7 Steps to Reducing Complaints in Your Nursing Home & SNF

Listening to the President’s “State of the Union” Message March 1, 2022, I was surprised that Nursing Homes made the State of the Union message. Quality of care in nursing homes continues to be of concern. Some facilities are meeting the Centers for Medicare & Medicaid Services (CMS) requirements on quality, while others are struggling to meet the quality needs of their residents.

In this article I want to address steps facilities can take to help reduce residents and family complaints in nursing homes concerning quality and other issues. 

During the pandemic complaint, investigations and recertification surveys became backlogged as the focus at that time was for Infection Control surveys of nursing homes.

CMS Guidance to Increase Oversight on Nursing Homes

November 12, 2021 CMS issued guidance to survey agencies concerning among other issues, complaint investigations, and recertification survey backlogs. This issuance was a memorandum QSO-22-02-ALL for increased oversight on nursing homes. To help clear the backlog, CMS ask state survey agencies and surveyors to add serious “Non-IJ High” complaint/facility reported incidents (FRIs) to the recertification surveys.    

For those interested, the detailed text for complaint prioritization for all Medicare/Medicaid-certified provider/supplier types can be found in “State Operations Manual  Chapter 5 – Complaint Procedures, Rev. 191, 07-19-19 Sections 5000 to 5080.1”. This gives a breakdown of the different levels of complaints.

Facility Reported Incident (FRI) – Past Noncompliance

“Past noncompliance” is a survey deficiency for an adverse facility reportable incident or event as a result of lack of regulatory compliance and serious risk to residents. The facility would have had a thorough internal investigation of the incident, done root cause analysis, made systemic changes, and taken appropriate corrective measures to prevent recurrence of the event. The facility would have documented evidence that demonstrates to surveyors the steps taken to also include a plan of correction, ongoing and consistent monitoring, and a QAPI plan. A resident elopement will fall in this category of adverse event and past noncompliance.

Steps to Help Reduce Complaints in Your Nursing Home 

Step # 1: Provide high-level quality of care and services for your residents – When the residents receive quality care and services they need and deserve, there will be little to complain about. The regulations state that “the facility must be administered in a manner that enables it to use its resources effectively and efficiently to attain or maintain the highest practicable physical, mental, and psychosocial well-being of each resident” (CMS State Operations Manual, Appendix PP, F-Tag 835 Administration)

Step # 2: Provide excellent customer service – customer service must be demonstrated at all levels in the organization. Customer service must be a focus on residents and staff as well. When staffs feel respected and treated fairly, they will pass that respect on to the residents and families. The environment should be one of courtesy, respect, and caring.

Step # 3: Establish a strong proactive “grievance program” – There must be policy and procedure for the grievance program. Residents can express concerns and grievances about their care, treatment, and other matters. “The resident has the right to voice grievances to the facility or other agency or entity that hears grievances without reprisals and without fear of discrimination.”  (CMS State Operations Manual, Appendix PP, F-Tag 585 Grievances)

Step $# 4: Listen to and make every effort to resolve the concerns of the residents and families – some staffs have the habit of ignoring the residents and families when they complain. Take their complaints seriously. When complaints are not addressed at the facility, residents and families seek out the Ombudsman and Survey Agency. 

Step # 5: Ensure regular training is conducted about the facility’s grievance program -Staffs at all levels in the facility need to know the grievance policy and procedures and be comfortable executing all aspects of the program at their level. Staff must report concerns to their supervisors. Staffs need to know that residents can report concerns verbally, in writing, and also anonymously. Anonymous reporting must stay anonymous. There should be signs posted in the facility of the different agencies where residents and families can file grievances.

Step # 6: The administrator must establish a culture in the facility allowing staff to report mistakes without fear of reprisals or reprimands. This does not mean that staff will not be held accountable for bad behavior and incompetent work. Staff should not be afraid to report mistakes, so mistakes can be corrected.

Step # 7: The administrator must ensure the facility has a comprehensive and effective QAPI program. The QAPI program must address all systems of care and services offered by the facility. The administrator and QAPI Director must ensure that all staffs are aware of their role in the facility’s QAPI program. 

It is the goal of the skilled nursing facilities and nursing homes to meet the requirements of CMS to provide quality of care, quality of services, and a safe environment for the residents they serve.