Scope of Practice: What a CNA May and May Not Do
Key Takeaways
- Scope of practice is set by federal OBRA rules, Montana DPHHS regulations, and facility policy — the strictest of the three always wins
- CNAs never administer medications, insert or remove IVs or catheters, take verbal or telephone orders, or diagnose, assess, or interpret findings
- The federal floor under OBRA '87 is at least 75 hours of training plus a competency evaluation; Montana approves programs meeting that minimum
- When asked to perform a task outside your scope, decline respectfully, explain why, and report the request to the supervising nurse immediately
- CNAs observe and report; licensed nurses assess, diagnose, and plan care
Scope of Practice
Quick Answer: A CNA's scope of practice is the set of tasks a nursing assistant is legally permitted to perform. It is defined by federal law (the Omnibus Budget Reconciliation Act of 1987, or OBRA), Montana Department of Public Health and Human Services (DPHHS) regulations, and your facility's policies. CNAs never give medications, never insert or remove IVs, never take verbal orders, and never diagnose or interpret findings.
Scope of practice is the legal boundary around your job. Everything a CNA is trained and authorized to do — bathing, feeding, positioning, measuring vital signs, reporting changes — sits inside that boundary. Everything else sits outside it, and performing an outside task can end a career: it is treated as practicing nursing without a license, can trigger abuse or neglect findings on the Montana Nurse Aide Registry, and can expose you to civil and criminal liability.
What Defines a CNA's Scope of Practice
Three layers of authority define what you may do, and the most restrictive layer always wins:
- Federal law. OBRA '87 set the national floor for nurse aide training and competency evaluation. It requires a minimum of 75 hours of training (at least 16 of them supervised practical, hands-on training) plus a state-administered competency evaluation — the knowledge test and skills test you take through Headmaster in Montana.
- State law and regulation. Montana DPHHS approves training programs, administers the Nurse Aide Registry, and adopts rules about what nursing assistants may do and under whose supervision. Montana's approved programs meet or exceed the 75-hour federal minimum.
- Facility policy. Your employer may narrow — but never widen — your scope. If state rules allow a task but your facility's policy manual says CNAs do not perform it, the policy controls while you work there.
A classic exam trap: just because you were shown how to do something, watched a video, or did it at a previous job does not bring it into your scope. Scope comes from law and policy, not from confidence or convenience.
Working Under Nurse Supervision
Every CNA task is performed under the direction and supervision of a licensed nurse — a registered nurse (RN) or licensed practical nurse (LPN). This shapes the fundamental division of labor the exam tests again and again:
- Nurses assess; CNAs observe and report. A nurse analyzes findings and makes clinical judgments. You gather data — a temperature, a change in skin color, a resident's complaint of pain — and report it. You may notice that a resident seems short of breath; you may not conclude why.
- Nurses diagnose and plan; CNAs carry out. The care plan comes from the nurse and the interdisciplinary team. You implement assigned parts of it.
- Nurses interpret; CNAs describe. Chart what you saw, heard, and measured — never your interpretation of what it means.
Tasks Within a CNA's Scope
Typical in-scope tasks include:
- Activities of daily living: bathing, grooming, dressing, toileting, feeding, ambulation
- Transfers and positioning, including use of gait belts and mechanical lifts
- Measuring and recording vital signs, intake and output, height and weight
- Collecting routine specimens (urine, stool, sputum) when delegated
- Making beds, passing fresh water, keeping the environment clean and safe
- Applying non-sterile dressings or elastic stockings when trained and delegated
- Observing, reporting, and documenting changes in the resident's condition
Tasks Always Outside CNA Scope
| Task | Why it is outside scope |
|---|---|
| Administering any medication, including over-the-counter drugs, eye drops, or medicated creams | Medication administration requires a licensed nurse (or a separately credentialed medication aide — not a CNA credential) |
| Inserting, adjusting, or removing IV lines | Invasive, sterile procedure reserved for licensed professionals |
| Inserting or removing urinary catheters or feeding tubes | Invasive procedures; CNAs provide catheter and tube care, not insertion |
| Taking verbal or telephone orders from a physician | Only licensed nurses may receive and transcribe orders |
| Diagnosing, assessing, or interpreting a resident's condition | These are clinical judgments reserved for nurses and providers |
| Developing or changing the care plan | Care planning belongs to the nurse and care team; CNAs give input through reporting |
| Sterile procedures such as sterile dressing changes or sterile suctioning | Require licensure-level training and aseptic technique beyond CNA preparation |
What to Do When Asked to Perform a Task Outside Your Scope
It happens: a busy nurse says "just give her the pill," or a family member asks you to "check if the IV looks infected." The correct response follows the same pattern every time:
- Decline respectfully — state that the task is outside your scope of practice.
- Explain why briefly — you are protecting the resident as well as yourself.
- Report the request to the supervising nurse immediately so the task gets done by someone qualified.
- Document per facility policy if requested.
Never perform an out-of-scope task "just this once," even under pressure, even if the resident consents, and even if a nurse promises to take responsibility. A nurse cannot expand your legal scope by giving permission. The exam's correct answer is always the response that keeps the task with a qualified, licensed person.
Which task is outside a CNA's scope of practice?
Under OBRA '87, what is the federal minimum training requirement for nurse aides?
A nurse asks a CNA to administer a resident's eye drops because the unit is short-staffed. What is the CNA's best response?