CMS 2018 Hospital Restraint and Seclusion: Navigating the Most Problematic CMS Standards and Proposed Changes

Prepare for CMS’s Restraint and Seclusion Guidelines for 2018

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. CMS issued a memo summarizing all of the deficiencies against hospitals which is updated quarterly. Did you know that the number one area of deficiencies in the CMS CoP is regarding restraints?

CMS has issued interpretive guidelines on restraint and seclusions for hospitals. Does your staff understand all 50 pages of the CMS interpretive guidelines? Did you know that both CMS and Joint Commission require hospital staff to be educated on restraint and seclusion interpretive guidelines? CMS says that restraint training must be on-going so you can’t just provide training at orientation and forget about it. Did you know any physician or provider who orders restraint must be trained in the hospital’s policy? Did you know that CMS has ten pages of training requirements? If a CMS surveyor showed up at your hospital tomorrow would you be prepared? The restraint policy is one of the hardest to write and understand in healthcare today.

Every hospital that accepts Medicare patients will have to comply with the interpretive guidelines even if the hospital is accredited by the Joint Commission, HFAP, CIHQ, or DNV Healthcare. Hospitals will need to make sure their policies and procedures comply with these. Joint Commission and CMS both require that you provide restraint training to staff. There is also a requirement that physicians and anyone who writes an order for restraints will have to be educated on the hospital’s policy.

The guidelines explain the training requirements for the RN doing the one hour face to face visits for patients who are violent and/or self-destructive. There are basically 21 rules covered by the CMS interpretive guidelines. The Joint Commission standards on restraint and seclusion will be reference and are now closer in the crosswalk. Patient safety is at risk and patients have been injured or have died from improper restraint usage.

Join this session, where medico-legal consultant Sue Dill Calloway will discuss the most problematic standards in the restraint section. Sue will discuss the proposed changes to restraints published in the hospital improvement rule.

This session 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 also include what must be documented in the medical record. The session will discuss the reporting requirements for patients who die in restraints and within 24 hours of being in a restraint.

The session will simplify and take the mystery out of the 50-page restraint and seclusion interpretive guidelines. It will provide a crosswalk to the Joint Commission standards. Avoid the restraint nightmare now and take the mystery out of these confusing regulations with this session.

Session Highlights

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

Session Outline

In this session, you will learn about:

• Right to be free from restraint
• Number of deficiencies
• Providing copy of right to patients
• Restraint protocols
• Proposed changes in the hospital improvement rule
  • PA to order and change from LIP to LP
• CMS deficiency reports
• CMS changes effective to internal log and soft wrist restraints
• Most current manual
• 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
• Learning from each other
• What 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 one hour face to face assessment
• New training requirements
• New death reporting requirements
• Ending at earliest time
• Revisions to the plan of care
• PI requirements
• Time limited orders
• Renewing orders
• Staff education
• First aid training required
• Stricter state laws
• Monitoring of patient in R/S
• Joint Commission hospital restraint standards and differences from CMS

Who Should Attend

• All nurses with direct patient care
• Compliance officers
• Chief nursing officers
• Chief of medical staff
• COOs
• Nurse educators
• ED nurses
• ED physicians
• Medical staff coordinators
• Risk managers
• Patient safety officers
• Senior leadership
• Hospital legal counsel
• Chief risk officers
• PI directors
• Joint Commission coordinators
• Nurse managers
• Quality directors
• Chief medical officers
• Security guards
• Accreditation and regulation staff and others responsible for compliance with hospital regulations and anyone involved in the restraint or seclusion of patients
• People responsible for rewriting the hospital policies and medical staff bylaws, also includes staff that remove and apply them as part of their care such as radiology techs, ultra sound technologists, transport staff, and others

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