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Hello Everyone-how come we're all alarmed by this, but Peter and Carol think it's ok. Just wondering....
Peter, when you say "we have allowed the epi to not only cover bee stings but other issues requiring that med." are you talking about the Lovenox?
Lovenox is a low molecular weight heparin, given for its anticoagulation effect on blood pre and post surgury. It has extensive contraindications and precautions and its life-threatening side effect is hemorrhage.
Epinephrine is in the Epi-pen, it is used as a bronchodilator managing severe allergic reactions. Contraindications and precautions are fewer and there are no life-threatening side effects from the med.
Insulin is a hormone used to treat diabetes. There are very few contraindications, precautions and adverse side effects. The life-threatening side effect is hypoglycemia.
So, all 3 meds are given subcutaneously and that is about the only thing they have in common. The method of injection is not the issue. Patient safety is the issue. A monkey can give a SC injection, but the monkey can't keep the patient safe afterwards. (no offense to the CRMA's)
This is the email I received at work from the director of the home health division that was denied payment:
"I just heard back from Lorraine LaChappelle at BEAS re: the meeting last week that looked at CRMA curriculum. In that meeting Lorraine brought up the Lovenox issue and the licensing regs governing level IV group homes. They acknowledged that section 7.1.2 and 7.1.3 allow for unlicensed personnel to administer insulin and bee sting kits only. They feel however, that because Lovenox is a SQ medication and administered by the same technique that it could be administered by a CRMA with proper training per sections 7.16 and 7.17 of those same regs. Also, they looked at Chapter 6 of the BON regs re:teaching an unlicensed person. She said if the group home continued to have concerns they should call Peter Mauro."
What ever happened to the delegation decision tree? If the task is within the RN's scope of practice and NOT within the scope of practice of the UAP then we can not delegate the task. So if one RN decides to delegate and another RN decides to protect her patient and her license and NOT delegate, the agency is punished financially if we choose patient safety.
The payment issue for MaineCare is NOT the same issue as the CRMA doing this type of task. It is one thing to say the fee is "built into" the rate so the home takes the hit when a nurse is needed. It is another thing to say we can teach unlicensed people tasks that are beyond their training. If they want to be nurses, let them go to school and get the degree, license and debt, like the rest of us.
I realize the BON participated to some extent in the regs but I would like to present the specifics of how the regs are being interpreted to see what they think. Anyone have a best friend on the Board?
I keep wondering if the private-pay assisted living homes are delegating nursing tasks.
Kathleen
----- Original Message -----
From: Mauro, Peter
To: 'Darlene' ; 'Kathleen Bernard' ; Beas-crma@lists.state.me.us
Sent: Monday, December 13, 2004 3:11 PM
Subject: RE: beas-crma Fw: sub-cutaneous injections
Even though the regs are specific about insulin and bee sting, we have allowed the epi to not only cover bee stings but other issues requiring that med. Also, at the end of section 7 there is a section which was designed from the BON in their chapter 6 on coordination and oversight, to take care of other issues that might come up that would allow RNs to teach unlicensed personnel. DHHS/BEAS does not dictate that all RNs do this teaching, but if they feel that the person is competent to learn and competent to carry through, then they can. Also, DHHS/MaineCare is not going to double pay the services of homehealth when there is a portion built into the rate for Nurse services. Those facilities that want to train CRMAs to do some of those procedures, can, those who want to hire a nurse and pay them out of the daily rate to do some of those other services can do that. As licensing moves towards being merge red into one unit, perhaps some of this can and will be looked at. Carol and I have looked at all inquiries that providers have had and we deal with over 800 freestanding facilities, to help alleviate some of these issues.
-----Original Message-----
From: owner-beas-crma@lists.state.me.us [mailto:owner-beas-crma@lists.state.me.us]On Behalf Of Darlene
Sent: Monday, December 13, 2004 10:40 AM
To: 'Kathleen Bernard'; Beas-crma@lists.state.me.us
Subject: RE: beas-crma Fw: sub-cutaneous injections
Kathleen, I also read the regs as specific to allowing CRMA's to administer sc insulin and bee sting kits after RN instruction. Anything further in my opinion, is asking too much from our CRMA's. What does Peter say about this matter?
Darlene Grass RN
Granite Hill Estates
-----Original Message-----
From: owner-beas-crma@lists.state.me.us [mailto:owner-beas-crma@lists.state.me.us]On Behalf Of Kathleen Bernard
Sent: Friday, December 10, 2004 11:59 PM
To: Beas-crma@lists.state.me.us
Subject: beas-crma Fw: sub-cutaneous injections
----- Original Message -----
From: Kathleen Bernard
To: Beas-crma@lists.st.me.us
Sent: Friday, December 10, 2004 7:50 AM
Subject: sub-cutaneous injections
Hi Everyone,
I would like to get your feedback on a recent dilemma. I cover 6 group homes under the assisted living regs, PNMI and BDS. One home is a level IV assisted living home but serves adults with mental illness. We have CRMA's, one LPN that coordinates appointments and works M-F days.
We needed home health to provide evening SC lovenox which they did but Medicaid denied their payments. The Medicaid folks feel that CRMA's can administer this SC medication because the assisted living regs state SC insulin is ok so the assumption is that SC anything is ok.
Is anyone aware of CRMA's giving anything but bee sting and insulin injections? The CRMA course seems specific, as do the regulations....bee sting and insulin with instruction from an RN and not part of the CRMA course itself.
Through the many levels of conversations about this subject Peter Mauro's name was mentioned. It is unclear to me at this point what details were presented to him.
Thanks for any help and guidance.
Kathleen Bernard RN,BC
Community Health and Counseling/Bangor
947-0366 x452
the email is my home, I don't have work email
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