Dear Valued HCS & ICF Providers,

In light of recent communications, Theia Health wants to address an important matter concerning nursing assessments to ensure clarity and compliance. We have been made aware of concerning practices by certain nursing support agencies in Texas, leading to questions surrounding the protocols for client assessments.

Numerous Home and Community-based Services (HCS) & Intermediate Care Facilities (ICF) providers have reached out with a critical inquiry: “Can an RN perform an in-person assessment of a client, then hand that assessment to another RN to complete the Comprehensive Nursing Assessment?” We want to be unequivocally clear: The short answer is “NO!”

The integrity of the Comprehensive Nursing Assessment process is fundamental to our standard of care. It demands comprehensive understanding and personal engagement with the client throughout the entire assessment phase. Assessments are not merely a form-filling exercise; they enhance patient-centered care and are crucial for formulating effective, individualized care plans.

Handing off responsibilities in the manner described undermines the goal of delivering personalized care and could put clients at unnecessary risk. Each RN must directly demonstrate their clinical judgment and knowledge of the patient to ensure accuracy and efficacy in the subsequent nursing assessments.

We urge all providers to review their practices and reinforce proper protocols among staff. Each client’s health and safety hinge on our adherence to established nursing standards, and as care providers, we hold that responsibility with the utmost seriousness.

In the ever-evolving landscape of healthcare, the accountability of nursing professionals continues to come under scrutiny, particularly in the context of Comprehensive Nursing Assessments. As outlined by Texas Human & Health Services Commission in a recent correspondence with HCS Program Policy, it has become increasingly clear that accountability does not rest solely on the program provider. The Registered Nurse (RN) who completes the assessment when performed by another RN, shares this weight of responsibility.

The regulatory framework under 26 TAC 565.13 Nursing emphasizes the need for diligence and accuracy in the assessment process. While the rules do not explicitly mandate that a nursing assessment be conducted by the same RN throughout the continuum of care, the Commission has expressed a belief that such practice is implied. This sentiment underscores the importance of continuity in care and the potential risks associated with multiple assessors.

A comprehensive nursing assessment is not merely a bureaucratic requirement; it holds the key to understanding each patient’s unique healthcare needs. When an RN interprets and acts upon data gathered by another, they inherit not only the responsibility for their patient’s care but also the weight of that prior assessment’s integrity. Therefore, the collaborative practice model among nurses, where clear communication and thorough documentation triumphed, is paramount.

Thus, it is vital for all nursing professionals involved in this process to remain acutely aware of their commitment to providing safe and effective patient care. Every piece of information gathered goes through a lens that may differ from one RN to another, and this variability can directly influence care outcomes. As the healthcare community navigates these waters, embracing the full spectrum of implications related both to legality and patient well-being is essential. In supporting accountability at every level, nurses ensure their practice aligns with the overarching goal of exemplary patient care, making each assessment not just a checkbox, but a critical juncture in the patient’s healthcare journey.

Below is the complete and unedited statement by HHCS:

“The comprehensive nursing assessment is based on a physical assessment of the individual and a review of the individual’s medical records, including physician notes, lab results and all other pertinent clinical records. The nurse may document the source of any assessment information obtained from areas other than the nurse’s assessment. It is expected that the RN who completes the physical assessment completes the form because the RN who initials and signs the comprehensive assessment form assumes responsibility for the validity of the information on the form. How would an RN validate the results of a physical assessment if they did not complete the assessment themselves? A nurse must provide nursing services within the scope of the nurse’s license and standards of practice.

While HCS regulatory rules under 26 TAC 565.13 Nursing, do no specifically say the nursing assessment must be completed by the same RN, we believe it is applied by the following:

(a)        A program provider must:

(J) ensuring a registered nurse (RN):

      (i) performs a nursing assessment for each individual:

             (I) before an unlicensed service provider performs a nursing task for the individual, unless a physician has delegated the task as a medical act under Texas Occupations Code Chapter 157, as documented by the physician; and

             (II) as determined necessary by an RN, including if the individual’s health needs change;

         (ii) documents information from performance of a nursing assessment;

There are limited situations where an RN does not have to complete the assessment in person. I highlighted and bolded below.

a) An RN must complete a comprehensive nursing assessment of an individual in person:

  (1) if the initial IPC includes a sufficient number of RN nursing units for the program provider’s RN to perform a comprehensive nursing assessment as described in §263.104(k)(9) of this chapter (relating to Process for Enrollment of Applicants);

  (2) if there is a significant change in an individual’s health or functional status:

    (A) that, based on a determination by the RN, will not normally resolve itself without further intervention; and

    (B) requires review or revision of the IPC;

  (3) at least annually if a nursing service is on the individual’s renewal IPC;

  (4) before an unlicensed service provider performs a delegated nursing task; and

  (5) if the RN who completed the most recent comprehensive nursing assessment of the individual is no longer providing a nursing service to the individual, except as provided in subsection (b) of this section.

(b) The comprehensive nursing assessment required to be completed in accordance with subsection (a)(5) of this section does not have to be completed in person if:

  (1) the comprehensive nursing assessment is not the annual comprehensive nursing assessment; and

  (2) an unlicensed service provider is not performing a delegated nursing task or a health maintenance activity for the individual.

Per HCS Program Policy, Texas Human & Health Services Commission, “The comprehensive nursing assessment is based on a physical assessment of the individual and a review of the individual’s medical records, including physician notes, lab results and all other pertinent clinical records. The nurse may document the source of any assessment information obtained from areas other than the nurse’s assessment. It is expected that the RN who completes the physical assessment completes the form because the RN who initials and signs the comprehensive assessment form assumes responsibility for the validity of the information on the form. How would an RN validate the results of a physical assessment if they did not complete the assessment themselves? A nurse must provide nursing services within the scope of the nurse’s license and standards of practice.”

Theia Health Group reached out to HHCS Stakeholders and asked the following question, “Can an RN complete Form 8584 (Nursing Comprehensive Assessment) and corresponding documentation whereas another RN did the in-person assessment?”

It just seems to me that the RN that performed the in-person physical assessment would be required to complete Form 8584.  My question is simple, can one RN do the assessment and then another RN actually complete Form 8584?”