At the 2006 FNCE meeting, DEP’s Kathleen Carozza (Director, Dietetic Internship, College of Saint Elizabeth) and Debra Hook (Metabolic Dietitian/ Clinic Coordinator and Lecturer, UCI Medical Center & Children's Hospital) met with the RPG Executive Committee to discuss educator-driven concerns related to student learning experiences at various dialysis clinics across the country.
Some of the topics discussed included:
- policies regarding student chart notes
- appropriate practice experiences in compliance with federal and state rules and regulations and with facility/corporate policies (i.e. data collection and analysis, mock interviews and 24-hour dietary recalls with real patients, and observing RD counseling)
- what the dialysis facilities/corporations could do to help the educators.
Mary Hager (Senior Manager, ADA Regulatory Affairs) asked the Centers for Medicare & Medicaid Services (CMS), the agency that implements federal regulations which establish standards for the quality and safety of patient care, whether regulation –
§405.2136(d)(3) (3) If the services of trainees are utilized in providing ESRD services, such trainees are under the direct supervision of qualified professional personnel
-- applies to both students/interns and new employees alike and for an interpretation of “direct supervision.”
CMS indicated that the qualified dietitian who meets their educational and experiential requirements conducts assessments and independently provides direct care. Trainees are only allowed to provide professional-level services if the qualified dietitian is present to observe the student for the entire session. That way, the qualified dietitian can correct the student/intern at the time they make an error and ensure that the patient is receiving optimal nutrition care.
However, this does not preclude students/interns from conducting 24-hour recalls, reviewing diaries and collecting other types of data from patients. CMS emphasized that the same principles of direct supervision apply to DTRs and other technical support employees regardless of years of service.
An unofficial poll of several dialysis centers revealed these three common policies:
- An approval has to be obtained from the Area & Clinic Managers, followed by a letter of agreement between the company & the University or Institute they (interns) represent. Usually both the company and the University have their own agreements or contracts.
- It is required that students sign a 'no breech of confidentiality' document.
- Interns bring their own professional liability insurance with them.
- The supervising dietitian reviews and co-signs the intern’s documentation.
