CMS Memo S&C: 14-01-NH
The Section for Long-Term Care Regulation wants to make certified providers aware that this Memo requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR. CMS’ guidance had previously been that an on-duty staff member be able to perform CPR appropriately at all times. If a question arose during a federal process regarding whether someone could perform CPR properly, a surveyor may have needed to ask for an explanation of appropriate technique from some available staff member to verify compliance with that requirement, but verifying the certification of a particular staff member typically wasn’t necessary.
One point that remains unaddressed in this new S&C Memo is that many different CPR training agencies offer “certification” of their own, and this Memo doesn’t specify which agency’s certifications are acceptable to CMS and which are not. SLCR has requested a clarification of this point from the CMS Central Office, and so has the Kansas City Regional CMS office. Neither of our offices have received a response. When we receive further guidance, we will provide it to you via this Listserv. Until then, we will not be altering our current survey practices, but we want to make providers aware that this new S&C Memo has been issued by CMS, and that depending on their answer to our questions, it’s likely that some of your staff may need to obtain CPR certification with very short notice.
Because this memo references the American Heart Association as a standard-setting organization with regard to CPR, it is our belief that provider certification through the AHA will almost certainly be deemed acceptable by CMS. Whether other certifications will suffice is less clear at this time. As soon as we have some clarification on this point, we will share it with you. We apologize that we can’t offer more specific guidance at this time, and appreciate your patience.
UPDATED GUIDANCE HAS BEEN POSTED – PLEASE REFER TO: