Mar 21 2025 | Responsibilities of the Director of Nursing
On January 13, 2025, the Centers for Medicare & Medicaid Services (CMS) released a memo which identifies their 2025 Mission and Priorities. Contained within this document are CMS’s focus areas for nursing homes which include the following:
- Reducing the usage of inappropriate antipsychotics
- Preventing discharges that violate federal requirements
- Nurse staffing requirements
- PBJ reporting compliance
As a result of this information, facilities should expect surveyors to have a heightened regulatory focus on these requirements. Appendix PP, F727 addresses the facility’s requirement for a full-time Director of Nursing (DON). Full time is defined as working a minimum of 40 hours per week. The facility may permit the DON to serve as a charge nurse only when the facility has an average daily occupancy of sixty or fewer residents.
With the regulatory changes effective April 28, 2025, CMS has expanded the guidance to include more details about RNs and the DON. For example, when CMS notes RN responsibilities in the guidance, they have added language around the RN’s need to develop and evaluate residents’ plans of care. CMS also formally separated and added to investigative procedures under F727, directing surveyors to follow the Sufficient and Competent Nurse Staffing Critical Element Pathway in addition to the guidance outlined in Appendix PP.
During the annual survey entrance conference, the State Survey team will request confirmation of a full-time DON. If, at any time during the survey, the team identifies concerns with the availability of a full-time DON, CMS directs them to investigate further.
It is important to also note our state requirements regarding the Director of Nursing Services. The law clearly states that all licensed nursing homes must have a DON who is a registered nurse or an advanced registered nurse practitioner. The director of nursing services is responsible for the following:
- Coordinating the plan of care for each resident.
- Permitting only licensed personnel to administer medications (this does not exclude nurse technicians and other individuals according to their scope of practice and requirements).
- Ensuring that the licensed practical nurses and the registered nurses comply with chapter 18.79 RCW, and persons certified under chapter 18.135 RCW comply with the provisions of that chapter and rules adopted under it.
The rules go on to state that the nursing home must ensure that a sufficient number of qualified nursing personnel are available on a 24-hour basis seven days per week to provide nursing and related services to attain or maintain the highest practicable physical, mental and psychosocial well-being of each resident as determined by resident assessments and individual plans of care. The nursing home must also designate a registered nurse or licensed practical nurse to serve as charge nurse who is accountable for nursing services on each shift and have a full time DON who is a registered nurse.
While the nursing home must ensure that staff respond to resident requests for assistance in a manner that promptly meets the resident’s quality of life and quality of care needs. According to the Washington rules, the DON is responsible for the following:
- Coordinating the plan of care for each resident.
- Ensuring that registered nurses and licensed practical nurses comply with chapter 18.79 RCW.
- Ensuring that the nursing care provided is based on the nursing process in accordance with nationally recognized and accepted standards of professional nursing practice.
The role of the Director of Nursing is critical to the delivery of quality care and services to residents in skilled nursing facilities. It is also important that they understand their responsibilities and are prepared when the survey team enters the facility. If you have questions, please contact Elena Madrid, Executive Vice President of Education and Regulatory Affairs.