F678—CPR Appendix PP Revisions

F678—CPR Appendix PP Revisions

CMS revisions to F 678 Cardiopulmonary Resuscitation were significant in bringing the regulations to align with current nationally accepted standards for CPR training. Here’s what you need to know to bring your training and policies and procedures up to date…

In regulatory grouping §483.24(a)(3) in Appendix PP we find the requirement that facility personnel must “provide basic life support, including CPR, to a resident requiring such emergency care prior to the arrival of emergency medical personnel and subject to related physician orders and the resident’s advance directives”. This requirement now states “Staff must maintain current CPR certification for Healthcare Providers through a CPR provider whose training includes a hands-on session either in a physical or virtual instructor-led setting in accordance with accepted national standards. Surveyors must make the determination whether the facility ensured that the “staff maintain current CPR certification for healthcare providers in accordance with the accepted national standards through a CPR provider whose training includes hands-on practice and in-person skills assessment”.

The Facility CPR policies should include the following:

• • Training of staff to initiate CPR when cardiac or respiratory arrest occurs for residents who do not show obvious clinical signs of irreversible death and:
    • Who have requested CPR in their advance directives, or
    • Who do not have a valid DNR order.
  • Ensuring staff receive certification in performance of CPR (CPR for Healthcare Providers).
    • CPR-certified staff must always be available to provide CPR when needed.
    • Staff must have CPR certification for Healthcare Providers, which must include hands-on practice and in-person skills assessment.

The American Health Care Association has a “Tip Sheet” that provides the following advice for LTC facilities:

1. Add CPR booster training to your routine staff education. The tip sheet states that the American Heart Association (AHA) notes “there is substantial evidence that BLS skills significantly decline after training at 6 months”, and therefore frequent ‘booster’ training is very beneficial for the staff.
2. Conduct semi-annual CPR drills across all shifts. Just like other drills done in the facility such as fire drills, elopement drills, etc, CPR drills can promote staff readiness when CPR is indicated, and can serve as a form of “booster” training. Using a facility CPR drill form can provide the necessary observation information to use as part of the QAPI Committee review of the facility CPR preparedness.
3. Establish a routine to verify staff have the necessary certification to ensure CPR readiness across all shifts, which includes the physical or virtual instructor observed staff hands-on practice and in-person skills assessment. The AHCA recommends quarterly reviews of this information

By ensuring staff receive CPR training in accordance with acceptable national standards, and by doing “booster” training for the staff, including CPR drills, the facility can ensure staff are prepared to respond to cardiac or respiratory emergencies effectively, reduce the risk of deficiencies in F678, and the risk of CPR related long term care litigation.

Next Steps:

1. Maintain year-round survey readiness with the Survey Ready Toolkit—created to guide facilities to deficiency free surveys and schedule a mock survey with Proactive.
2. Ensure policy and procedure compliance for all of the Appendix PP Revisions with Proactive’s resource package now available in the Solutions Center!
3. Join us beginning August 27 for the new webinar series Survey Prep & Understanding Post-Survey Elements

Written By: