Immediate Jeopardy cited – now what?




When a skilled nursing facility is cited with immediate jeopardy, it means that the facility is in violation of regulations to an extent that it poses a serious threat to the health and safety of its residents. Immediate jeopardy is a serious situation that requires prompt and decisive action.

Once a survey team has identified and received confirmation from their State Agency that Immediate Jeopardy (IJ) exists, they must notify the facility administrator immediately and provide them with a copy of the completed IJ template that was used in the determination. The survey team will then also request a written IJ removal plan from the administrator.

As outlined in Section VII of the SOM Appendix Q , the facility’s removal plan must:

      • Identify those recipients who have suffered, or are likely to suffer, a serious adverse outcome as a result of the noncompliance; and
      • Specify the action the entity will take to alter the process or system failure to prevent a serious adverse outcome from occurring or recurring, and when the action will be complete.

Developing and writing an acceptable removal plan can be challenging. The state agency will review the plan and determine that, if implemented appropriately, the removal plan will remove the likelihood that serious harm will occur or recur. It’s not uncommon for the state agency to reject a facility’s plan, requesting additional information and/or other edits to be made. These edits may require the facility to extend their date of compliance resulting in additional days of monetary penalties.

The state agency’s approval of the written removal plan does not mean the IJ is removed. To remove IJ, the facility must implement the removal plan, and the survey team must verify through observation, interview, and record review, that all actions the facility took were effective in removing the likelihood that serious injury, serious harm, serious impairment or death would occur or recur.

IJ is considered to be removed when surveyors verify that the approved removal plan is fully implemented, and no recipient is currently experiencing serious injury, serious harm, or serious impairment; and/or serious injury, serious harm, serious impairment, or death is not likely. If the plan is not fully implemented, the IJ will continue until the removal plan is fully implemented and the likelihood of serious injury, serious harm, serious impairment, or death no longer exists.

Save the date to join us January 9, 2024 for the first session in our new webinar series High Risk Tags & Immediate Jeopardies.  The January opening session will focus on Elopement risks and case studies from actual IJ citations. Learn more and register.


Angie Hamer RN, RAC-CT
Clinical Consultant

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