Restraint and Seclusion: Navigating a Problematic CMS Standard
From: Apr 28, 2023 - To: Dec 31, 2023
Restraint and Seclusion is a hot spot with both CMS and the Joint Commission and a common area where hospitals are cited for being out of compliance. The restraint policy is one of the hardest to write and understand in healthcare today.
CMS made significant changes in restraints in 2019. Specifically, CMS changed the term from LIP - licensed independent practitioner to LP (licensed practitioner). The change allows PAs to write orders for restraints in states where they are considered dependent practitioners. The changes will be discussed in detail. The number one area of deficiencies for a specific requirement in the CMS CoP is regarding restraints. CMS permits access to the deficiencies against hospitals which is updated quarterly. This program will discuss the most problematic standards in the restraint section.
Did you know any physician or provider who orders restraint must be trained in the hospital’s policy? Did you know that both CMS and Joint Commission require hospital staff to be educated on restraint and seclusion interpretive guidelines on an annual basis? This program can be used to help hospitals meet this requirement. CMS also says that restraint training must be ongoing so you cannot just provide training at orientation and forget about it. CMS has ten pages of training requirements.
This program will discuss the requirements for an internal log and what must be in the log for patients who die in one or two soft wrist restraints. It will include what must be documented in the medical record also. It will also discuss the new electronic reporting requirements for patients who die in restraints and within 24 hours of being in a restraint.
Outline:-
Introduction to CoP Manual
CMS deficiencies and access
Complaint manual
CMS changes to restraint and seclusion
PA may write orders
Internal log and soft wrist restraints
Conditions of Participation for CAH
Learning from Each other
Seclusion – what it is and is not
Medical restraints
Behavioral health restraints
Violent and self-destructive behavior
Definition of restraint and seclusion
Manual holds of patients,
Leadership responsibilities
Two soft wrist restraints, internal log, and documentation
Culture of Safety
Drugs used as a restraint
Standard treatment
Restraints do not include
Side rails, forensic restraints, freedom splints, immobilizers
Assessment
Need order ASAP
Order from LIP and notification of attending physician ASAP
Documentation requirements
Least restrictive requirements
Alternatives
RNs and One-hour face-to-face assessment
Training for RN doing a one-hour face-to-face assessment
New training requirements
New death reporting requirements
Ending at the earliest time
Revisions to the plan of care
Time-limited orders
Renewing orders
Staff education
First aid training required
Monitoring of patients in R/S
Joint Commission Hospital Restraint standards and differences from CMS
Who Should Attend:-
All nurses with direct patient care
Compliance officer
Chief nursing officer
Chief of medical staff
COO
Nurse Educator
ED nurses
ED physicians
Medical staff coordinator
Risk manager
Patient safety officer
Senior leadership
Hospital legal counsel
Chief Risk Officer
PI director
Joint Commission coordinator
Nurse managers
Quality director
Chief medical officer
Security guards
Compliance officer
Accreditation and regulation staff and others responsible for compliance with hospital regulations
Anyone involved in the restraint or seclusion of patients.
Persons are responsible for rewriting the hospital policies and medical staff bylaws.
Staff that removes and applies them as part of their care such as radiology techs, ultrasound technologists, transport staff, and others.
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