On October 18, 2013 CMS released S&C: 14-01-NH regarding F155 and Cardiopulmonary Resuscitation (CPR) in Nursing Homes.  This memo was revised on 1-23-15. 

The memo (see link below) gives guidance to surveyors on assessing a facilities policy for honoring resident choice and advance directives.  In the past, some facilities have chosen to not train their staff to initiate CPR but to call 911 in the event of a code.  The thought was that this would relieve the facility of liability.  CMS has determined that this policy does not meet the rights of residents who have declared a full code status as there would be a delay in emergency response.  The regulation clearly states that skilled nursing facilities may not have a “no CPR” policy.  

Although we can agree to disagree with CMS and having a CPR certified employee in attendance for all outings can place a hardship on facilities, it is now the regulation.  The question for each of us is how do we meet these requirements?  Here are a few suggestions:

• Have all staff CPR certified, housekeepers, activity staff, dietary staff, etc. Maintain CPR certification documents in the employee file.

• Initiate an audit process to ensure certification is current and updated timely.

• Schedule one additional, CPR certified staff member (does not need to be a licensed nurse) to accompany residents on outings.

• Discuss the regulatory requirement with your contracted transport provider and require that their personnel be CPR certified. Be sure to establish a file with certification documents for any driver

• Seek legal counsel regarding additional charges for transporting residents using facility vehicles to assist in covering the additional expense of staff in attendance.

• Limit outings and schedule physician visits on specific days of the week when possible to ensure staffing meets the needs.