Published January 29, 2019

A common struggle SNF administrative teams have is conducting a thorough investigation to rule out
abuse. Abuse and investigation citation frequency is steadily climbing above the infamous Infection
Prevention & Control that has ranked number one across the nation since the start of our new survey
process. If you are struggling in this area, start with the basics of making sure your policies and
procedures are up-to-date with the Phase 1 & 2 RoP and contain the processes required in F607:

1. Screening
2. Training
3. Prevention
4. Identification
5. Investigation
6. Protection and
7. Reporting & Response

Second, review your required orientation and annual in-service content on Abuse, Neglect, Exploitation
and Misappropriation to be certain staff are receiving education on these definitions and that they
understand common characteristics of abuse such as bruises of unknown origin that are found in areas
inconsistent with the resident’s history or course of treatment. Knowing the signs and types of abuse
will promote timely and appropriate reporting.

Last, review your Incident and Accident reporting format. The versions found in most electronic medical
records often times leave a lot to be desired. The facts needed to determine if an abuse investigation
should be conducted are obtained at the time of the incident. Staff need to understand their
responsibility to collect as many details as possible (including statements from the resident, staff and
others that may have information related to the incident) and initiate an immediate intervention to
protect the resident and prevent a re-occurrence.

The most successful incident review processes include the interdisciplinary team (IDT) and not just one
individual. To be timely and proactive, since each incident report could lead to a full abuse investigation,
consider reviewing incident reports daily. Waiting until a weekly meeting can lead to delayed
investigations & prevention, delayed reporting and subsequently result in citations.

Keep in mind, you must be able to provide evidence that, upon the allegation of abuse,
neglect, mistreatment, and/or misappropriation of resident property, that your investigation
commenced immediately, regardless of the time of day or day of the week when the
incident occurred. Know the CMS abuse regulations, what your state requirements are for reporting and
have a consistent investigative process. Prevention is key!

We recognize these challenging times so please don’t hesitate to reach out to us for your training needs,
assistance with improving your current process or to prepare for the upcoming Phase 3 requirements of
incorporating abuse investigations into your QAA process.

Amy Lee, RN, MSN, CRRN, QCP
President/CEO