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Who Can Conduct Resident Assessments in Assisted Living?

This article was originally sent via an emailed Survey and Regulatory newsletter in March 2022. While still accurate, new updates have come from DSHS because of WHCA’s efforts to support a member who received a citation and subsequently prevailed during an informal dispute resolution. This Management Bulletin was shared with all Residential Care Services (RCS) staff on March 24, 2023 and includes a link to the Dear Provider Letter sent to assisted living providers on the same date.
Assisted living regulations are vague and thus cause confusion regarding the expectations surrounding who can conduct resident assessments. This article aims to provide clarification on this topic.
Perhaps one of the most confusing aspects in the entirety of WAC 388-78A lies with the use of the word “assessment.” This word provokes thoughts of a nurse conducting a head-to-toe patient assessment or a medical doctor assessing a patient’s current ailment. While nursing assessments are necessary in assisted living, for those residents needing some level of intermittent nursing services, the remainder of the assisted living resident assessment would be better termed “evaluation.” The vast majority of information gathered during an assessment is really evaluating the resident’s needs and preferences and requires very little by way of clinical expertise.
Depending on the type of assessment, the assisted living provider might utilize staff with differing levels of education and experience.
Preadmission Assessment
The preadmission assessment is conducted before the resident moves in. This assessment must be completed by a “qualified assessor” whose education and experience are outlined in WAC 388-78A-2080 and includes a person with any of the following:
  • A master’s degree in social services, human services, behavioral sciences or an allied field and two years social service experience working with adults who have functional or cognitive disabilities.
  • A bachelor’s degree in social services, human services, behavioral sciences or an allied field and three years social service experience working with adults who have functional or cognitive disabilities.
  • A valid Washington state license to practice nursing.
  • This could be an LPN, RN, or ARNP
  • A state license to practice medicine.
  • Three years of successful experience acquired prior to September 1, 2004, assessing prospective and current assisted living facility residents in a setting licensed by a state agency for the care of vulnerable adults, such as a nursing home, assisted living facility, or adult family home, or a setting having a contract with a recognized social service agency for the provision of care to vulnerable adults, such as supported living.
Regardless of who performs your facility’s preadmission assessments, ensure documentation supports the individual’s qualifications.
14-Day and Ongoing Assessments
All residents new to the facility must have a full assessment within 14 days of moving in and must address all aspects of WAC 388-78A-2090. Ongoing assessments are defined in WAC 388-78A-2100 and include:
  • Annual (or more often, based on the facility’s policies and procedures) full assessment as outlined in WAC 388-78A-2090
  • Focused area(s) of assessment based on:
  • A resident’s change in condition
  • Times when a resident’s negotiated service agreement no longer addresses the resident’s current needs and preferences
  • Times when a resident has an injury requiring the intervention of a practitioner
The person conducting the 14-day assessment as well as the ongoing assessments does not have to meet the stringent education and experience standards that are required for preadmission assessments. Regarding ongoing assessments, the regulation states:
“Ensure the staff person performing the on-going assessments is qualified to perform them.”
Facility management could legally and feasibly train a staff person to conduct ongoing assessments to “ensure the staff person…is qualified to perform them.” It is suggested that any training provided to this individual(s) is documented, and any facility policy and procedure on the topic addresses who in the facility is qualified to perform ongoing assessments. Ideally this task is included in the individual’s job description.
Nursing Assessments
Residents who need nursing services will need a nursing assessment. This assessment is focused on the resident’s condition(s) that warrant nursing care and can only be conducted by a registered nurse (RN). The Washington State nurse practice act outlines the differing roles and responsibilities of the RN and the LPN. An LPN can make observations, gather data, and provide relevant information as part of a nursing assessment, while the RN is responsible for conducting the nursing assessment.
WAC 388-78A-2310 captures what constitutes intermittent nursing services; any resident’s needs that fall into any or all these categories would require a RN assessment, specific to these issues and/or resident conditions. Topics that warrant a RN’s assessment include:
  • Medication administration. This service is a complex one, that involves times when a resident cannot perform the “final step” of medication self-administration or cannot accurately direct others to perform the task. Common medication administration provisions include times when a nurse must inject medications (vitamin B12 injections, for example) or spooning medications into a resident’s mouth when the resident is unaware s/he is receiving medications.
  • Administration of health treatments. This too is a vague term, and requires considerations of tasks that typically fall to licensed nurses such as prescribed wound care/wound dressing changes or indwelling urinary catheter changes.
  • Diabetic management, including whenever staff must perform blood glucose monitoring for a resident (piercing of the skin) and/or insulin injections. Individual facilities/companies may include other services under diabetic management in order to offer enhanced oversight of the condition, such as monitoring the extremities for wounds/skin breakdown, diabetic nail care, or even nursing oversight of any resident diagnosed with diabetes.
  • Nonroutine ostomy care. This includes changing the protective wafer around a stoma and observing/providing skin care to treat or minimize skin breakdown where the wafer is applied.
  • Tube feeding.
  • Nurse delegation.
It is reasonable that an assisted living facility has more than one staff person who can complete resident assessments. No matter the type of assessment conducted, the facility should have a system in place to ensure assessments are done timely and by the appropriate, trained person(s).
AL Questions?
Please email Vicki McNealley or call her at 1-800-562-6170 extension 107.
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