A Certified Nursing Assistant (CNA) is an unlicensed healthcare provider who assists licensed nursing staff, such as Registered Nurses (RNs) and Licensed Practical Nurses (LPNs), with basic patient care needs. This supportive role is governed by a defined scope of practice, which limits the procedures a CNA can legally perform to ensure patient safety and regulatory compliance. Understanding this scope is particularly important when considering treatments like oxygen therapy, a process that involves both regulated medical intervention and routine supportive tasks.
The CNA Scope of Practice Regarding Oxygen Initiation
The direct answer to whether a CNA can initiate oxygen therapy is generally no, because medical-grade oxygen is legally classified as a prescription medication. Administering oxygen requires a physician’s order detailing the flow rate and delivery method, and its initiation or adjustment involves clinical judgment. This assessment and decision-making responsibility is reserved for licensed nurses who have the formal training to evaluate a patient’s respiratory status.
Licensed personnel must assess factors like the patient’s underlying lung disease, current blood oxygen saturation levels (SpO2), and signs of respiratory distress before starting or changing the oxygen flow rate. CNAs typically lack the specialized education required to perform this complex assessment or to titrate—meaning to adjust—the flow rate in response to a patient’s changing condition. Mismanagement of oxygen can lead to complications, such as administering too little oxygen, which results in hypoxemia, or administering too much, which can cause oxygen toxicity.
The potential for harm from improper administration is why the task of initiating or changing oxygen settings falls outside the CNA’s scope of practice across the majority of jurisdictions. A CNA’s training is focused on observational care and assistance with activities of daily living, not the independent management of therapeutic medical gases. Therefore, any task requiring the CNA to make a judgment about a patient’s need for oxygen or the appropriate dosage is universally prohibited.
Permissible Supportive Tasks
Maintenance and Monitoring Tasks
While the act of initiating or titrating oxygen is prohibited, CNAs perform several permissible and important supportive tasks related to oxygen therapy after a licensed nurse has established the treatment plan. These actions focus on maintaining the established therapy and observing the patient and equipment for any complications or changes.
CNAs are responsible for ensuring the continuous and safe delivery of oxygen by performing tasks such as:
- Securing the oxygen delivery device (nasal cannula or face mask) to ensure proper positioning and patient comfort.
- Monitoring the oxygen setup to ensure the tubing is free of kinks or obstructions that could interrupt the flow of gas.
- Checking the flow meter to confirm the dial is set to the exact liter flow rate or percentage previously ordered by the nurse.
- Performing skin checks around contact points (behind the ears, face, or nose) to identify irritation or pressure injuries from continuous equipment use.
- Promptly reporting any changes in the patient’s condition—such as increased shortness of breath, a change in skin color, or an equipment malfunction—to the supervising licensed nurse.
In some facilities, and depending on state regulations, a CNA may be permitted to perform highly specific oxygen-related actions that do not require clinical judgment. These limited allowances, such as applying and removing the oxygen device during patient transfers or turning the oxygen on and off at a pre-established flow rate, are only granted when the flow rate is already set and the task is performed under the direct supervision and instruction of the licensed nurse.
Factors Governing Delegation and Facility Policy
The rules defining what a CNA can and cannot do are established by the state Boards of Nursing (BON) through the state’s Nurse Practice Act (NPA). These regulatory bodies define the scope of practice based on the CNA’s level of education and demonstrated competency. Because the CNA role is considered unlicensed assistive personnel, their practice is always dependent on the oversight of a licensed nurse.
The concept of “delegation” is the mechanism by which a licensed nurse transfers the authority to perform a specific nursing task to a competent CNA. Delegation is strictly task-specific and applies only to duties that do not require the independent nursing judgment, complex assessment, or clinical decision-making involved in initiating or titrating oxygen. Therefore, a licensed nurse cannot legally delegate the authority to start oxygen therapy, regardless of the patient’s condition.
The variability in the CNA scope from one state to the next reflects differences in how each state’s BON interprets the training level and allowable tasks. Some states permit tasks like turning oxygen on and off at a fixed rate, while others prohibit any manipulation of the oxygen equipment beyond basic maintenance. The licensed nurse who delegates a task remains accountable for the patient outcome, which is why they must ensure the task is within the CNA’s scope and the CNA is competent to perform it.
Adding another layer of regulation, individual healthcare facilities establish their own internal policies and procedures. These facility policies must always be equal to or more restrictive than the state’s Nurse Practice Act regarding the CNA scope. A facility cannot allow a CNA to perform a task that the state law prohibits, but it can choose to prohibit a task that the state law might otherwise permit, ensuring the highest standard of safety within their specific clinical environment.
Legal and Safety Implications of Exceeding Scope
Operating outside the defined scope of practice carries serious legal and safety consequences for the patient, the CNA, and the supervising nurse. The most immediate concern is the risk to the patient, which can manifest as adverse events ranging from discomfort to severe respiratory compromise. If a CNA improperly initiates or adjusts oxygen, the patient could suffer from untreated hypoxemia or oxygen toxicity, which can be life-threatening.
For the CNA, performing a task outside of their scope can lead to disciplinary action by the state Board of Nursing, including suspension or permanent revocation of their certification. This action not only ends their employment but also damages their professional standing, making it difficult to work in the healthcare field again. In cases of significant patient harm, the CNA may also face civil liability in a lawsuit.
The supervising licensed nurse is also held liable for any damages that result from improper delegation or failure to supervise, as they maintain the ultimate accountability for the patient’s care. The facility itself may face regulatory penalties and liability for failing to enforce proper protocols and ensure staff are working within their legal boundaries. Adherence to the scope of practice is therefore a matter of professional integrity and a foundational element of patient safety.