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Survey Trends with D-Level Abuse Citations

Posted Nov 4, 20192 min Read

Regulatory & Clinical

The Indiana Health Care Association has recently conducted an analysis of the D level survey citations received across the state of Indiana in order to identify the root cause of those citations and provide our members with actionable strategies to mitigate their risk and avoid receiving the CMS ICON warning to consumers now part of CMS Nursing Home Compare.

Top reason for the D level Citations in no order:

  • Misappropriation of a resident’s narcotics
  • Misappropriation of a resident’s property (borrowed, missing and or taken without permission)
  • Staff to resident abuse
  • Resident to resident abuse

Indiana Health Care Association is preparing education for our members on how to strengthen internal systems and practices but encourage members to evaluate their systems now in the following areas:

  • Evaluate effectiveness and accuracy of current policy and procedures related to resident’s property and how this is documented upon admission, and concurrently during a resident stay over time. Include in the evaluation, how items are added and deleted over time.
  • Evaluate facility policy on lost items and how this is handled.
  • Evaluate the communication of staff expectations related to residents’ personal belongings including credit cards, money, and all other belongings. Include in the evaluation consequences of violating policy and how this policy is enforced and communicated to new and current employees in education and orientation.
  • Evaluate with your pharmacy consultant, the current narcotic controls and accountability of narcotics. Identify opportunities for improvement.  Note: Most misappropriation of narcotics was related to reconciliation of discontinued medications, and the opt out by licensed nurses of counting narcotics and inspecting narcotics at shift change.
  • Evaluate documentation of self-reportable events related to resident to resident events.
  1. Eliminate the use of adjectives unnecessarily.
  2. Be clear and concise of whether physical injury occurred.
  3. Document the presence of supervision (within eyesight).
  4. Document when intervention occurred – Immediate?
  5. Implement follow-up documentation every shift for 3 days, however, do not use adjectives unnecessarily.

Stay tuned for upcoming education opportunities on this topic.

If you have questions or need assistance with a survey issue, please email