CMS F678 and 679 regarding Regulations/Guidance related to Staff training:
F678 §483.24(a)(3) Personnel provide basic life support, including CPR, to a resident requiring such emergency care prior to the arrival of emergency medical personnel and subject to related physician orders and the resident’s advance directives.
INTENT §483.24(a)(3)
To ensure that each facility is able to and does provide emergency basic life support immediately when needed, including cardiopulmonary resuscitation (CPR), to any resident requiring such care prior to the arrival of emergency medical personnel in accordance with related physicians orders, such as DNRs, and the resident’s advance directives.
GUIDANCE §483.24(a)(3)
In keeping with the requirement at §483.24 to “provide the necessary care and services to attain or maintain the highest practicable physical, mental, and psychosocial wellbeing of the resident” facilities must ensure that properly trained personnel (and certified in CPR for Healthcare Providers) are available immediately (24 hours per day) to provide basic life support, including cardiopulmonary resuscitation (CPR), to residents requiring emergency care prior to the arrival of emergency medical personnel, and subject to accepted professional guidelines, the resident’s advance directives, and physician orders.
Facilities must have systems in place supported by policies and procedures to ensure there are an adequate number of staff present at all times who are properly trained and/or certified in CPR for Healthcare Providers to be able to provide CPR until emergency medical services arrive.
F659 Guidance
The facility must ensure that services provided or arranged in accordance with the resident’s plan of care are delivered by individuals who have the skills, experience and knowledge to do a particular task or activity. This includes proper licensure or certification, if required.
The regulation for F678 also states that a CPR-certified employee must be available “at all times.” Surveyors have interpreted this to mean even off-site (i.e., for transportation to physician visits, dialysis, activity outings, etc.). Several facilities have received immediate jeopardy citations for failing to provide CPR-certified staff for residents off-site.
While we recognize that having a CPR-certified employee present at every outing can be a burden on facilities, it is required by regulation. Here are a few suggestions to help meet the requirements.
- Have all staff, including housekeepers, activity staff, dietary staff, etc., CPR certified. 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 (who 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.
- To ensure staffing meets needs, limit outings and schedule physician visits on specific days of the week when possible.