1. Constructing for Health and Safety Permit Review Process for Senior Healthcare Facilities in Colorado May 15, 2014

2. Panel Members Rob Sontag – Colorado Division of Fire Prevention & Control Deputy Section Chief for Fire & Life Safety Gary Prager, AIA, NCARB, CDT, LEED AP – H+L Architecture Senior Life Practice Lead Kimberly Erickson – Morningstar Senior Living VP of Operations Carole Hull – Spectrum Retirement VP of Resident Care

3. Objectives Create an understanding throughout Colorado of the differing construction permitting requirements between DFPC and Local Authorities Having Jurisdiction. Demystifying the applicable Codes and Standards Editions Understanding of the relationship of the construction permit, Certificate of Compliance and the Licensure as a health facility.

4. The mission of the Colorado Division of Fire Prevention & Control (DFPC) is: “…to provide leadership and support to Colorado communities in reducing threats to lives, property and the environment from fire through fire prevention and code enforcement; wildfire preparedness, response, and management; and the training and certification of firefighters.” The Fire and Life Safety Section of DFPC is tasked with ensuring (through partnerships with local fire and building safety officials and property owners) the safety of the State’s schools and community colleges, casinos, fireworks facilities, installed fire suppression systems and licensed health facilities. WHO IS DFPC?

5. Colorado House Bill 12-1268 transferred responsibility for ensuring the construction and fire safety of licensed health facilities from the Colorado Department Of Public Health and Environment (CDPHE) to the Colorado Department of Public Safety, Division of Fire Prevention & Control (DFPC). The statute mandates (and DFPC rules reinforce) that where there are locals willing and capable of doing the plan review and inspections and no other requirements (i.e. Medicare or Medicaid requirements) exist that the local jurisdiction is in charge. DFPC is tasked with ensuring compliance with established codes and standards where there is no local review and where CMS has requirements. WHY IS THE DFPC INVOLVED IN MY HEALTH FACILITY CONSTRUCTION PROJECT?

6. The process is slightly different than it was at CDPHE: 1) If the facility is not billing CMS and there are local jurisdictions willing and capable, DFPC may not do any plan review and may only need to be notified of the project 2) DFPC uses a true permitting process rather than a ongoing plan review process. 3) DFPC can provide for pre-submittal plan review conferences to address design challenges. IS THE PROCESS THE SAME AS IT WAS AT CDPHE?

7. The process is slightly different than it was at CDPHE: 4) Nearly every construction project is subject to permitting (of some sort). 5) Pre-identified construction inspections can and should be called for concurrently with your local inspectors to save time and money. 6) For licensure, DFPC is looking at an updated code set (2012 Life Safety Code, 2012 ICC Codes, 2010 FGI). 7) There is a pre-defined appeals process. IS THE PROCESS THE SAME AS IT WAS AT CDPHE? (cont.)

8. There are 2 types of DFPC fees associated with Building a Health Facility in Colorado 1- Plan Review Fee Based on Project Valuation In addition to local jurisdiction 2- Certificate of Compliance Fee CDPHE can not issue a license with out a valid COC Note that these are in addition to the fees required by CDPHE for Licensure. What’s with all these fees?

9. WHO IS H&L ARCHITECTURE?

10. Denver based since 1963 Specialists in Senior Life, Hospital and Healthcare Projects WHO IS H&L ARCHITECTURE?

11. CDPHE Colorado Department of Public Health and Environment DFPC Department of Fire Prevention & Control Transfer of Permit Reviews COLLABORATION 2009 Schools 2012 Healthcare Senior Living

12. What are the Current Building Codes? 2012 International Building Code 2012 International Fire Code 2012 International Plumbing Code 2012 Mechanical Code 2012 Energy Conservation Code 2012 Existing Building Code 2012 International Residential Code 2012 NFPA 101 and 101A Life Safety Codes 2010 Facilities Guidelines Institute (FGI) 2012 NFPA 99 Health Care Facilities Code 2000 NFPA 101 Life Safety Code with State Comments PLUS LOCAL REQUIREMENTS, ORDINANCES, ETC.

13. Recommended Pre-submittal Reviews Pre-submittal review with DFPC Determine AHJ Pre-submittal review with CDPHE Review compliance with Licensing requirements Pre-submittal review with Local Building Department Discover ordinances, amendments & restrictions Confirm zoning requirements Pre-submittal review with Local Fire Department Review access & fire protection requirements Confirm I or R Occupancy requirements 1. 2. 3. 4.

14. Recommended Review Documentation Preliminary Site Plans Show ingress & egress Show FD access Preliminary Floor Plans Preliminary Code Study Indicate paths of travel & exiting Indicate fire & smoke compartments Indicate construction type compliance Licensing Indicate compliance with FGI 1. 2. 3. 4. Show building layouts

15. Founded by Ken Jaeger in 2006 based on our mission of Honoring God in our business practices and relationships, valuing seniors as gifted and contributing individuals and investing generously in our teams’ ability to serve well, MorningStar Senior Living is a owner/operator/developer of Independent, Assisted And Memory Care communities throughout the western United States. We operate 11 communities within Colorado, Arizona, Montana, Nevada and Idaho, and have a projected 7 new communities opening in the next 12-36 months. WHO IS MORNINGSTAR?

16. MORNINGSTAR’S RECENT EXPERIENCE Due to our growth and development within multiple jurisdictions within the state of Colorado, we’ve been faced with situations that require partnerships with local city and fire and the CDPHE. Partnership with local fire and city (review of EOP) Maneuvering through the changes at the CDPHE in development that was started prior to July 2013 Understanding how building construction impacts emergency operations plans and evacuation. What’s next, building after July 2013 and it’s impact on operations.

17. WHO IS SPECTRUM? 31 Communities Operating/Developing in 11 States Privately Owned Corporate Office in Denver, Colorado Developer, Owner, Operator, of Senior Living Communities Celebrated 10 Years in April, 2012

18. SPECTRUM’S RECENT EXPERIENCE WITH INITIAL LICENSING 7 New Communities in past 2 years Arizona Colorado Illinois Missouri New Mexico Colorado [by far] most organized & collaborative Life Safety Visits occurred throughout construction resulted in building approval without surprises.

19. Q&A