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Hi Suzy:
Your question seems based upon what you feel eticial/
comfortable providing versus what is okay per regulations.
1. Per law and profession ethics both, OTs, PTs or
SLPs may not delegate tasks to aides/ assistants that are beyond their
scope of practice/ training levels
2. The therapists themselves should not accept tasks that
they are not adeqautely skilled for, or feel uncomfortable about
3. It is okay for you or any PT/OT/ OTA/ PTA to train aides to
perform simple, routine tasks that do not require their judgment in delivery of
such services
4. Aides must be trained for the job that they are delegated.
Training usually is done with an initial orientation and on a per patient
basis.
5. Per OBRA, it is the responsibility of the SNF to ensure
optimal physical and mental functioning of their residents. Hence, whether or
not they are reimbursed for restorative services (e.g. counting towards the
case-mix to determine medicaid rates/ routine costs), it is not optional for
nursing homes whether or not to provide these services (may be called different
names). They must provide them when appropriate. It must be done under the
technical supervision of nursing for states that pay for such services, but
either way periodical training may be provided by a therapist. While the
'administrative' supervision can be provided by a therapist, all the notes/ poc/
reviews must be signed by an RN for it to be accounted as a qualified service
under MDS.
6. Please note that the terminology restorative therapies (per
medicare) means OT/PT/SLP services provided by or under the supervision of a
licensed therapist of the respective disciplines. This should not be confused
with the generally used term 'restorative therapy' which is more correctly
'restorative nursing' as it must be under a nursing POC in SNFs. I would
also be concerned if restorative aides or restorative techs/ rehab
aides are called restorative therapists in the nursing home you are
referring to. There certainly is a lot of difference to what the title
implies to.
7. Restorative nursing services are usually provided to
maintain/ ensure optimal functional independence that do not need the skills of
a therapist on a regular basis. The program is such that it expects improvement
or maintainence of status, that would otherwise not be possible if the resident
does not receive such services. You are right, if there is a non
self-limiting change of status with the client's functioning/ safety/ joint
congruity/ skin integrity, the skills of the therapist are probably required to
assess and provide active therapy.
Ofcourse, your line of action will thus, depend upon your own
professional judgment upon what you feel comfortable with to delegate, and above
all what the client needs- active skilled intervention or, a referral to
restorative nursing with optimal training provided to the nurse incharge of the
program and the aides providing it, if they are not already trained to
do so. Again, per OBRA the inference is that therapists must provide periodical
screenings in SNFs to ensure optimal functioning/ safety of the residents. Hope
this helps.
Joe
----- Original Message -----
Sent: Saturday, July 12, 2003 1:19
PM
Subject: Re: [OTlist] Three
Questions
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I have been approached by an RN in an SNF to provide sort of a
general overall strengthening and ROM exercises that the
restorative therapists do in that facility even though I do not
supervise what they do or even work with them. I have some
serious reservations about doing this as I'm concerned
about liability if something should go wrong when they are doing a
tx that I have shown them. Typically, the PT on contract will
get a referral and have the restorative therapists perform the
service. That may be an upper or lower extremity exercise
program, then he comes back periodically to review how the patient is
doing. This is primarily a psyc facility and they have no
full time OT or PT. I mainly work in a
state psychiatric facility and the SNF is located on the grounds
and I go see patients periodically for positioning or when there's
a decrease in ADL's. If tx is involved, I always do the
tx. I don't rely on the restorative therapists. I was
told they need to receive "some training" from the PT and the
OT to continue doing their jobs. I'm not sure I feel comfortable
providing that training. Does anyone have opinions about what I
should do? Thanks, Suzy
-------Original
Message-------
Date: Saturday, July
12, 2003 12:04:05 PM
Subject: Re: [OTlist]
Three Questions
----- Original Message -----
Sent: Saturday, July 12, 2003
7:16 AM
Subject: [OTlist] Three
Questions
1st Can
COTA/L do recerts?
No, recertification
(i.e, 701s usually used) is a process involving 'assessment' of
status/ goals and establishing/ re-establishing them along with an
updated plan of treatment. The OTR is responsible for all these
functions, as the physician recertifies the need for continued skilled
services. A COTA/L may assist with the process such as, writing down
demographics and gathering data, however, the regs requires the
OTR to infer, modify and re-establish need for
services.
2nd What
requirements are necessary for a restorative Aide? Either by
the State or by Medicare? A restorative aide is different from a
Tech.
How?
as far as the requirements?
A restorative aide
usually functions based upon a restorative 'nursing' plan of care
that may have been established with the assistance of a therapist;
but again an RN should be signing-off on the POC nad reviewing it
'periodically'. In states that count the restorative programs for
their case-mix index (CMI), e.g., OH & WV, you must be aware
that you must have at least 2 programs run 6 days a week, at least
15 mins each program, each day. I have not come across a written
statement from Medicare or the State (my state OH), where, they
mandate any particular qualification for restorative aides. But
prudently as supervised under a nursing POC technically, they should
be CNAs/ STNAs. Most facilities prefer an CNA with 1 year
experience.
Again to the best of
my knowledge, there are no mandated qualifications by the states or
medicare for techs. either. Hence, it's upto the discretion of the
SNFs. They are different in the sense that a restorative aide
has the prime responsibility to carry out the restorative programs,
and at least technically for the states that have restorative
programs count towards CMI are supervised per a nursing POC. Techs
basically assist therapists to file, clean-up, set-up, provide
non-judgmental/ simple direct care under 'line-of-sight'
supervision of a licensed therapist in states that allow it,
and ofcourse also perform......other duties as assigned!
A restorative
aide may function as a rehab technician as well. Most facilities
require both the restorative and rehab aides to be CNAs. And, in
states that do not count restorative programs towards CMI, I do not
see why a non CNAs/STNAs ( a rehab tech not also certified as a CNA)
can not perform a maintainence program as a rehab aide that is
periodically reviewed by a therapist or nurse.
Joe
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