Quarterly Risk Management Tip
Mandated CPR Staff Training
The CMS has revised surveyor guidance in Appendix PP of the State Operations Manual (SOM) under F155 to clarify Cardiopulmonary Resuscitation (CPR) policies for nursing homes. Facilities must not implement a facility-wide "no CPR" policy, as this policy may prevent implementation of a resident's advance directives and does not meet professional standards of quality as required in §483.20(k). The American Heart Association (AHA) publishes guidelines every five years for CPR and Emergency Cardiovascular Care. These guidelines for CPR provide the standard for the American Red Cross, state Emergency Medical Services, healthcare providers, and the general public.
If a resident experiences a 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 order; and
- If the resident does not show obvious signs of clinical death.
Prompt initiation of CPR is essential, as brain death begins four to six minutes following cardiac arrest if CPR is not initiated within that time.
Additionally, CPR certified staff must be available at all times. Staff must maintain current CPR certification for healthcare providers through a CPR provider whose training includes hands-on skills practice and in-person assessment and demonstration of skills; online only certification is not acceptable because proper technique should be evaluated by an instructor through in-person demonstration of skills. CPR certification, which includes an online knowledge component, as well as in-person skills demonstration to obtain certification or recertification, is acceptable.
Please note, this memo does not specifically address which staff must maintain CPR certification. Upon questioning, the CMS expects that facility policy would address this issue. In developing this policy, facilities should consider healthcare industry standards of practice, state laws and regulations, the needs of their residents and characteristics of their facility. It is unlikely that having only one CPR staff member per shift for an entire facility would permit prompt initiation of CPR.