Compliance
Documenting an alternative equipment maintenance programme
January 16, 2026 · 7 minute read
An alternative equipment maintenance programme lets a hospital maintain some equipment on intervals and activities other than the manufacturer’s recommendation, provided the alternative is justified in writing and does not reduce safety. The programme is not the deviation. It is the documented reasoning behind the deviation.
What sits outside an AEM programme
Some categories cannot go into an AEM programme at all, and getting this wrong is the most serious error available here.
- Equipment subject to federal or state law or regulation that sets the maintenance requirement
- Equipment where the manufacturer identifies the maintenance as a condition of a warranty or a regulatory clearance
- Equipment new to the organisation, until enough of your own history exists to justify anything else
- Anything where the risk assessment concludes the alternative would reduce safety
What the written justification has to contain
This is the part that gets asked for, and the part most often reconstructed the week before a survey.
- The equipment, identified by type and by inventory
- The manufacturer’s recommendation, quoted, with the source document
- The alternative activity and interval being adopted
- The evidence: your own maintenance and failure history for that equipment type, with numbers
- The risk assessment, including what happens if the equipment fails and how the failure would be detected
- Who made the decision, their qualification to make it, and the date
- How the programme is monitored, and what would cause it to be revisited
Your own history is the evidence, so keep it
The justification rests on being able to show what actually happened to this equipment type in your hospital: how many devices, how many scheduled maintenance events, what proportion found a problem, and what failures occurred between events. Without that, the decision is an opinion, however well written.
Monitor and report it, or it decays
An AEM programme is not a decision made once. Completion rates and failure history for AEM equipment need reporting on a regular cycle, and a rising failure rate has to be able to move equipment back to the manufacturer’s schedule. Programmes that are never revisited are the ones that fail a review.
The standards have moved recently
This area has changed. ANSI/AAMI EQ103:2024 is the first consensus standard specifically for AEM programmes, and accreditation expectations around medical device maintenance have been rising with it. Check the current edition of whatever standard your accreditor references rather than relying on a summary, including this one.
Where to start
One equipment type, with a large population and good history, where the manufacturer’s interval is clearly conservative for how you use it. Write the full justification for that one, get it reviewed, and use it as the template. A programme that starts with a hundred device types produces a hundred thin justifications.
