CMS SOM App. A, Tag A-0944

room. In accordance with applicable State laws and approved medical staff policies and

procedures, LPNs and surgical technologists may assist in circulatory duties under the

supervision of a qualified registered nurse who is immediately available to respond to

emergencies.

Interpretive Guidelines §482.51(a)(3)

The circulating nurse must be an RN. An LPN or surgical technologist may assist an RN in

carrying out circulatory duties (in accordance with applicable State laws and medical-staff

approved hospital policy) but the LPN or surgical technologist must be under the supervision of

the circulating RN who is in the operating suite and who is available to immediately and

physically respond/intervene to provide necessary interventions in emergencies. The supervising

RN would not be considered immediately available if the RN was located outside the operating

suite or engaged in other activities/duties which prevent the RN from immediately intervening

and assuming whatever circulating activities/duties that were being provided by the LPN or

surgical technologist. The hospital, in accordance with State law and acceptable standards of

practice, must establish the qualifications required for RNs who perform circulating duties and

LPNs and surgical technologists who assist with circulating duties.

Survey Procedures §482.51(a)(3)

• If LPNs and surgical technologists (STs) are assisting with circulating duties, verify that

they do so in accordance with applicable State laws and medical-staff approved policies

and procedures.

• Verify in situations where LPNs and STs are permitted to assist with circulating duties

that a qualified RN supervisor is immediately available to respond to emergencies.

• Verify that RNs working as circulating nurses are working in accordance with applicable

State laws and medical-staff approved policies and procedures.