CPR – Is Your Facility Meeting the New Regulations?

Angie Szumlinski
March 4, 2015

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.  

The regulation for F155 also states that a CPR certified employee must be available “at all times”.  This has been interpreted by surveyors to mean even off-site (i.e., transportation to physician visits, dialysis, activity outings, etc.).  Several facilities have received immediate jeopardy citations for not providing CPR certified staff for residents off-site.  Evolucent has obtained clarification and a legal opinion on this requirement and it was determined that this is the intent of the regulation.

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.
As always, if you have any questions or need assistance with developing a plan please contact your Evolucent risk manager.  Thank you!

Link to CMS.gov memorandum regarding CPR: Cardiopulmonary Resuscitation (CPR) in Nursing Homes

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