SPECIAL BULLETIN COVID-19 #108: Behavioral Health Services: Guidance on Re-certification and Certification Requirements for CPR/First Aid and Restrictive Interventions

Wednesday, July 8, 2020

Background and General Guidance

NC Medicaid, in partnership with the Division of Mental Health, Developmental Disabilities and Substance Abuse Services (DMHDDSAS), is offering the following guidance to providers, instructors, and staff regarding restrictive interventions and CPR/First Aid. This is applicable to mental health, developmental disabilities, and substance use disorder services, during the COVID-19 pandemic.

Certification and Training Requirements Pertaining to Intervention Curricula

The re-certification and initial certification requirements are outlined in Rules 10A NCAC 27E. 0107, Training on Alternatives to Restrictive Interventions and 10A NCAC 27E. 0108, Training in Seclusion, Physical Restraint and Isolation Time-Out. The following guidance applies to staff who are currently certified or seeking initial certification in the prevention components of restrictive intervention curricula: 

  • Existing certifications currently held by individuals may be extended and deemed valid through September 30, 2020 to allow additional time for renewal of certifications considering the unprecedented circumstances of the COVID-19 public health emergency and to prevent a lapse in certification. Such extensions apply only to individuals who are already certified and whose certification would otherwise be due for renewal before September 30, 2020. 
  • Training on the non-physical prevention components of a curriculum can be completed via two-way, real-time interactive audio-video technology. 
  • Given the nature of restrictive interventions and the circumstances culminating in their potential use, the physical components of the training in restrictive interventions must continue to be done in-person, face-to-face. While we understand the need for appropriate flexibility in training options, the safety of consumers remains our top priority. As such, the requirement that the physical components of training on restrictive interventions be conducted face-to-face remains in effect and will continue to be enforced. Please note that the timeframe flexibility discussed above is to allow current certifications to be deemed valid through September 30, 2020 to allow additional time to arrange for and complete in-person training for those individuals seeking re-certification. 
  • Our goal is to help safely address potential staffing issues anticipated as a result of the restrictions imposed in response to the COVID-19 pandemic. We anticipate that an extension of current certifications and the modification permitting the use of two-way audio-video technology with non-physical prevention components will help accomplish this goal. 
  • In managing staffing issues, providers are encouraged to exercise their best judgment in handling the physical component of hands-on training consistent with guidance regarding COVID-19 mitigation measures issued by the North Carolina Department of Health and Human Services and the Centers for Disease Control (CDC)

CPR and First Aid Training Requirements 

  • Individuals who are certified or provisionally certified in CPR or first aid in compliance with the American Red Cross or the American Heart Association training and certification programs (as applicable) will be deemed to be currently trained and certified for purposes of meeting any State regulatory requirement for current training or certification in CPR or first aid pertaining to mental health, developmental disabilities, and substance abuse services. This includes, without limitation, requirements set forth in 10A NCAC 27D.0101(f); 10A NCAC 26E.0104(e);10A NCAC 27E.0108(i); and 10A NCAC 27G.0202(h). 
  • We will continue to monitor the impact of the pandemic on clinical and business operations and work through the Secretary of the Department of Health and Human Services and the Commission for Mental Health, Developmental Disabilities and Substance Abuse Services to provide additional guidance as necessary. 

Additional Resources