Conducting Thorough Incident Investigations: Key Steps for F610 Compliance

Conducting Thorough Incident Investigations: Key Steps for F610 Compliance

Nursing homes must have evidence that all allegations of abuse, neglect, exploitation, or mistreatment are thoroughly investigated. A detailed and thorough investigation is essential– not only for compliance, but also to uncover all of the facts, preventing recurrence, and ensuring resident safety moving forward. To ensure consistency and effectiveness, facilities should have a structured investigation process in place, with designated and trained staff leading the effort. Consider these tips when conducting investigations…

Under the State Operations Manual – Appendix PP, regulatory grouping 483.12 Freedom from Abuse, Neglect and Exploitation, F-tag F610 outlines the requirement that:

“In response to allegations of abuse, neglect, exploitation, or mistreatment, the facility must have evidence that all alleged violations are thoroughly investigated”.

Key Steps for a Thorough Investigation

1. Define the Purpose of the Investigation

Understanding why an investigation is being conducted is critical in guiding the investigator’s approach and determining the key questions that need to be answered.

For example, when investigating an injury of unknown origin, the investigator should aim to determine:

• • How and why the injury occurred
  • Whether other residents may also be at risk
  • Whether the injury was immediately reported
  • Whether abuse is involved- and if so, who the perpetrator may be

2. Develop an Organized Plan

While ensuring resident protection remains the priority, a structured investigation plan should be developed. Consider:

• • Who will lead in the investigation, and will additional staff be needed?
  • Were all required notifications (to state agencies, family, law enforcement, etc.) completed?
  • What evidence needs to be gathered and reviewed?
  • Who should be interviewed, and who will conduct the interviews?

3. Review the Evidence

Regulatory guidance under F610 specifies that evidence review should include:

• • Observations of the alleged victim, including any injuries
  • Assessment of the location where the alleged incident occurred
  • Staff-resident interactions and relationships
  • Resident-to-resident interactions

In addition, a comprehensive record review may include:

• • Progress notes (nursing, social services, physician, therapists, consultants, etc.)
  • Incident reports, if applicable
  • Hospital/emergency room reports
  • Laboratory or x-ray reports
  • Medication administration records
  • Financial records
  • Photographic evidence
  • Reports from other investigatory agencies

4. Conduct Interviews

When conducting interviews, err on the side of inclusion rather than exclusion. Any possible witnesses- including those who may have seen or heard something relevant should be interviewed.

According to F610 guidance, interviews should include:

• • The alleged victim and their representative
  • The alleged perpetrator
  • Any witnesses
  • Practitioners involved in the resident’s care
  • Personnel from outside agencies (e.g., other investigatory agencies, hospital or emergency room staff)
  • Visitors, volunteers, and residents who may have been affected

5. Concluding the Investigation & Implementing Follow-Up Measures

Once all evidence has been gathered and interviews completed, the investigator should conduct a Root Cause Analysis to answer the questions identified in Step 1:

• • What caused the incident or injury?
  • Were other residents affected?
  • Was the incident reported immediately?
  • Was abuse involved, and if so, who was responsible?

Follow-up reports should be completed and submitted as required, with appropriate disciplinary actions and preventive measures implemented.

A poorly conducted or incomplete investigation can lead to serious consequences, including survey citations, ongoing resident safety risks, and legal implications.

Learn More About Effective Investigation Techniques

For deeper insights into investigation strategies- including interviewing techniques, re-enactment methods, and follow-up interviews- join us on February 18th for the 2nd installment of the Reducing Litigation Risk Webinar Series for SNF & AL: Incident Investigations.