Legionella Compliance by State: What Facilities Need to Know

If your facility operates in Ohio, Indiana, Kentucky, Michigan, Pennsylvania, or West Virginia, you are already subject to Legionella compliance requirements. The good news is you do not have to figure it out alone.

IWM provides Legionella testing, water management plan development, risk assessments, and remediation services built specifically for healthcare and senior living facilities. From routine testing to 24/7 emergency response, our team helps facility administrators stay ahead of compliance instead of scrambling to catch up after a survey finding or an outbreak.

Compliance by State

Every certified healthcare and senior living facility in the country operates under one mandatory federal standard, regardless of state. The Centers for Medicare and Medicaid Services requires certified facilities to maintain a documented water management plan and demonstrate an active Legionella risk reduction program based on ASHRAE Standard 188. This is not optional, and it applies fully in every state IWM serves.

From that federal baseline, several states have added their own requirements on top. Here is where each state stands.

  • Federal (CMS), all states. A documented water management plan and active Legionella risk reduction program are required for every Medicare and Medicaid certified facility, enforced through survey.

  • Ohio. State law requires assisted living facilities to implement a water management plan, hospital licensure rules adopted in 2024 set additional standards for addressing Legionella risk, and Ohio Plumbing Code Section 610 governs disinfection of new plumbing systems, on top of the federal requirement.

  • Michigan. Michigan Administrative Code R 325.45303 requires health care facilities to establish and implement a water management program based on ASHRAE Standard 188, including a risk assessment, control measures, and ongoing verification, on top of the federal requirement.

  • Pennsylvania. The federal CMS requirement is fully in force for certified facilities statewide. Allegheny County has also issued its own local guidance and requirements for Legionella control in healthcare facilities.

  • Indiana. The federal CMS requirement is fully in force for certified facilities. Indiana has not yet added a state level Legionella law on top of it.

  • Kentucky. The federal CMS requirement is fully in force for certified facilities. Kentucky has not yet added a state level Legionella law on top of it.

  • West Virginia. The federal CMS requirement is fully in force for certified facilities. West Virginia has not yet added a state level Legionella law on top of it.

Why IWM Helps Facilities Stay Ahead

IWM works with each facility to build a proactive approach tailored to that facility's specific water system, risk profile, and budget. There is no one size fits all plan here, our team designs a program that fits what your facility actually needs.

When something does go wrong, timing matters. In an emergency, every hour without the right response increases risk to residents and staff. IWM's 24/7 outbreak response team is built for exactly that moment, because the right leadership in a crisis protects lives, not just compliance records.

IWM also believes facilities should be equipped, not dependent. Our team provides training and ongoing support so your own staff can confidently manage day to day water safety practices, with IWM as the expert partner behind them.

The best place to start is often the simplest. IWM offers a Free Memo of Understanding, a no cost water management plan review to see where your facility stands today and what a proactive path forward looks like. Contact us today to learn more.

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Community Partner: Center for Disease Control (CDC)