Personnel Requirements of a Florida Home Health Agency – Part 2

Welcome back to our series about the Personnel Requirements of a Florida Home Health Agency.  In the last installment, we discussed the requirements of the Administrator and Alternate Administrator.  This week, we will review the qualifications and responsibilities of the Director of Nursing.

Every home health agency licensed by the State of Florida that provides skilled nursing and other therapy services must have a person who acts as the Director of Nursing (DON). Medicare Conditions of Participation requirements mandate supervision of the agency by a physician or a registered nurse (RN). The State of Florida also has specific qualifications and responsibilities for the DON to meet.

The primary, and most obvious, qualification to serve as the DON is an active RN license; the DON must be a graduate of an “approved school of nursing” and have at least one year of supervisory experience as an RN. In addition to the requirement of being a direct employee of the home health agency, the DON is responsible for overseeing the delivery of professional nursing and therapy care, as well as the non-skilled services provided by the agency.

If the administrator of the home health agency is not a physician or RN, the DON is required to:

1. Establish service policies and procedures regarding biomedical waste, occupational safety and health, and universal precautions and infection control procedures;
2. Employ and evaluate nursing personnel;
3. Coordinate patient care services; and
4. Set or adopt policies for, and keep records of criteria for admission to service, case assignments and case management.

Even though the Administrator is responsible for the daily and ongoing operations of the home health agency, the DON is required to establish and conduct an ongoing quality assurance (QA) program. This QA program must assure that:

1. Case assignment and management are appropriate, adequate, and consistent with the plan of care, medical regimen and patient needs;
2. Nursing and other services provided to the patient are coordinated, appropriate, adequate, and consistent with plans of care;
3. All services and outcomes are completely and legibly documented, dated and signed in the clinical service record;
4. Confidentiality of patient data is maintained; and
5. Findings of the quality assurance program are used to improve services.

Incidentally, an agency with less than 10 full time equivalent employees and contracted personnel may employ the DON as the administrator.

Finally, significant changes to the Florida Administrative Code are being proposed through the rule making process by the Agency for Health Care Administration. They include modifications to the duties and responsibilities of the DON and fairly significant changes to the QA responsibilities of the DON. We will revise this article when those changes are finalized, which we hope will happen within the year.

Join us next week for Part 3 of our series on Personnel Requirements of a Florida Home Health Agency where we will discuss the Supervising Nurse.

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