CMS Clarifies CPR Policy for Nursing Homes

Members | January 29, 2015

The Centers for Medicare and Medicaid Services (CMS) has issued an updated Survey and Certification Letter regarding provision of cardiopulmonary resuscitation (CPR) in nursing homes. The memo announces the addition of a new section to the surveyor guidance accompanying the residents rights requirements for refusal of treatment, participation in experimental research, and advance directives.

The Centers for Medicare and Medicaid Services (CMS) has issued an updated Survey and Certification Letter regarding provision of cardiopulmonary resuscitation (CPR) in nursing homes.  

The memo announces the addition of a new section to the surveyor guidance accompanying the residents rights requirements for refusal of treatment, participation in experimental research, and advance directives.  

The additional guidance is intended to clarify nursing homes’  obligation to provide CPR. 

Included is that CPR-certified staff must be available at all times and  staff must maintain current CPR certification for healthcare providers and that the certification process must incorporate hands-on practice and an in-person skills assessment.  

Online-only certification is not sufficient, but programs that include both an online component and an in-person demonstration and skills assessment is acceptable.

What's In the Letter?

This Survey and Certification Letter is an update to the Oct. 18, 2013, CMS memo, "Cardiopulmonary Resuscitation (CPR) in Nursing Homes."

The revised guidance to surveyors adds section “CARDIOPULMONARY RESUSCITATION (CPR)” to Appendix PP at F-155 and is intended to clarify facilities’ obligation to provide CPR.

“F155:  §483.10(b)(4) and (8)-Rights Regarding Refusal of Treatment and Participation in Experimental Research and Advance Directives

      § 483.10(b)(4) – The resident has the right to refuse treatment, to refuse to participate in experimental research, and to formulate an advance directive as specified in paragraph (8) of this section.

      §483.10(b)(8) – The facility must comply with the requirements specified in subpart I of part 489 of this chapter relating to maintaining written policies and procedures regarding advance directives.  These requirements include provisions to inform and provide written information to all adult residents concerning the right to accept or refuse medical or surgical treatment and, at the individual’s option, formulate an advance directive. This includes a written description of the facility’s policies to implement advance directives and applicable State law.”

The revised/added guidance clarifies that staff must maintain current CPR certification for healthcare providers and that certification must be obtained “…through a CPR provider whose training includes hands-on practice and in-person skills assessment…”
    • Online-only certification is not sufficient, but CPR certification that includes both an online component and an in-person demonstration and skills assessment for certification/recertification is acceptable.
Facilities are prohibited from implementing a facility-wide “no CPR” policy as this would interfere with residents’ rights regarding to advance directives.    
     
Consistent with current American Heart Association (AHA) guidelines for CPR and Emergency Cardiovascular Care (ECC),  if a resident experiences cardiac arrest, “…facility staff must provide basic life support, including CPR, prior to the arrival of emergency medical services, and:
    • In accordance with the resident’s advance directives.
    • In the absence of advance directives or a Do Not Resuscitate (DNR) order.
    • If the resident does not show obvious signs of clinical death” ‘(e.g., rigor mortis, dependent lividity, decapitation, transection, or decomposition).
CPR-certified staff must be available at all times.