Q: Where should nursing leadership start with the new final rule?

A: Consider up front how much time and effort it will take to put a plan in place. The director of nursing needs to look at policies, procedures and forms. What do those forms say? Should they include new definitions or need revision? The second piece is planning ahead of how they will implement and accomplish the training needed.

Q: The final rule is in three phases, with the first deadline Nov. 28. What may cause concern? 

A: Physician choice and notification. We should have already been complying with this, but are we? For example, if a nurse makes an appointment for a resident with a specialist, how do we have proof the resident has been told and given contact information for the physician? A nurse may, in passing, inform the resident or family member of their appointment. But I envision this as something that you will need to document. 

Q: What do you hear as nurse leadership concerns around the rule? 

A: Infection control, as it is a heavily cited tag in a lot of states. Now it’s going to require having someone identified [by Phase 3] as the infection prevention control officer. The question of what antibiotic stewardship looks like is, I think, a little nerve-racking.