Guidance Clarification Update February 21, 2014
CMS Memo S&C: 14-01-NH
The Section for Long-Term Care Regulation (SLCR) wants to make certified providers aware that updated guidance from CMS (S&C: 14-01-NH) now requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR. Previously, if a question arose during a federal regulatory 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 was not necessary.
This most recent memo states that “certification” of some staff members is mandatory, but the memo does not clarify which certifying agencies are acceptable (i.e., American Heart Association). SLCR and the Kansas City Regional CMS office requested a clarification of this point.
We have now received guidance indicating that the purpose of this memo was to, “…ensure that facilities do not implement facility-wide ‘no CPR’ policies and that facilities have CPR-certified staff available at all times,” but that CMS does not intend to review or approve all certification agencies.
A wide range of organizations offer CPR certification – some are based online and some are conducted in-person. To this point, CMS has clarified that while S&C: 14-01-NH does not require the use of any specific certifying agency, there are two components that are required with regard to CPR certification:
- The certification must be designed for healthcare providers (therefore, CPR courses for laypersons which teach chest compressions, but not mouth breathing, are not sufficient); and
- Nursing home policies should address how staff members should maintain and document their CPR certification.
The American Heart Association certification is acceptable under this guidance, but it is not the only acceptable certification. Many homes in Missouri are currently obtaining CPR certification through the American Safety & Health Institute (ASHI), which is also acceptable, as are others, as long as they are designed for professional healthcare providers.
You may view the memo here: CMS Memo S&C: 14-01-NH, or visit www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.