CMS Hospital Restraint and Seclusion 2024 Updates : Navigating the Most Problematic CMS Standards

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Restraint and Seclusion is a hot spot with both CMS and the Joint Commission and an area where hospitals are frequently cited as non-compliance. This program will discuss this most problematic standard.
CMS has fifty pages of interpretive guidelines on restraint and seclusions for hospitals. Every hospital that accepts Medicare patients will have to comply with the regulations even if accredited by the Joint Commission, HFAP, CIHQ, or DNV Healthcare.
Any physician or provider who orders restraint must be trained in the hospital’s policy. Both CMS and Joint Commission require hospital staff to be educated on restraint and seclusion interpretive guidelines on an annual basis. CMS also says that restraint training must occur before a staff member/provider can apply or remove restraints and must be ongoing so it cannot occur at orientation only. There are ten pages of training requirements.
Finally, this program will briefly cover The Joint Commission standards on restraint and seclusion, many of which fall closely with the CMS Conditions of Participation.
Learning Objectives:-
Recall that CMS requires all physicians and others who order restraints to be educated on the hospital policy.
Describe that CMS has restraint education requirements for staff.
Discuss that CMS has specific things that need to be documented in the medical record for the one-hour face-to-face evaluation of patients who are violent and or self-destructive.
Define the CMS restraint requirement of what a hospital must document in the internal log if a patient dies within 24 hours with two soft wrist restraints on.
Agenda:-
Restraints in the news
Introduction to CoP Manual
Deficiencies - restraints and seclusion
Complaint manual and process
Conditions of Participation
Seclusion - what it is and is not
Medical restraints
Behavioral health restraints
Definition of restraint and seclusion
Reasons to restrain
Leadership responsibilities
Falls and use of restraints
Drugs used as a restraint
What restraints do not include?
Side rails, forensic restraints, freedom splints, immobilizers
Patient assessment
Need order ASAP
Order from LP and notification to attending physician
Documentation requirements
Least restrictive requirements
RNs and One-hour face-to-face assessment
Training for RNs doing the one-hour face-to-face assessment
Training requirements
Ending at the earliest time
Revisions to the plan of care
Time-limited orders
Renewing orders
Provider training
Staff education
First aid training is required
Monitoring of patients in R/S
Death reporting requirements
Joint Commission standards
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