AFL 22-32
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Clearpol's Opinion of this Guidance as of 12/12/2022
Reminds SNFs of the CMS guidance regarding the provision of dialysis services. It also clarified with 3.5 DHPPD requirements, of which a minimum of 2.4 DHPPD must be performed by CNAs.
A dialysis facility may provide dialysis services to SNF residents in the SNF “home” setting, with specific requirements. The AFL provides guidance on this including:
Dialysis Supervision and Administration
The CDC/ERSD facility providing services to a resident in a SNF must ensure:
· Onsite supervision of dialysis by a trained RN whenever a resident is receiving HD in the SNF, and by a trained RN or LVN when a resident is receiving PD treatment in the SNF;
· Qualified/trained dialysis administering personnel must be present in the room and maintain direct visual contact with the resident receiving HD throughout the entire duration of the treatment; and
· SNF nurses may not provide dialysis treatments. Dialysis services must be provided by staff from the CDC/ESRD.
Hemodialysis Treatment Supervision
The CDC/ESRD facility must ensure that a trained supervising RN is constantly present on-site at the SNF and immediately available to respond to concerns or emergencies that may occur during a resident's hemodialysis treatment. The supervising nurse must be present in the general area where the resident(s) are receiving dialysis and readily available. The supervising nurse should not have other duties that may hinder or negatively affect their ability to respond immediately to the needs of the dialysis patient(s).
SNF DHPPD Standards
SNFs must have a minimum number of direct care service hours of 3.5 per patient day. Only direct caregivers shall count toward the 3.5 and 2.4 DHPPD staffing standards. A nurse supervising or participating in the provision of dialysis treatments is not counted in the 3.5 DHPPD.
Clearpol Inc. does not make any guarantees regarding the accuracy of the opinions provided on our platform. Please use your own judgement.
Clearpol's AI Summary
The California Department of Health issued an All Facilities Letter (AFL) reminding skilled nursing facilities (SNFs) and chronic dialysis clinics (CDCs)/end-stage renal disease dialysis facilities (ESRDs) of the Centers for Medicare and Medicaid Services (CMS) guidance on dialysis services. The AFL clarifies the 3.5 Direct Care Service Hours Per Patient Day (DHPPD) requirements, with a minimum of 2.4 DHPPD performed by certified nurse assistants (CNAs). Dialysis services must be provided by staff from the CDC/ESRD, and SNF nurses are not permitted to provide dialysis treatments in California. The CDC/ESRD facility must ensure on-site supervision of dialysis by a trained registered nurse (RN) for hemodialysis and by a trained RN or licensed vocational nurse for peritoneal dialysis treatment. A supervising RN must be constantly present on-site at the SNF and immediately available to respond to concerns or emergencies during a resident's hemodialysis treatment. Direct caregivers count towards the 3.5 and 2.4 DHPPD staffing standards, but a nurse supervising or participating in the provision of dialysis treatments is not counted in the 3.5 DHPPD.
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