncertainties stem from NFPA 99's absence in some state codes, potentially deferring to federal or local authorities, but sources consistently point to the 2012 edition.

Overview

Arizona hospitals and health care facilities primarily adhere to the 2012 edition of NFPA 99, which provides guidelines for systems like medical gases, electrical installations, and emergency management to ensure patient safety. This matches the CMS standard for certified providers, effective since 2016. State agencies like the Arizona Department of Health Services (ADHS) enforce this through licensing, with supporting documents requiring certification under the 2012 edition for specific systems.

State Adoption and CMS Alignment

While Arizona's administrative rules do not explicitly list NFPA 99, practical enforcement through ADHS and CMS ensures its application. For instance, architectural approvals mandate compliance with Chapter 5.1.12 for medical gas systems. This setup avoids conflicts with federal requirements, as states cannot impose less stringent standards for CMS participation.

Effective Dates and Exceptions

The CMS effective date of July 5, 2016, applies statewide. For new construction or modifications, codes in effect at plan submission govern, but no deviations from 2012 NFPA 99 are specified. Existing facilities may have limited exemptions for unrelated systems, but annual inspections maintain overall compliance.

Potential Updates

No imminent changes were found, with Arizona's recent regulatory updates focusing elsewhere. CMS continues with 2012, despite calls for modernization.

The 2012 edition of NFPA 99 serves as the primary mandated standard for hospitals and other health care facilities in Arizona, consistent with the national CMS baseline established in 2016. This edition provides comprehensive requirements for electrical systems, gas and vacuum systems, environmental systems, materials, and emergency management in health care settings, aiming to minimize risks to patients, staff, and visitors. Arizona's state licensing authority, the Department of Health Services (ADHS), does not explicitly adopt a different edition in its administrative rules, but supporting documents from ADHS indicate compliance with the 2012 version for key elements like medical gas certifications. This alignment ensures that Medicare and Medicaid-certified facilities meet federal conditions of participation without state-level deviations that could create less stringent standards.

In detail, the Arizona Administrative Code (A.A.C.) Title 9, Chapter 10, which governs health care institution licensing, incorporates several NFPA standards by reference under R9-10-104.01. These include NFPA 70 (National Electrical Code, 2012 edition) for electrical safety and NFPA 101 (Life Safety Code, 2012 edition) for occupancy, egress, and fire protection in facilities such as hospitals, nursing care institutions, and behavioral health centers. However, NFPA 99 is notably absent from direct mentions in the code. Instead, an ADHS PowerPoint on the architectural approval process explicitly requires a "Compliance certification as per 2012 NFPA99 Ch. 5.1.12," which pertains to medical gas and vacuum system testing and verification. This requirement applies to room-specific designs in health care facilities, ensuring systems like piped medical gases meet safety thresholds for pressure, purity, and alarms.

For context, CMS adopted the 2012 editions of NFPA 101 and NFPA 99 in a final rule published May 4, 2016, effective July 5, 2016, to update fire safety requirements for certain health care facilities. This federal baseline mandates minimum standards for installation, inspection, testing, maintenance, and performance of systems in health care environments. Arizona, like other states, must ensure its regulations are at least as stringent for CMS-certified providers, which include most hospitals. Since no state rule supersedes or adopts a newer edition, the 2012 version prevails. Cross-verification with ASHE resources confirms that CMS still enforces the 2012 edition nationally, with ongoing advocacy for updates but no changes as of 2025.

Arizona supplements these with the 2018 edition of the FGI Guidelines for Design and Construction of Health Care Facilities, incorporated under the same A.A.C. section. The FGI 2018 references "governing editions" of NFPA 99, meaning the edition enforced by the local AHJ—typically ADHS for licensing or the State Fire Marshal for fire safety. Interpretations from FGI indicate alignment with NFPA 99 for electrical receptacles in patient care areas, but without specifying an edition beyond what the AHJ mandates. Given the ADHS reference to 2012, this suggests no shift to newer versions like 2018 (which FGI 2018 might implicitly reference) unless locally adopted.

On the state fire code side, the Arizona State Fire Code adopts the 2018 International Fire Code (IFC), as enforced by the Department of Forestry and Fire Management's Office of the State Fire Marshal. The 2018 IFC references various NFPA standards in Chapter 80, including NFPA 99 (likely the 2018 edition for consistency with publication dates). However, this applies broadly to building construction and is not tailored to health care facilities. For hospitals, state licensing under ADHS takes precedence, with fire inspections required annually by local departments or the State Fire Marshal to verify compliance. No health care-specific amendments to the state fire code were found that alter NFPA 99 requirements.

Local variations add nuance but do not indicate statewide differences. For example, the City of Tucson adopted the 2024 editions of ICC and NFPA model codes on June 3, 2025, effective January 1, 2026, skipping the 2021 cycle. While this includes updates to fire alarm systems and safety plans, NFPA 99 is not explicitly mentioned, and such local codes govern building permits rather than state health care licensing. Similarly, the Sun City Fire District adopted amendments to 2018 codes in May 2025, referencing NFPA 99 for emergency power in Group I-2 occupancies (health care), but without specifying an edition beyond the adopted IFC.

Regarding amendments or exceptions, Arizona rules distinguish somewhat between new construction and existing facilities. For new builds or modifications (e.g., costing over $300,000 or affecting capacity/services), architectural plans must demonstrate compliance with codes in effect on submission date (R9-10-104). Existing facilities licensed before October 1, 2013, may have exemptions for certain systems (e.g., sprinklers or alarms), provided documentation is maintained. However, no NFPA 99-specific exceptions were noted. Effective dates tie to plan submission or CMS adoption (2016), with no Arizona-unique timeline.

No pending updates or alignments with 2021 or 2024 NFPA 99 editions were identified. Recent Arizona rule changes, such as the February 28, 2025, updates to Title 9, Chapter 10 (effective March 10, 2025), focused on home health licensing and general compliance but omitted NFPA revisions. CMS has permitted alternative power sources under the 2021 NFPA 99 in a 2023 memo, but this does not change the baseline adoption. NFPA's 2024 edition introduces risk-based approaches, but without state or federal adoption, it remains non-mandated. ASHE and FGI resources emphasize the 2012 edition's persistence, with no Arizona-specific notes.

Uncertainties arise from NFPA 99's omission in A.A.C. Title 9, Chapter 10, potentially implying deference to CMS or FGI. Conflicting local adoptions (e.g., 2018 IFC referencing possibly 2018 NFPA 99) could create discrepancies for non-CMS aspects, but cross-checks with primary sources like CMS memos and ADHS documents lean toward 2012 as the de facto standard. If a facility is not CMS-certified, local codes might allow newer editions, but most hospitals are certified, minimizing this gap.

This comprehensive survey incorporates all sourced details, ensuring a self-contained reference for understanding NFPA 99's application in Arizona health care settings.

Key Citations

• Arizona Department of Health Services PowerPoint on Architectural Approval Process
• CMS Life Safety Code & Health Care Facilities Code Requirements
• Arizona Administrative Code Title 9, Chapter 10
• Facility Guidelines Institute Adoption Map
• ASHE NFPA 99 Resources
• CMS Adoption of 2012 NFPA 99
• Arizona State Fire Code
• City of Tucson Updated Building Codes