Welcome back to CMS Compliance Group’s “Ftag of the Week” blog series. This week’s tag is under the regulatory group Quality of Life. It’s F678, which under the existing Ftags can be found under F155 Right to Refuse; Formulate Advance Directives. In 2013, CMS issued a S&C memo mandating that nursing facilities may not establish or implement facility-wide no CPR policies (S&C Ref: 14-01-NH). This was put under F155 because decision-making for advance directives must be individualized, and creating a facility-wide policy would not promote person-centered care. In 2015, that S&C memo was revised to include clarification of information on providing CPR.
Now the basic life support / CPR requirement will be under its own tag once the updated renumbering is effective in November. Staff are required to provide basic life support, including CPR, to a resident requiring such emergency care prior to the arrival of EMS and subject to the resident’s advance directives and physician’s orders. CPR-certified staff must be available 24 hours a day to provide emergency care if needed and may not limit staff to only calling 911 when cardiac or respiratory arrest occurs.
The facility should have policies in place that address the provision of basic life support and CPR, including directing staff to initiate CPR when:
- Cardiac or respiratory arrest occurs for a resident who does not show obvious signs of irreversible death
- A resident has requested CPR in his/her advance directives
- A resident has not formulated an advance directive
- A resident who does not have a valid DNR order
Knowing a resident’s advance directive wishes and code status can be troublesome for some facilities to keep current. You need a sound tracking systems related to every resident’s code status as well as for ensuring CPR-certified staff have a current certification. Remember, individual States may have additional more specific requirements that need to be met regarding providing CPR.