Staff CPR requirements for Assisted Living Residences – Department Guidance

 

Inappropriate CPR training/certification is becoming a frequent area of non-compliance/citation on survey   Over the past 2 months, the Department has cited ALRs for non-compliance in this area more than 25 times, primarily for having staff that has training documentation from an organization that is not nationally recognized, with the express concern being documentation from organizations that do not have an observed demonstration of skills (whether in-person or remote) as part of the certification process.   6 CCR 1011-1, Chapter 7, Part 8.7, requires each assisted living residence (ALR) to have staff trained in CPR onsite at all times as follows:   8.7 Each assisted living residence shall have at least one staff member onsite at all times who has current certification in cardiopulmonary resuscitation (CPR) and obstructed airway techniques from a nationally recognized organization such as the American Red Cross, the American Heart Association, the National Safety Council or the American Safety and Health Institute. The certification shall either be in Adult CPR or include Adult CPR.    A completely online course with no hands-on practice and observed skills demonstration does not meet the same level of training as intended by referencing a “nationally recognized organization such as the American Red Cross, the American Heart Association, the National Safety Council or the American Safety and Health Institute.”   Please recognize that a “certificate of completion” is not the same thing as “certification” in the context of Part 8.7. Online-only courses by nationally recognized organizations result in a certificate of completion, NOT certification.   All certifications by nationally-recognized programs require a hands-on component and observed skills demonstration in order to be certified   Performing CPR is a combination of cognitive knowledge and physical skill. Online training is a valid and recognized method of learning the cognitive knowledge related to performing CPR. However, online learning cannot ensure proficiency in the physical skills required to perform CPR. National organizations recognize online learning as legitimate for gaining CPR knowledge, but not as a legitimate way of learning and becoming proficient in the physical skills involved with CPR. This proficiency can only be ensured through hands-on practice and skills testing. This can be gained through an in-person class, or in a hybrid/blended format. For hybrid/blended classes, the student would take the classroom portion of the training online, and then schedule a hands-on session. Hands-on sessions may be provided in person by a provider approved by the individual national organization, or, in some cases, may be done remotely with real-time video observation of the student performing CPR on a mannequin.   A certification card issued by a qualified instructor affiliated with a reputable, recognized training organization is documentary evidence that the holder has demonstrated their skill proficiency.   Note: Blended/hybrid learning is NOT online-only learning. Blended or hybrid learning is a training delivery model that combines online course content with an in-person, hands-on skills evaluation. Online-only training features no hands-on component.   Evaluate online programs carefully:   In speaking with facilities as we are discovering and citing this issue, we are finding some confusion from providers regarding online training sites’ claims. Therefore, we want to provide the following clarifications:   Accredited—there is NO organization that provides nationwide or worldwide accreditation for CPR training. If a website is claiming to be accredited, they may be accredited for something other than providing CPR training. Beware of this claim. (Note: The American Heart Association does authorize training sites and training centers. This authorization is not an accreditation.)   Board Certified—The Colorado State Board of Health does NOT certify agencies. Some CPR training agencies may indeed be “board certified” but look carefully at the board doing the certification—we specifically saw certification from the Florida Board of Massage Therapy, and the National Certification Board for Therapeutic Massage and Bodywork. Please understand that these approvals are not relevant to the ALR setting in Colorado, and do not make a program “nationally recognized.”   Nationally Recognized—Just because an online training program claims it is nationally recognized, does not make it true. If the organization is one that is not specifically included in Chapter 7, Part 8.7, their claims should be carefully scrutinized.    Certified Instructors—The American Heart Association does certify instructors; however, if the instructor is practicing outside of a training center authorized by the American Heart Association, they may or may not be using appropriate standards in teaching the course.   What to avoid when shopping online for training—the following is a non-inclusive list of phrases that indicate the CPR training will not meet the requirements of Part 8.7: Online CPR card, download instantly Download your certification card right after finishing your course No hands-on skills required 100% online Immediate certificate or wallet card Have your card/be certified today Full refund if not accepted Another good way to assess the validity of the training is to look at the wording on the documentation or certification card. For example, “The above individual has successfully completed the cognitive and skills evaluations in accordance with the curriculum of the American Heart Association Basic Life Support (CPR and AED) Program,” indicates compliance with the standards of a nationally recognized organization, whereas “This card certifies that the above individual has successfully completed the requirements in accordance with American Health Care Academy’s curriculum,” does not.   To this point, though some of the national organizations offer online courses, they will issue a “certificate of online training.” This is different than being certified in CPR. All major sponsors of emergency care training have a credible and documented process designed to ensure that instructors only issue certification cards following hands-on training and practical skills assessment.   If an online program does not include hands-on practice and observed skills observation, CPR training from that provider will not meet the requirement of Chapter 7, Part 8.7. If you have any questions about whether a particular training program/certification will meet the Part 8.7 standard, please contact the department for guidance.   Waivers may be available for CPR training/certification from a non-nationally recognized organization   If your facility uses an organization other than the American Red Cross, the American Heart Association, the National Safety Council, or the American Safety and Health Institute, it may apply for a rule waiver to allow the specific training. Waivers will be evaluated based on whether the provider training is equivalent to the training provided by the nationally recognized organizations.