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

Restraint and seclusion practices are areas of significant scrutiny by both the Centers for Medicare & Medicaid Services (CMS) and the Joint Commission, often leading to hospitals being cited for non-compliance. Understanding and adhering to these standards is critical for ensuring patient safety and regulatory compliance. In this webinar, industry expert Laura A. Dixon, BS, JD, RN, CPHRM, will provide valuable insights into navigating these complex regulations and avoiding common pitfalls associated with restraint and seclusion.

CMS has issued a comprehensive fifty-page document detailing interpretive guidelines for hospitals on restraint and seclusion. These guidelines are mandatory for all hospitals that accept Medicare patients, regardless of their accreditation status with the Joint Commission, HFAP, CIHQ, or DNV Healthcare. The guidelines cover various aspects of restraint and seclusion, emphasizing the importance of proper training and ongoing education for healthcare providers.

Physicians and other providers who are authorized to order restraints must be thoroughly trained in the hospital's policies. Both CMS and the Joint Commission mandate that hospital staff receive annual education on the interpretive guidelines for restraint and seclusion. This training is not a one-time requirement but must be ongoing to ensure that staff are continually up to date on the latest standards and practices. CMS specifically requires that training occur before a staff member or provider is permitted to apply or remove restraints, with ten pages of the guidelines dedicated to outlining these training requirements.

Additionally, the webinar will explore how the Joint Commission’s standards on restraint and seclusion closely align with CMS Conditions of Participation. Laura A. Dixon will provide an overview of these standards, helping attendees understand the connections between CMS guidelines and the Joint Commission’s requirements. This session is essential for healthcare professionals committed to ensuring that their facilities comply with these stringent standards, ultimately improving patient care and reducing the risk of non-compliance.

Webinar Objectives

• Recall that CMS requires that all physicians and others who order restraints 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 on 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 having two soft wrist restraints on.

Webinar 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 RN doing one-hour face to face assessment
• Training requirements
• Ending at earliest time
• Revisions to the plan of care
• Time limited orders
• Renewing orders
• Provider training
• Staff education
• First aid training required
• Monitoring of patient in R/S
• Death reporting requirements
• Joint Commission standards

Who Should Attend

• All nurses with direct patient care
• Compliance officer
• Chief nursing officer
• Chief of medical staff
• COO
• Nurse Educator
• ED nurses
• ED physicians
• Medical staff coordinator
• Risk manager
• Patient safety officer
• Chief Risk Officer
• PI director
• Joint Commission coordinator
• Nurse managers
• Quality director
• Chief medical officer
• Security guards
• Accreditation and regulation staff and others responsible for compliance with hospital regulations
• Anyone involved in the restraint or seclusion of patients.
• Any staff that could remove/apply restraints as part of care