CMS Hospital Restraint and Seclusion - Navigating the Most Problematic CMS Standards

CMS Hospital Restraint and Seclusion - Navigating the Most Problematic CMS Standards

June 19, 2024 01:00 PM EST 90 Minutes

Presented By: Laura A Dixon

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Description

Restraint and Seclusion is a hot spot with both CMS and the Joint Commission and an area where hospitals are frequently cited as non-compliant. This program will discuss this most problematic standard.

CMS has fifty pages of interpretive guidelines on restraint and seclusions for hospitals. Every hospital that accepts Medicare patients will have to comply with the regulations even if accredited by the Joint Commission, HFAP, CIHQ, or DNV Healthcare.

Any physician or provider who orders restraint must be trained in the hospital’s policy. Both CMS and Joint Commission require hospital staff to be educated on restraint and seclusion interpretive guidelines on an annual basis. CMS also says that restraint training must occur before a staff member/provider can apply or remove restraints and must be ongoing so it cannot occur at orientation only. There are ten pages of training requirements.

Finally, this program will briefly cover The Joint Commission standards on restraint and seclusion, many of which fall closely with the CMS Conditions of Participation.

Learning Objectives:-

  • Recall that CMS requires all physicians and others who order restraints be educated on the hospital policy.
  • Describe how CMS has restricted education requirements for staff.
  • Discuss that CMS has specific things that need to be documented in the medical record for the one-hour face-to-face evaluation of patients who are violent and or self-destructive.
  • Define the CMS restraint requirement of what a hospital must document in the internal log if a patient dies within 24 hours with two soft wrist restraints on.

Detailed Agenda:-

  • Restraints in the news
  • Introduction to CoP Manual
  • Deficiencies – restraints and seclusion
  • Complaint manual and process
  • Conditions of Participation
  • Seclusion – what it is and is not
  • Medical restraints
  • Behavioral health restraints
  • Definition of restraint and seclusion
  • Reasons to restrain
  • Leadership responsibilities
  • Falls and use of restraints
  • Drugs used as a restraint
  • What restraints do not include
  • Side rails, forensic restraints, freedom splints, immobilizers
  • Patient assessment
  • Need order ASAP
  • Order from LP and notification to attending physician
  • Documentation requirements
  • Least restrictive requirements
  • RNs and One-hour face-to-face assessment
  • Training for RN doing one-hour face-to-face assessment
  • Training requirements
  • Ending at the earliest time
  • Revisions to the plan of care
  • Time-limited orders
  • Renewing orders
  • Provider training
  • Staff education
  • First aid training required
  • Monitoring of patients in R/S
  • Death reporting requirements
  • Joint Commission standards

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
  • Chief Risk Officer
  • PI director
  • Joint Commission coordinator
  • Nurse managers
  • Quality director
  • Chief medical officer
  • Security guards
  • Accreditation and regulation staff and others responsible for compliance with hospital regulations
  • Anyone involved in the restraint or seclusion of patients.
  • Any staff member who could remove/apply restraints as part of care.

Know Your Presenter

Laura A. Dixon recently served as the Regional Director of Risk Management and Patient Safety for Kaiser Permanente Colorado, providing consultation and resources to clinical staff. Prior to joining Kaiser, she served as the Director of Facility Patient Safety and Risk Management and Operations for COPIC from 2014 to 2020. In her role, Ms. Dixon provided patient safety and risk management consultation and training to facilities, practitioners, and staff in multiple states. Such services included creating presentations on risk management topics, assessing healthcare facilities, developing programs, and compiling reference materials that complement physician-oriented products.

Before joining COPIC, she served as the Director, of the Western Region, Patient Safety and Risk Management for The Doctors Company, Napa, California. In this capacity, she provided patient safety and risk management consultation to the physicians and staff in the western United States. Ms. Dixon’s legal experience includes medical malpractice insurance defense and representation of nurses before the Colorado Board of Nursing.

Ms. Dixon has over twenty years of clinical experience in acute care facilities, including critical care, coronary care, peri-operative services, and pain management.

As a registered nurse and attorney, Laura holds a Bachelor of Science degree from Regis University, RECEP of Denver, a Doctor of Jurisprudence degree from Drake University College of Law, Des Moines, Iowa, and a Registered Nurse Diploma from Saint Luke’s School Professional Nursing, Cedar Rapids, Iowa. She is licensed to practice law in Colorado and California.