US · guidance
CMS SOM App. A, Tag A-0957
§482.51(b)(4) - There must be adequate provisions for immediate post-operative
care.
Interpretive Guidelines §482.51(b)(4)
Adequate provisions for immediate post-operative care means:
• Post-operative care must be provided to all surgical patients, including same-day surgery patients, in accordance with acceptable standards of practice.
• A post-operative care area, usually referred to as the post-anesthesia care unit
(PACU), is a separate area of the hospital. Access is limited to authorized
personnel.
• Policies and procedures specify transfer requirements to and from the PACU.
Depending on the type of anesthesia and length of surgery, the post-operative
check before transferring the patient from the PACU includes, but is not
limited to:
o Level of activity;
o Respirations;
o Blood pressure;
o Level of consciousness;
o Level of pain;
o Patient color; and
• If a patient is not transferred to the PACU, determine that provisions are made
for close observation until the patient has regained consciousness, e.g., direct
observation by a qualified RN.
Post-operative Monitoring
Hospitals are expected to develop and implement policies and procedures addressing the
minimum scope and frequency of patient monitoring in post-PACU care settings,
consistent with accepted standards of practice.
Patients receiving post-operative intravenous (IV) opioid medications are of particular
concern, due to the higher risk for oversedation and respiratory depression
7F
8. Once out of
the PACU, patients receiving IV opioid medication may be placed on units where vital
signs and other monitoring traditionally has not been done as frequently as in the PACU
or intensive care units, increasing the risk that patients may develop respiratory
compromise that is not immediately recognized and treated. (See the interpretive
guidelines at §482.23(c)(4)). When post-surgical patients are transferred out of the
PACU to another area of the hospital but continued on IV opioid medications, they need
vigilant monitoring, even if post-PACU care is not typically referred to as “immediate”
post-operative care. Opioid- induced respiratory compromise has resulted in inpatient
deaths that might have been prevented with appropriate assessment and vigilant
monitoring of respiration and sedation levels.
8F
9
Survey Procedures §482.51(b)(4)
• Verify that the hospital has provisions for post-operative care.
• Observe care provided to patients in a PACU to determine whether patients
See for example: 8 Institute for Safe Medication Practices (ISMP), Medication Safety Alert - High Alert
Medication Feature Reducing Patient Harm from Opiates. February 22, 2007.
9 Institute for Safe Medication Practices (ISMP), Medication Safety Alert – Fatal PCA Adverse Events
Continue to Happen…Better Patient Monitoring is Essential to Prevent Harm. May 30, 2013
are monitored and assessed appropriately prior to transfer or discharge (in the
case of same-day surgery patients) from the PACU.
• Does the hospital have a system for identifying and addressing the monitoring
needs of post-operative patients transferred from the PACU to other areas of
the hospital?
• Ask staff in the PACU and in units who receive patients from the PACU how
the needs of post-operative patients for vigilant monitoring is addressed when
the patients are transferred from the PACU to other areas of the hospital.
History
Rev. 116, I ssued: 06-06-14 Effective: 06-06-14, Implementation 06-06-14
Provenance
- Source
- cms.gov
- Retrieved
- 2026-07-22
- Edition
- som-2026-07-22
- Content hash
bc5f7d512f6f7667d3888260b094d78548a6a56be7c4abfab8b872fac0a100ec
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