Is the registered nurse (RN) allowed to delegate routine foot and nail care to a patient with diabetes or other circulatory problems to the nursing assistant-registered/nursing assistant-certified (NA-R/NA-C) or home care aide-certified (HCA-C)?

No. The Washington State Board of Nursing determines that RN delegation to the NA-R/NA-C or HCA-C to perform foot and nail care is not allowed for a patient with diabetes or a patient with other conditions resulting in poor circulation in any setting because of the risk for injury.

Further, WAC 388-106 Long-Term Care Services stipulates that it is not within the scope of practice of a NA-R, NA-C, or HCA-C to perform foot care on a patient with diabetes or a patient with poor circulation even through the nurse delegation process. This rule applies to long-term  care services administered directly or through contract by the Washington State Department of Social and Health Services (DSHS) and identified in WAC 388-106-0015.