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07/10/2025

You Asked... We Answered...

You Asked: Are water cultures for Legionella required as part of a facility’s water management program? 

We Answered: No, routine water cultures for Legionella are not required as part of a water management program. CMS states, in Appendix PP, of the State Operations Manual, under F880: At this time, CMS does not require water cultures for Legionella or other opportunistic waterborne pathogens as part of routine program validation, although there may be instances when it is needed (e.g., a case of healthcare-associated legionellosis or a potential outbreak of legionellosis in the facility).  

The facility should contact the local/state public health authority if there is a case of healthcare-associated legionellosis or an outbreak of an opportunistic waterborne pathogen causing disease. The facility must follow public health authority recommendations which may include, but is not limited to, remediating the pathogen reservoir and adjusting control measures as necessary.  

The State Agency will work with local/state public health authorities, if possible, to determine if the water management program was inadequate to prevent the growth of Legionella or other opportunistic waterborne pathogens and whether the facility implemented adequate prevention and control measures once the issue was identified.   

Additional guidance can also be found in the CDC’s Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings toolkit.  

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