The Emergency Nurses Association, the American College of Emergency Physicians and the American Academy of Emergency Medicine representing more than 60,000 emergency healthcare providers, sent a letter to The Joint Commission regarding deep concerns over the interpretation of standard MM.3.20 EP1. (Standard MM.3.20 applies when medications are ordered, dispensed or administered.)

The standards interpretation division of the Joint Commission has held that under MM.3.20 EP1:
"Protocols can be initiated by a registered nurse once the protocol is ordered by a licensed independent practitioner. Initiation of a protocol which includes a medical intervention (i.e. decision to administer a medication) requires an order by an independent licensed practitioner. "

It is clear that this interpretation of MM.3.20 EP1 can delay patient treatment, exacerbate crowding, and is an infringement on nursing's scope of practice as well as on the authority of the state boards of nursing to regulate the scope of nursing practice in their respective states.

The letter requests that The Joint Commission immediately reverse its position on nurse initiated protocols in the ED and offers the Joint Commission the opportunity to meet face to face with representatives from each of the signing organizations to discuss the consequences the implementation of this standard causes in the ED.

I encourage all ENA members to read the letter in its entirety so that you can fully understand the issues we face under this interpretation of MM.3.20 EP1.

To see a copy of the letter, go to: http://www.aaem.org/emtopics/NurseInitiatedProtocols.pdf 

ENA will continue to monitor this situation and keep all of our members informed.

Sincerely,
Donna Mason, RN, MS, CEN
2007 President, ENA