Can a Patient Care Tech Perform This Task?

Carolyn Buppert, MSN, JD


December 28, 2016

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The new clinical educator of a community hospital wrote to us describing a circumstance that could happen in almost any healthcare setting, and of which all registered nurses (RNs) who supervise unlicensed personnel must be aware:

I discovered that patient care technicians (PCTs) are taking out peripheral intravenous (PIV) lines in this hospital. This was not permitted in the hospital where I previously worked. I found no training records. I contacted the state health department for clarification on the policy, and they said that unlicensed assistive personnel are not allowed to remove PIVs—it is not within their scope of practice. I went to the nursing administrator, who wants a policy permitting the PCTs to remove PIVs, which states that a RN must assess the PIV site and discontinue the fluids, and then a PCT can remove the catheter. I have drafted a checklist to train the PCTs, but if they are not supposed to be performing this skill according to state regulations, this does not seem right. What should I do?
Response from Carolyn Buppert, MSN, JD
Healthcare attorney

The answer depends on the state, and you did the right thing by contacting the state health department. Some states specify, in policy or regulation, the tasks that unlicensed assistive personnel (such as PCTs) may perform, some states specify what they may not do, and some states are silent on these issues.

For example, New York says:

...[T]asks that require the exercise of medical judgment and assessment, or tasks that are specifically restricted to licensed professionals, may not be delegated to "medical assistants" or otherwise unauthorized persons. Such tasks must be performed by licensed persons who, by virtue of their education and licensure, are presumed to possess the level of professional judgment and assessment skills that will ensure safe practice.

The New York policy then provides examples, but taking out a PIV catheter is not addressed.

The next step, if you are in New York, is to decide whether the removal of PIV catheters requires medical judgment or assessment skills. It is a reasonable conclusion that if a physician or advanced practice clinician has ordered the PIV to be discontinued and if a RN assesses the site and turns off the fluids, then the act of pulling the PIV catheter out and applying pressure and a dressing is technical, rather than assessment or judgment.

However, it doesn't matter what I think is reasonable, if a staff person at the state health department told you that the task was inappropriate for a PCT. Regulatory agencies have the authority to make scope of practice decisions. Perhaps another call to the state health department is needed before the proposed policy is implemented. If the state agency persists in the opinion that the task is not in the scope of a PCT's practice, then that determination must be honored.

California specifically forbids medical assistants to disconnect IVs. Here is the answer to a frequently asked question from the California medical board's website:

Are medical assistants allowed to start or disconnect IVs or administer injections or medication into IVs?

No. Medical assistants may not place the needle or start or disconnect the infusion tube of an IV. These procedures are considered invasive, and therefore, not within the medical assistant's scope of practice. Medical assistants are not allowed to administer medications or injections into the IV line.

Both states refer to "medical assistants" and not PCTs; however, I don't think it is worthwhile to make an issue of the differences among the various forms of unlicensed assistive personnel unless a state's law makes a distinction. In my view, one can and should apply the rule on medical assistants to PCTs.

This issue certainly is worthy of consideration and discussion in hospitals, after a review of any applicable law and a query to the nursing and/or medical boards. If state law or policy is ambiguous or nonexistent, and, on questioning, a high-level staff person at a licensing board or other regulatory department has an opinion, document what the regulator said, the date, the staffer's name, and follow that person's direction. If you question whether the person on the other end of the call has the authority and understanding to make a determination, ask to speak with a higher-level regulatory staff person and/or ask for a determination in writing.


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