CMS SOM App. A, Tag A-0199

- The hospital must require appropriate staff to have education,

training, and demonstrated knowledge based on the specific needs of the patient population in at

least the following:

(i) Techniques to identify staff and patient behaviors, events, and environmental factors

that may trigger circumstances that require the use of a restraint or seclusion.

Interpretive Guidelines §482.13(f)(2)(i)

The term “appropriate staff” includes all staff that apply restraint or seclusion, monitor, assess, or

otherwise provide care for patients in restraint or seclusion.

All staff, including contract or agency personnel, designated by the hospital as having direct patient care

responsibilities are required to receive training in the areas of clinical techniques used to identify patient

and staff behaviors, events and environmental factors that may trigger circumstances that require the use

of restraint or seclusion. This training should be targeted to the specific needs of the patient populations

being served, and to the competency level of staff.

Staff needs to be able to employ a broad range of clinical interventions to maintain the safety of the

patient and others. The hospital is expected to provide education and training at the appropriate level to

the appropriate staff based upon the specific needs of the patient population being served. For example,

staff routinely providing care for patients who exhibit violent or self-destructive behavior that

jeopardizes the immediate physical safety of the patient, a staff member, or others (such as in an

emergency department or on a psychiatric unit) generally require more in-depth training in the areas

included in the regulation than staff routinely providing medical/surgical care. Hospitals may develop

and implement their own training programs or use an outside training program. However, standard (f)

specifies that individuals providing staff training must be qualified as evidenced by education, training,

and experience.

Hospitals have the flexibility to develop their own training program to meet the staff training

requirements at §482.13(f) or purchase a training program from the outside. CMS does not specify that

any particular outside vendor must be used to provide the required training. Each hospital must assess

the learning needs and competency of their staff to determine how extensive periodic training and staff

competency demonstration must be subsequent to initial training. The training program must be

provided to all appropriate staff. Any person monitoring or providing care to a restrained patient must

demonstrate the knowledge and abilities required by the regulations.

At a minimum, physicians and other LIPs authorized to order restraint or seclusion by hospital policy in

accordance with State law must have a working knowledge of hospital policy regarding the use of

restraint and seclusion. Hospitals have the flexibility to identify training requirements above this

minimum based on the competency level of their physicians and other LIPs and the needs of the patient

population that they serve.

Survey Procedures §482.13(f)(2)(i):

• Does the hospital educational program include techniques related to the specific patient

populations being served?

• Does the hospital educational program include techniques to identify staff and patient behaviors,

events, and environmental factors that may trigger circumstances that require the use of restraint

or seclusion?

• Does the hospital educational program provide more in-depth training in the areas included in the

regulation for staff members who routinely provide care to patients who exhibit violent or self-destructive behavior (e.g., staff who work in the emergency department or psychiatric unit)?

• Interview staff to assess their knowledge of the restraint and seclusion techniques addressed in

this requirement.