CMS SOM App. M, Tag L858

- The hospice 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.

(ii) The use of nonphysical intervention skills.

(iii) Choosing the least restrictive intervention based on an individualized

assessment of the patient’s medical, or behavioral status or condition.

(iv) The safe application and use of all types of restraint or seclusion used

in the hospice, including training in how to recognize and respond to

signs of physical and psychological distress (for example, positional

asphyxia).

(v) Clinical identification of specific behavioral changes that indicate that

restraint or seclusion is no longer necessary.

(vi) Monitoring the physical and psychological well-being of the patient

who is restrained or secluded, including but not limited to, respiratory

and circulatory status, skin integrity, vital signs, and any special

requirements specified by hospice policy associated with the 1-hour face-to-face evaluation.

(vii) The use of first aid techniques and certification in the use of

cardiopulmonary resuscitation, including required periodic

recertification.

Interpretive Guidelines §418.110(o)(2)

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

assess, or otherwise provide care for patients in restraint or seclusion.

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

safety of the patient and others. The hospice is expected to provide education and

training at the appropriate level, to the appropriate staff, based upon the specific needs of

the patient population(s) being served.