3.3 Delegation Limits and What the CNA Must Not Do
Key Takeaways
- A Colorado CNA does not independently administer medications, start IVs, insert catheters, take verbal orders, perform sterile procedures, or diagnose.
- G-tube or J-tube feedings and other expanded-scope tasks stay off-limits unless an RN has deemed the CNA competent and the client is stable and not high risk.
- The nurse is busy is never permission to exceed scope.
- Rule 1.11: students must not perform any services they have not been trained and found proficient in by the instructor.
- Employer policies may be stricter than the Board minimum, and a resident's refusal must be honored and reported to the licensed nurse.
3.3 Delegation Limits and What the CNA Must Not Do
Quick Answer: A licensed nurse may assign work that is inside CNA scope. A licensed nurse may not hand you a task that Colorado law, your training, or your competency file does not support. The sentence the nurse is busy is not a delegation. Rule 1.11 says students must not perform services they have not been trained and found proficient in. Employer policy may be stricter than the Board minimum. When in doubt, stop and report to the licensed nurse.
Why refusal is a tested skill
NNAAP Domain III.D does not only ask who is on the team. It asks what happens when the team asks you to do the wrong thing. The written exam builds stems that feel helpful: the nurse is in an admission, the family is angry, the resident wants the catheter now, another CNA says everyone does it here. The scoring key is almost always the same. Stay inside scope. Do not harm the client. Tell the licensed nurse.
Hard no — tasks a Colorado CNA must not do
Use this table as an exam checklist. A few rows have a narrow I.3 exception. If the exception does not apply today, the answer is still no.
| Task someone may ask you to do | Colorado CNA limit | Lawful next step |
|---|---|---|
| Independently administer medications from a cart, stock bottle, or unlabeled cup | No. The only medication-related expanded task is placing a presorted boxed or packaged dose in the mouth after RN competency, on a stable, not high-risk client | Get the licensed nurse; do not pour, crush, inject, or decide the dose |
| Start or discontinue an IV, hang IV fluids, or adjust an IV pump | No. Venous access and IV therapy are not CNA scope | Report the request; stay with the client if needed |
| Insert a urinary catheter or any other invasive tube | No. Emptying a drainage bag and giving assigned catheter care are different from insertion | Tell the nurse the insertion is not a CNA task |
| Give a G-tube or J-tube feeding | Only if an RN has deemed you competent and the client is stable and not high risk | If either gate is closed, the nurse does the feeding |
| Digital stimulation, suppository, or enema | Same expanded-scope gates | Report constipation or impaction signs; do not improvise |
| Change an ostomy bag / apply authorized oxygen | Same expanded-scope gates | Report stoma or breathing changes; do not invent the device or rate |
| Perform a sterile procedure (sterile dressing to non-intact skin, sterile catheterization, sterile suction setup) | No. Clean technique for assigned personal care is not the same as sterile procedure | Ask the nurse to perform or to assign a licensed person |
| Take a verbal order from a physician, PA, or family | No. Licensed staff receive and transcribe orders | Direct the caller to the nurse; do not write the order |
| Diagnose, interpret labs, or tell a family the medical reason for a change | No. Observe and report | Give the facts you saw to the nurse |
| Ignore a resident's refusal | No. Refusal is a right. Forcing care is abuse | Stop, protect safety, and report the refusal to the nurse |
| Change the care plan or skip a two-person transfer because you are short-staffed | No. The plan stands until the licensed nurse changes it | Get help; report the staffing problem up the chain |
Notice the pattern. Basic personal care and data collection stay yes. Invasive, sterile, diagnostic, and independent-medication work stay no. Expanded-scope work is a conditional yes that collapses the moment competency, stability, or facility policy is missing.
The nurse is busy is not permission
Exam writers love a time-pressure stem.
- The nurse is admitting a new resident and says, Just start the IV so we are not behind.
- The charge nurse is on the phone and says, Give the enema — you have seen me do it.
- A coworker says, If you wait for the nurse, breakfast will be cold; just put the G-tube feeding through.
None of those sentences create legal authority. Delegation requires a task that is inside your scope, a person who is competent to do it, and circumstances that are safe. A busy nurse can assign another bath. A busy nurse cannot assign an IV start to a CNA. If the client will be harmed by a delay, you stay with the client, call out for any licensed nurse or the charge nurse, and use the chain of command. You do not fill the gap by stepping into RN or LPN practice.
The same rule applies when the request comes from a physician who is standing at the bedside, a family member who used to be a nurse, or an administrator who wants the hall to look efficient. Rank does not enlarge CNA scope. Only the practice act, Rule 1.10, your competency file, and a lawful assignment do that.
Students — Rule 1.11 proficiency bar
Rule 1.11 requires the training program to ensure that students do not perform any services for which they have not been trained and been found proficient by the instructor. A second clinical-preceptor sentence in the same rule family says the same thing for services on the unit: no proficiency, no performance.
