Nursing Facilities Are At Risk Of Deficiency If All CPR Training Is Done Online

by Abbie J. Widger

This article was written for The Nebraska Health Care Association.

In 2013, CMS issued a survey and certification letter stating a nursing facility may not have a “no CPR” policy. Generally, CMS stated that a facility maintaining a “no CPR” policy violated a resident’s right to have an advanced directive and make his or her determination on health care. The 2013 letter was incorporated in the revisions to F tag 155. F tag 155 provides that a facility is required to establish, maintain and implement written policies and procedures regarding a resident’s right to formulate an advance directive, refuse medical or surgical treatment, and refuse to participate in experimental research. Pursuant to the guidance for surveyors for F155, the facility is required (by 42 C.F.R. § 489.102 Requirements for Providers) to provide this information in writing at the time of a resident’s admission. The resident must also receive a written description of the facility’s policies that govern the exercise of these rights. In addition, a facility is responsible for ensuring that its staff follow policies and procedures.

On Jan. 23, 2015, CMS revised survey and certification letter 14-01-NH to clarify a nursing facility’s obligation to provide CPR. The update states, “Staff must maintain current CPR certification for healthcare providers through a CPR provider whose training includes hands-on practice and in person skills assessment; online-only certification is not acceptable… Resuscitation science stresses the importance of properly delivered chest compressions to create blood flow to the heart and brain. Effective chest compressions consist of using the correct rate and depth of compression and allowing for complete recoil of the chest… Proper technique should be evaluated by an instructor through in-person demonstration of skills. CPR certification that includes an online knowledge component, yet still requires an in-person demonstration and skills assessment to obtain certification or recertification, is acceptable.”

This means that if the survey agency examines a facility’s CPR training and finds all training is online, the facility may receive a survey deficiency. The facility should check its CPR training and ensure that it contains an in-person demonstration and skills assessment.