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ARTICLE

Date ArticleType
10/1/2018 Regulatory
Avoid Survey Issues with Involuntary Seclusion

Surveyors in Indiana are questioning the appropriateness of resident admissions that place residents behind a secured or locked door.  I recommend conducting an internal audit to mitigate your risk of non-compliance.  If a resident resides in a secured/locked area that restricts a resident’s movement throughout the facility, a provider must make sure that the resident is free from involuntary seclusion to avoid a federal tag during a survey. 
First steps in conducting an audit:Review the admission policy for the secured/locked area

  • Review the facility policy and procedure for restraints
  • Identify the clinical criteria for placement of a resident in the locked/secured area
  • Ensure supportive documentation is available in the clinical record
  • Documentation of the clinical criteria met for placement in the secured/locked area by the resident’s physician along with information provided by members of the interdisciplinary team;
  • Documentation that reflects the resident/representative’s involvement in the decision for placement in the secured/locked area;
  • Documentation that reflects whether placement in the secured/locked area is the least restrictive approach that is reasonable to protect the resident and assure his/her health and safety;
  • Documentation by the interdisciplinary team of the impact and/or reaction of the resident, if any, regarding placement on the unit; and
  • Ongoing (no less than quarterly) documentation of the review and revision of the resident’s care plan as necessary, including whether he/she continues to meet the criteria for remaining in the secured/locked area, and if the interventions continue to meet the needs of the resident.
  • Never place a resident in a secured area for convenience or discipline or solely related to a diagnosis.
  • If you have questions, forward those questions to ldavenport@ihca.org.