Reminder for North Carolina LPNs: You are Not Allowed to complete CAAs by NC Board of Nursing Scope of Practice

North Carolina Only:

From Mary Maas, NC RAI Manager on the NC MDS email list-serve:

Below you will see the BON’s position statement issued following an exchange of emails between Cindy DePorter and Carol Walker from the NC Board of Nursing published August 2010.

Mary Maas

LPN Participation in MDS 3.0 Portion of CMS RAI

The laws and rules governing nursing practice in North Carolina require that an RN is responsible for the nursing assessment of clients.  Nursing law and rules give the RN comprehensive assessment responsibility for the determination  of nursing care needs based on the collection of data, interpretation of all data (whether collected by the RN personally or  by another competent individual), and formulation of a nursing diagnosis.  The RN also is responsible for developing and modifying the nursing plan of care and for evaluating the extent to which desired outcomes of nursing care are met. 

In contrast, nursing law and rules allow an LPN to “participate in” the nursing assessment of clients.  The rules define this participation as the collection of client data using written, structured guidelines, policies or forms.  This is sometimes identified as a “focused assessment.”  The documented focused assessment completed by an LPN is then used by an RN in the completion of the comprehensive nursing assessment of a client.  The rules further specify that data interpretation by the LPN is limited.

It is essential to note that the nursing assessment of a client is required on admission and on an ongoing basis independent of, but in collaboration with, the initial and ongoing RAI process.  The nursing assessment and nursing plan of care will incorporate data collected on the MDS and throughout the RAI process but will require additional data and guide interventions based on the RNs ongoing independent assessment and evaluation of client condition and nursing care needs.  As CMS notes, “the process of completing the MDS and related portions of the RAI does not constitute the entire assessment that may be needed to address issues and manage the care of individual residents” (CMS’s RAI Version 3.0 Manual, June 2010, Pages 4-7&8).

The Practice staff of the Board has reviewed CMS’s MDS 3.0 form, the CMS guidelines and intent statements, and consulted with several resources.  As a result, we understand that the RAI, including all three components of MDS, Care Area Assessments (CAAs), and Individualized Care Plan, meets CMS’s requirement for a documented comprehensive assessment of the client.  The MDS is the starting point for this comprehensive assessment and when it is completed, provides a foundation for a more thorough assessment and the development of an individualized care plan. 

The Board’s determination is that the MDS 3.0 is a structured assessment form used for the purpose of data collection and, as such, falls within the scope of practice of the LPN in North Carolina.  The LPN is responsible to sign the certification statement for those portions of the MDS for which they collect and document data.  We understand that the RN Assessment Coordinator’s signature indicates that all portions of the MDS have been completed by those appropriate to do so, and does not indicate validation or accuracy of any portion. However, interpreting and addressing the identified CAAs or care areas and developing/coordinating the individualized care plan are beyond the scope of practice of the LPN.  This level of assessment, interpretation, and planning is within RN scope of practice.  The RN collaborates with the attending physician and other health professional members of the interdisciplinary team as indicated by client condition and care needs.