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I am finding these discussions fascinating and appreciate hearing
others' opinion on this most important matter. Although I am not the RN
trainer for my Assisted Living sites, I do oversee the overall
operation, including what services can safely be provided, and what the
limitations, expectations and liability will be to not only our staff,
but to our agency as well. Although the Dept. has gotten increasingly
lenient in rule as to what services are now allowed in our non-nursing
model, we are still all faced with the limited revenue to provide a
much higher level of nursing which is now becoming the expectation that
we provide because MaineCare will not cover a needed home health
component. In many state-funded Residential Cares or Assisted Living
projects, nursing staff is limited, and surely spread thin. This seldom
allows for the ongoing assessment and observation that seems implied by
the statute/ definition of "limited nursing oversight".
In a non-medical model, we struggle every year to remain insured (as
required), have seen liability rates increase 700%, and now have very
few options to fall back on in the State of Maine. All insurance
companies are taking a very close look at what types of medication
programs and nursing services are being offered in these AL/Res Care
sites, and injectibles start to really cross the line.
I do hope there are more "conversations" at the state level and with all
stakeholders on "limitation of services ", as much more work needs to be
done in this area. (not to mention the growing area of narcotic use)
Deb
-----Original Message-----
From: owner-beas-crma@lists.state.me.us
[mailto:owner-beas-crma@lists.state.me.us] On Behalf Of Kathleen Bernard
Sent: Monday, December 13, 2004 11:05 PM
To: Djgam100@aol.com; Dgrass@gwi.net; Beas-crma@lists.state.me.us
Subject: Re: beas-crma Fw: sub-cutaneous injections
No one is "dunning" the regulators. If we can't have an open and honest
discussion among our peers, then we might as well get in the branding
line. Just because they are "regulators" doesn't make them right about
any of this. Personally, I want to be consulted before I am told I
"have" to do something that I feel is not safe.
Nursing isn't stagnant, it is fluid, it requires thought, debate,
critical thinking, creativity and sometimes hard words said with
respect, but said none-the-less.
It is easy to say it us up to the individual nurse to decide what to
teach, but that is not true. Ultimately, it is up to Mainecare and the
"regulators" because they decide what they will pay for and what they
will allow. We, as nurses, have to protect the patient and the
profession. The more you teach others, the more they will be allowed to
do. When does it stop? Do you want your family taken care of by a nurse,
or by UAP's who know how to do a task but don't know what to look for,
how it all comes together, and how to avoid the unpredictable.
I have tremendous respect for the CRMA's that I teach and that work for
me. I support them completely. They are competent and capable, but they
are not licensed and I will not jeopardize the client, the CRMA or
myself by expecting too much from them.
As we quote regulations, keep in mind the Assisted Living regs and the
BON regs that say we cannot delegate assessment. Giving heparin requires
assessment.
Kathleen
----- Original Message -----
From: Djgam100@aol.com
To: Dgrass@gwi.net ; voodoosgirl@midmaine.com ;
Beas-crma@lists.state.me.us
Sent: Monday, December 13, 2004 10:26 PM
Subject: Re: beas-crma Fw: sub-cutaneous injections
Hi all.
Kathleen,
I have read the regs and chapter 6 of the BON regs. I find it peculiar
that although the regs specifically state Insulin and Bee Sting Kits
that a number of instructors refer to epi pens as an injection that
CRMA's can give. Epi pens are not stated in the regs., only Bee Sting
Kits.
7.1.2 No injectable medications may be administered by an unlicensed
person, with the exception of bee sting kits and insulin.
7.1.3 Before using a bee sting kit, unlicensed persons must be trained
by a registered professional nurse in regard to safe and proper use.
Documentation of training shall be included in the employee record.
note that there is no mention of epi pens in this reg, but nurses teach
CRMA's to administer them.
7.16 Whenever a Registered Nurse teaches or provides in-service
training to unlicensed personnel on medical issues, treatments and/or
medical equipment not specifically outlined in these Regulations, there
must be documentation in the employee file.
The above regulation implies to me that the RN can provide in service
training to unlicensed persons that is not stated specifically in these
regulations inclusive of the administration of other SC injections.
Going along with the BON chapter 6, if the resident/client/consumer is
stable on the medication and the CRMA(s) have proven competency in
administering SC insulin why should they not be allowed to administer
other medications SC? Levonox is available in pre filled syringes to
take the guess work out of the amount to be administered and is probably
safer than administering Insulin. An SC injection is an SC injection
regardless of what the medication is. If the CRMA is taught to do one,
I see no difference in another just because it is a different medication
being injected.
I also understand that if, as RN's we are not comfortable with teaching
the CRMA to do this, we do not have to. We as RN's , when working in
Home Health, teach family members to do more complicated procedures and
administer more dangerous meds and these family members, for the most
part, have not training whatsoever previous to our instruction. I think
that CRMA's, with the new Standardized Curriculum are better able to
give an SC injection than ever before.
We need to give the CRMA's the credit they deserve for the knowledge
that we have imparted on them throughout our teaching and use our own
judgement in what we teach them after they are trained as CRMA's.
I also feel that instead of dunning the regulators that we should work
with them in a constructive manner as opposed to always throwing dig at
them. It never ceases to amaze me that we cannot ever seem to ask
questions or reply to questions from others without dunning the
regulators for trying to keep the services provided under them safe and
affordable.
Don
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