Standing orders and Medicare conditions of participation that relate to them are some of the most confusing compliance requirements that hospitals face. Both CMS and the Joint Commission address this tricky area, and four separate sections of the hospital CoP manual regulate the issue of standing order requirements. After CMS moved most of the standing order requirements from Tag 405 to Tag 457, hospital staffs likely suffered more confusion.
The last thing your facility wants is a Statement of Deficiencies from CMS. What should hospitals be doing to keep up with the compliance requirements that seem to flow endlessly from CMS in this confounding area?
Why Are ‘Standing Orders’ So Confusing?
According to CMS, nurses and other staff are allowed to administer drugs in accordance with pre-printed and electronic standing orders, orders and protocols that are collectively referred to as “standing orders.” A standing order allows non-physician staff members to administer care when patients meet certain criteria, and it is commonly used in ICUs, CCUs and EDs.
Standing orders have been an almost constant source of concern for CMS, and the agency has had to adjust its regulations in this area many times. State law also comes into play. Standing orders are one of the top tag numbers in hospital complaint data released by CMS. (Other areas of concern include restraints and seclusion, EMTALA, infection control, patient rights and consent, advance directives and grievances.)
Hospitals can use standing orders only under certain circumstances, but CMS has never really clearly defined what counts as a standing order, and so hospitals are often confused over how to comply with, for example, Tag 457.
Untangling CMS & Joint Commission Standards on Standing Orders
ProfEdOnDemand recently hosted the live audio conference “CMS Standing Orders, Protocols, Order Sets and Preprinted Orders” with noted expert Sue Dill Calloway, RN, MSN, JD, who addressed CMS and joint commission standards and guidelines on standing orders, protocols, order sets and preprinted orders.
Sue discussed the interpretive guidelines and regulations that are required by CMS and the Joint Commission regarding protocols, order sets, preprinted orders and standing orders and provided the history of each of the four sections and what each section requires hospitals to do. She also clarified confusing areas and made the requirements easy to understand for hospitals.
