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Hello everyone-
Sorry Peter, I know you requested that the conversation end, but I do
feel that discussing these issues adds to the quality of care that we
all provide so I would like to forward my thoughts as well.
I have spoken with the Board of Nursing recently as we have had
questions about teaching our CRMA's g-tube medication administration.
The clear response that I got from them is that the state regulations
need to specifically acknowledge that the RN may teach g-tube med.
administration. If this is not written in the regulations or written
specifically into the CRMA syllabus, they do not recognize it as a skill
that RN's may teach unlicensed personnel.
Again, I think these conversations are healthy and will help assure
that those in our care get what they deserve-the very best we have to
offer.
Cyndi Ranco, RN
Casa, Inc.
-----Original Message-----
From: Mauro, Peter [mailto:Peter.Mauro@maine.gov]
Sent: Tuesday, December 14, 2004 4:20 PM
To: 'Kathleen Bernard'; Mauro, Peter; 'Darlene';
Beas-crma@lists.state.me.us
Subject: RE: beas-crma Fw: sub-cutaneous injections
-----Original Message-----
From: Kathleen Bernard [mailto:voodoosgirl@midmaine.com]
Sent: Monday, December 13, 2004 10:19 PM
To: Mauro, Peter; 'Darlene'; Beas-crma@lists.state.me.us
Subject: Re: beas-crma Fw: sub-cutaneous injections
[Mauro, Peter]
As the Director of Assisted Living Licensing, CRMAs, who
are governed by the former DHS, are allowed by regulation to be taught
procedures by RNs. This is covered in Section 7 of the regulations.
Coordination and oversight is also covered under the BON chapter 6 which
was designed for Assisted Living and Residential Care. I stand on my
answer from before that we are not requiring that all RNs teach CRMAs
these procedures. There are RNs out there who feel this is acceptable
and some do not. If the provider wants to pay the home health agency or
an outside RN or employ an RN, that is up to the provider.
This discussion needs to end as it is going no where. I
believe I have made my position clear.
Hello Everyone-how come we're all alarmed by this, but
Peter and Carol think it's ok. Just wondering....[Mauro, Peter] One
should not assume what alarms Carol or myself.
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? [Mauro, Peter] No
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
<mailto:Peter.Mauro@maine.gov>
To: 'Darlene' <mailto:Dgrass@gwi.net> ;
'Kathleen Bernard' <mailto:voodoosgirl@midmaine.com> ;
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
<mailto:voodoosgirl@midmaine.com>
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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