That bar is higher than I watched it in lab. Watching a demonstration is not proficiency. Completing a worksheet is not proficiency. Being short-staffed is not proficiency. A student may observe, may assist with tasks already checked off, and must refuse tasks that have not been taught and signed as proficient — including Foley insertion, sterile dressings, tube feedings, and medication handling.
After certification the same honesty still applies. Expanded-scope I.3 adds a second proficiency layer: even a certified CNA needs the RN's signed deeming before those extra tasks. Your certificate is not a blanket yes.
Employer policy may be stricter than the Board minimum
Section I.6 of Rule 1.10 says a facility, agency, or employer may establish policies and procedures for the I.3 tasks provided these minimum requirements are met. Minimum means the Board floor, not the Board ceiling.
Examples that are lawful even when they feel unfair:
- The Board would allow a competent CNA to change an ostomy bag on a stable client, but this nursing home forbids it. You follow the home's policy.
- Your HPPP lists G-tube feedings from a prior job. This assisted-living residence does not permit CNA tube feedings. The HPPP listing is not a passport. You do not feed.
- The facility requires a second RN observation every six months even though the Board says at least annually. You meet the stricter schedule.
What an employer may not do is go below the floor: no competency document, no HPPP update, expanded tasks on high-risk clients, or students performing untrained services. If a supervisor tells you to ignore the Board minimum, that is a reportable assignment problem, not a green light.
Decision steps before you say yes
Walk this list on every unusual request:
- Is it on the basic I.2 / Rule 1.11 list? If yes, and you were trained and found proficient, proceed as assigned.
- Is it on the expanded I.3 list? If yes, do you have a current signed RN competency (and annual recheck) for this task? Is this client stable and not high risk? Does this employer allow it? All three must be yes.
- Is it invasive, sterile, diagnostic, an independent med pass, an IV, a verbal order, or a care-plan change? Then it is a no.
- Did the resident refuse? Stop. Do not argue the person into compliance. Protect safety and report.
- Are you a student who has not been found proficient in this service? Then it is a no, even if a staff CNA is watching.
- Whatever you refuse, tell the licensed nurse what you will not do and why, so the client still gets the care from someone who may do it.
Silence is not professional. A quiet no that leaves the resident without a nurse is as wrong as a yes that exceeds scope. Report the gap.
Colorado scenarios
Scenario A — the busy-nurse IV. You are newly certified on a Colorado medical unit. The RN is behind on admissions and says, Just start the IV fluids so this resident is not waiting. You decline to start the IV, stay with the resident if the person needs monitoring, and tell the RN that starting an IV is outside CNA scope. You do not ask another CNA to talk you through the stick. You do not start the IV because the order is already written. Written orders do not move a task from RN scope into CNA scope.
Scenario B — the student Foley. You are a Rule 1.11 student on clinical. The floor is short. A staff CNA says, You watched catheter insertion in lab yesterday — go insert Mrs. Hale's Foley so we can catch up. You refuse. Watching a lab demonstration is not being found proficient by the instructor. Inserting a catheter is not a student shortcut and is not basic CNA scope after certification either. You tell the instructor or the licensed nurse immediately so Mrs. Hale is not left without a licensed person to perform the insertion.
Scenario C — refusal plus a stricter policy. Mr. Chen refuses his bath and also refuses the presorted 0900 package. Facility policy is stricter than the Board: even CNAs with medication-placement competency may not place packaged meds here. You stop the bath, honor the refusal, do not hide the tablet in applesauce, and report both refusals to the licensed nurse right away — well inside the two-hour unused-medication window if a placement task had even been allowed. Forcing the bath or the tablet would be a rights violation on top of a scope violation.
Exam traps
- Treating the nurse is busy, the family said it was fine, or everyone does it here as legal authority.
- Confusing emptying a catheter bag or giving peri-care around a tube with inserting the catheter.
- Calling expanded-scope mouth-placement an ordinary med pass, or doing it without competency, stability, and employer permission.
- Letting a student perform an untrained service to help the floor.
- Assuming a Board-allowed expanded task overrides a stricter facility ban.
- Ignoring a refusal so the assignment sheet looks complete.
- Refusing a task and then failing to tell the licensed nurse, so the client never receives the care from someone who may provide it.
A licensed nurse is tied up with an admission and tells a newly certified Colorado CNA, Just start the IV fluids so the resident is not behind. What should the CNA do?
A Colorado nurse-aide student is on clinical. A staff CNA says, You watched catheter insertion in lab yesterday — go insert Mrs. Hale's Foley so we can catch up. What does Rule 1.11 require?
A facility policy says CNAs may not give G-tube feedings even if they have a Board expanded-scope competency document. The CNA's HPPP lists G-tube feedings. A nurse says, The Board allows it, so go ahead. What is correct?