Q:
What are some scenarios in which an IDR (Informal Dispute Resolution) might be requested?
A:
The IDR process gives nursing facilities one informal opportunity to dispute cited deficiencies after any survey of Federal requirements for participation. The facility must evaluate the proof used by the State Agency to support the deficiency cited and determine if they have the evidence to demonstrate that the deficiency was not warranted. Examples of situations in which to consider requesting an IDR might include the following:
- F 585 was cited pertaining to resident grievances. During the survey resident council meeting, three residents complained of call light response times taking too long and that “nothing had been done about it”. The survey team did not witness any prolonged response times to call lights during the survey process, but there was one family member that expressed the same concern when interviewed. The facility had failed to address in the resident council minutes “Old Business” the actions put in place to address the extended response times that occurred briefly during a flu outbreak that had took place approximately 4 months ago. Upon evaluation the facility determined that they had a Performance Improvement Project (PIP) done as part of their QAPI program that clearly outlined the facility’s investigation, plan of action, and ongoing monitoring of call light response times, which were averaging less than 10 minutes.
- F 655 was cited regarding the resident baseline care plan. The State Agency was unable to locate a baseline care plan in the Electronic Medical Record (EMR) for four newly admitted residents. When questioned, the brand new MDS Nurse was not aware that the Baseline Care Plans were being completed on paper, rather than in the EMR. Upon investigation, the facility determined that the paper baseline care plans for the 4 residents had been removed from the charts to use for development of the comprehensive care plans that were in progress during the survey.
- F 689 was cited related to a resident with multiple falls. While the State Agency questioned some staff about the resident’s falls, the interdisciplinary team responsible for conducting the “Root Cause Analysis” and determining the indicated interventions was not made aware of this investigation and was not questioned. Upon evaluation, the facility determined there was substantial additional evidence that was not reviewed by the survey team that would support the facility’s compliance with F 689, including post fall “Team Huddle” notes, root cause analysis documents, and care plan updates.
It is critical that the facility team be aware of all residents being reviewed by the surveyors, and what questions are being asked of the staff. Staying on top of the issues being investigated will help the facility to know what the surveyors will need to support that the facility is in compliance with the regulatory requirements. When deficiencies are cited that the facility has not been able to foresee and intervene with successfully before the exit, the IDR process can be of great benefit. Learn more about successful IDR tips and strategies in the IDR Workshop scheduled for May 15, 2025.
Written By:
Janine Lehman, RN, RAC-CT, CLNC
Director of Legal Nurse Consulting
Proactive LTC Consulting
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