top of page

Legionella Requirements & Recommendations

Requirements: CMS Legionella Prevention 

In June of 2017, the Centers for Medicare & Medicaid Services (CMS) published a memorandum titled, “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)”.  This is a requirement for certain provider types to maintain their Medicare/Medicaid certification.

Legionella Recommendations

The CDC provides a "Practical Guide to Implementing Industry Standards for Legionella Management" in the form of a toolkit which can be downloaded from the CDC website here.  Here is part of their recommendation: 

CDC Toolkit for water management program

According to the CDC:

"Legionella, the bacterium that causes a type of serious lung infection known as Legionnaires’ disease, grows best in building water systems that are not well maintained.  Some water systems in buildings have a higher risk for Legionella growth and spread than others.  Legionella water management programs are now an industry standard for large buildings in the United States (ASHRAE 188: Legionellosis: Risk Management for Building  Water Systems June 26, 2015.  ASHRAE:Atlanta.)"

Ways to Approach Legionella Management

If you’re a provider type identified in the CMS Legionella Memorandum – compliance is mandatory.  As a healthcare provider not specifically identified in the CMS directive, you still have the CDC recommendations to consider and could take any of the 3 approaches below.


Comply with the memorandum, believing it will eventually affect you and/or it's the right thing to do.


Adopt certain elements of a water management plan to improve your infection prevention program and/or prepare for future CMS updates


Ignore the memorandum until updates require your provider type to comply

 CMS Legionella Compliance

As a Medicare-certified provider you are required to ensure your facility has a water management plan and documentation that, at a minimum, includes 3 key elements:

  1. Facility Risk Assessment

  2. Water Management Program

  3. Specified Testing Protocols

We are happy to discuss CMS requirements in more detail.  So contact us with any questions you have or if you just need information to get started! 

Contact Us

What would you like more information about:

Thanks for submitting! We will get back to you as soon as possible.

How Trusted Water Can Help: 

Trusted Water can help you understand the CMS directive and simplify your water management plan requirements.  Whether you are following the CMS mandate or the CDC recommendations, we can help you implement any or all of the steps for a legionella water management plan.  You can follow the links below for more information about each of the 3 steps for Legionella compliance.  

On-sitelegionella risk assessment facility walk through

Identify where Legionella and other opportunistic waterborne pathogens could grow and spread in the facility water system.


Legionella Risk Assessment

trusted water CMS requirements for water management programs

Water Management Programs must consider the ASHRAE and CDC toolkit.

Legionella Water Management Program

Legionella testing as part of an On-site Legionella risk assessment

With acceptable ranges for control measures, including corrective actions when control limits are not maintained.

Legionella Testing

Who's affected by CMS Legionella Requirements? 

Updated again in July 2018, the memorandum applies specifically to the following provider types; Hospitals, Critical Access Hospitals and Long-Term Care centers.  While these provider types are identified specifically by the memorandum, it was intended to “provide general awareness for ALL healthcare organizations”, including outpatient settings.

Which healthcare facilities are required to comply to the CMS Medicare Medicaid memorandum "Requirements to reduce legionella Risk in healthcare facility water systems to prevent cases and outbreaks of Legionnaires Disease"
bottom of page