Did you know there were multiple changes to the hospital nursing chapter of the conditions of participation (CoPs) that went into effect on November 29, 2019, with changes in 2020? Did you know there were over eighteen CMS survey memos of importance to nursing in the recent past? The final changes were in the Hospital Improvement Rule. It will discuss plans of care, staffing, policy changes, when an RN is required in an outpatient department, documentation, supervision, nursing leadership, verbal orders, antibiotic stewardship program requirement, and more.
Did you know that CMS has issued deficiency reports which include which are the most problematic standards for hospitals? Did you know that nursing services have been cited over 5,635 times according to the most recent report? This is a must-attend program for any chief nursing officer, clinical nurse, or nurse supervisor or person interested in ensuring compliance with the CMS hospital conditions of participation in nursing. This must-attend program and will discuss the deficiencies and how hospitals can ensure compliance.
Recently, there has been increased scrutiny and surveillance to make sure that all hospitals are in compliance with the hospital CoPs. Don’t be caught off guard and put your hospital’s reimbursement at risk. If a surveyor showed up at your door tomorrow, would you be prepared?
CMS made previous revisions to IV medication administration, blood transfusion, safe injection practices, compounding, beyond-use date (BUD), and implemented safe opioid standards. Hospitals are still struggling with how to comply with these complicated standards especially the safe opioid interpretive guidelines.
There are many changes in the past to this section include timing of medications, standing orders, soft wrist restraints, and restraint reporting, plan of care, verbal orders, blood transfusions, IV medication, compounding, BUD, antibiotic stewardship program, safe injection practices, self-administration of medications and drug orders. CMS has issued the final worksheets on QAPI, discharge planning, and infection control which should be on the radar screen of all department managers especially because there are changes in 2020 in all these sections. There are also proposed changes to the infection control worksheet which will be discussed.
Every hospital that accepts Medicare and Medicaid reimbursement must follow the CMS (Center for Medicare and Medicaid Services) Conditions of Participation (CoPs) and it must be followed for all patients. This program will cover the nursing services section in the hospital CoP manual. Facilities accredited by the Joint Commission, Health Care Facility Accreditation Program, CIHQ, and DNV GL Healthcare must also follow these regulations.
This program will also reference other important sections that all nurses should be aware of that are found outside the nursing services section such as the revised discharge planning standards, medication standards, revised history and physicals, visitation, restraint and seclusion, and grievances, and privacy and confidentiality. CMS issued the privacy and confidentiality memo, safe injection practices memo, humidity memo, and insulin pen memo.
This section contains many problematic standards for hospitals including the nursing care plan standards and that an order is required for all medication especially if standing order or protocol used. Staffing, medications, a three-time frame for administering medications, and educational requirements will be discussed along with changes standing orders and protocols. CMS starting issuing deficiency reports and this will be covered so hospitals are aware of which are the problematic tag numbers.
Other important sections nurses should be aware of:
Chief nursing officer, all nurses, nurse managers, nurse supervisors, nurse educators, HIM staff, compliance officer, chief of medical staff, Medical staff coordinator, risk manager, patient safety officer, senior leadership, COO, documentation specialist, hospital legal counsel, QAPI director, Joint Commission coordinator, regulatory officers, legal counsel, chief operating officer, chief medical officer, physicians, education department staff, board members, director of health information management, audit staff, and others responsible for compliance with hospital nursing regulations including documentation compliance.
Please note that CMS has a separate CoP for critical access hospitals (CAHs). However, since the CAH nursing CoPs were rewritten on April 7, 2015, and in 2020, they are for the most part the same or a shortened version. These differences are discussed. Any CAH attending can have access to the CAH nursing CoPs because the tag numbers are different. All of the CAH tag numbers changes in 2020.
Sue Dill Calloway, R.N., M.S.N, J.D. is a nurse attorney and President of Patient Safety and Healthcare Consulting and Education. She is also the past Chief Learning Officer for the Emergency Medicine Patient Safety Foundation and a current board member. She was a director for risk management and patient safety for five years for the Doctors Company. She was the past VP of Legal Services at a community hospital in addition to being the Privacy Officer and the Compliance Officer. She worked for over 8 years as the Director of Risk Management and Health Policy for the Ohio Hospital Association. She was also the immediate past director of hospital patient safety and risk management for The Doctors Insurance Company in Columbus area for five years. She does frequent lectures on legal and risk management issues and writes numerous publications.
Sue has been a medico-legal consultant for over 30 years. She has done many educational programs for nurses, physicians, and other health care providers on topics such as nursing law, ethics and nursing, malpractice prevention, HIPAA medical record confidentiality, EMTALA anti-dumping law, Joint Commission issues, CMS issues, documentation, medication errors, medical errors, documentation, pain management, federal laws for nursing, sentinel events, MRI Safety, Legal Issues in Surgery, patient safety and other similar topics. She is a leading expert in the country on CMS hospital CoPs issues and does over 250 educational programs per year. She was the first one in the country to be a certified professional in CMS. She also teaches the course for the CMS certification program.
She also writes many articles for Briefing on the Joint Commission. She also writes articles on ambulatory surgery and present educational programs on ambulatory surgery issues. She was affiliated with Mount Carmel College of Nursing as an adjunct nursing professor for over seventeen years. She was also a trial attorney for eight years defending nurses, physicians and healthcare facilities.
She has been employed in the nursing profession for more than 30 years. Ms. Calloway has legal experience in medical malpractice defense for physicians, nurses and other health professionals. She is also certified in healthcare risk management by the American Society of Healthcare Risk Managers.
Ms. Calloway received her AD in nursing from Central Ohio Technical College, her BA, BSN, MSN (summa cum laude) and JD (with honors) degrees are from Capital University in Columbus. She is a member of many professional organizations. She has a certificate in insurance from the American Insurance Institute.
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