1.2 410 IAC 16.2 Standard 14: Prohibited Tasks and the Cream/Ointment Exception
Key Takeaways
- 410 IAC 16.2 Standard 14 lists tasks a CNA in Indiana may NOT perform regardless of nurse delegation, training, or resident request.
- Prohibited invasive procedures include enemas, rectal temperature measurement, fecal impaction removal, sterile dressing changes, and any technique requiring a needle.
- Medication administration in any form (oral, topical, injection, inhalation) is prohibited — CNAs may only remind a resident to take self-administered medication.
- The single exception is application of a non-prescription cream or ointment to intact skin, provided a licensed nurse has delegated it and the product is in the original container.
- Violating Standard 14 can result in INAR substantiated findings, registry removal, and employer discipline for both the CNA and the delegating nurse.
410 IAC 16.2 Standard 14: What an Indiana CNA Cannot Do
Quick Answer: 410 IAC 16.2 Standard 14 is the Indiana administrative code section that defines tasks a nurse aide may not perform in a licensed health facility, regardless of delegation, training, or a resident's request. The prohibition list covers injections, invasive procedures (enemas, rectal temperatures, fecal impaction removal, sterile dressings), and medication administration. There is one narrow exception: a CNA may apply a non-prescription cream or ointment to intact skin when delegated by a licensed nurse.
Why Standard 14 Exists
Standard 14 is the bright-line rule that protects residents from receiving care outside a CNA's training and protects the CNA from being pushed beyond scope. It is not a facility policy — it is state regulation, enforced by the Indiana Department of Health (IDOH) during annual surveys and complaint investigations. A nurse who delegates a Standard 14 task to a CNA, and a CNA who performs one, can both be cited and face registry sanctions.
The Prohibited Tasks Table
| Prohibited Task | Why It Is Prohibited | Who Performs It |
|---|---|---|
| Injections (subcutaneous, IM, ID, IV push) | Requires sterile technique and pharmacologic knowledge | Licensed nurse only |
| Enemas (any type, including Fleet and tap water) | Invasive procedure into a body cavity; risk of perforation, electrolyte imbalance | Licensed nurse |
| Rectal temperature measurement | Mucosal barrier invasion; perforation risk in fragile residents | Licensed nurse |
| Fecal impaction removal / digital disimpaction | Mucosal trauma, vagal stimulation, bleeding risk | Licensed nurse or physician |
| Sterile dressing changes | Requires sterile technique and wound assessment | Licensed nurse |
| Non-sterile dressing changes (wound covering) | Wound assessment and dressing selection are nursing tasks | Licensed nurse |
| Medication administration (any route: oral, topical, inhaled, instilled, transdermal) | Medications require knowledge of action, dose, interactions, side effects | Licensed nurse or qualified medication aide (QMA) |
| Insertion or irrigation of a urinary catheter | Sterile invasive procedure | Licensed nurse |
| Tube feedings via NG or PEG | Aspiration risk, formula/flow-rate decisions | Licensed nurse |
| Tracheostomy suctioning or care | Sterile airway procedure | Licensed nurse or respiratory therapist |
| Oxygen titration or adjustment | Oxygen is a medication requiring an order | Licensed nurse |
| Applying heat or cold treatments | Tissue damage risk; requires physician order and assessment | Licensed nurse |
| Any sterile procedure | Outside aide scope | Licensed nurse |
The Cream/Ointment-to-Intact-Skin Exception
There is a single, narrow exception carved out by Standard 14. A CNA may apply a non-prescription cream, lotion, or ointment to intact skin when all of the following are true:
- The licensed nurse has delegated the application
- The product is in the original, labeled container
- The skin is intact (no open wound, breakdown, rash of unknown cause, or active skin condition)
- The CNA has been oriented to the product and the resident's care plan
- The application does not require clinical assessment of the skin
If any of these conditions are not met — for example, the skin is broken, the product is prescription, or the nurse has not delegated it — the CNA does not apply the product. A common error is treating "apply lotion after a bed bath" as automatic; the lotion must be in the original container and the nurse must have delegated that application. Diaper creams, barrier creams, and moisturizing lotions typically meet the exception when delegated.
Medication Reminder vs. Administration
A frequent point of confusion is the line between reminding a resident to take medication and administering it. Indiana CNAs may:
- Remind a resident that it is time to take medication
- Hand the labeled medication bottle to the resident
- Observe the resident self-administer and document the reminder
Indiana CNAs may not:
- Remove medication from a bottle or med pass cart
- Pour or count pills
- Apply a transdermal patch
- Instill eye, ear, or nose drops
- Administer an inhaler
- Crush or split tablets
- Decide when a PRN (as-needed) medication should be given
- Document that a medication was "given" — only that it was reminded
If a resident cannot self-administer (cognitive impairment, weakness), a licensed nurse or a Qualified Medication Aide (QMA) — a separate Indiana credential requiring additional training — must perform the medication pass.
Why Dressings Are Prohibited
The CNA role is to observe and report wounds, not to dress them. A CNA may notice that a dressing is loose, soiled, saturated, or has a odor and must report this to the licensed nurse. The CNA may also protect the wound area during care (for example, keeping a dressing dry during a bed bath by covering it) but does not remove or reapply the dressing itself. Pressure ulcer staging and wound assessment are nursing functions; the CNA reports what is seen and the nurse stages.
Refusing a Prohibited Task
If a nurse instructs a CNA to perform a Standard 14 task, the correct response is to politely decline and reference Standard 14. This is not insubordination — it is a regulatory refusal. Document the request and the refusal, and escalate to the charge nurse or DON if the request continues. Performing a prohibited task is a registry-sanctionable act and the CNA, not just the delegating nurse, can be cited.
Common Test Pitfalls
- "Enema" is a tempting distractor — many candidates think a Fleet enema is a simple personal care task. It is not; it is prohibited.
- "Apply cream to a Stage II pressure ulcer" is prohibited because the skin is not intact.
- "Rectal temperature" appears in vital-signs questions — it is a temperature route, but it is prohibited for an Indiana CNA.
- "Help the resident take the medication she already set out" is allowed if the resident self-administers; the CNA only reminds and documents.
A licensed nurse hands an Indiana CNA a tube of prescription antibiotic ointment and asks the CNA to apply it to a resident's intact forearm. May the CNA apply it?
Which of the following tasks is an Indiana CNA permitted to perform?
During a bed bath, a CNA notices the resident's abdominal wound dressing is saturated with drainage. What is the correct action?