The word “Risk” is referenced in the CMS State Operations Manual – Appendix PP 524 times. Clearly Risk Management is a critical area of focus for the Director of Nursing and the nursing department.  According to the article Clinical Areas of Liability: Risk Management Concerns in Long-

Term Care in the January 2005 Annals for Long Term Care, Risk management is defined as a “facility-wide program designed to reduce preventable injuries and accidents and to minimize the financial severity of any claims”. What are the key areas that should be addressed in a successful Risk Management Program?

The CMS regulations in Appendix PP provide the primary areas of concentration when developing or enhancing the facility Risk Management program. F-tags that present the highest risk of negative outcomes for residents should be the core of risk management.  These areas would include:

  • Abuse/Neglect (with emphasis on resident-to-resident altercations and interactions)
  • Accidents/Incidents (especially falls and elopement)
  • Skin Management and pressure wound prevention
  • Nutrition/Hydration
  • Pain Management
  • Medication Management (particularly psychotropics)
  • Infection Control (with emphasis on the COVID pandemic)

Of course, there are many other regulatory areas that present resident risk as well.  Enteral and parenteral feedings/fluids, respiratory care, dialysis, and behavioral health cannot be overlooked when considering areas that require auditing and monitoring as part of a successful Risk Management program.

The facility QAPI Process is one of the most important components of Risk Management. Utilizing strong audit tools to examine each of the nursing areas listed above is a main function of QAPI but also serves a significant role in the Risk Management process. Frequent review of nursing documentation to identify any areas that may benefit from additional staff education and/or oversight is crucial in identifying areas of risk.  Staff competency testing is another important element in identifying areas where a lack of staff education could pose the risk of a negative resident outcome.

A valuable resource for assistance in the development or augmentation of the Risk Management processes is the facility liability insurance carrier.  Many of these companies provide Risk Assessments as part of the insurance coverage that can help the facility to identify areas/issues that present enhanced risk to the facility. Many also have tools and educational resources available for facility use.

Join us on August 10th for the second webinar in the Dynamic DON series for tools, tips and more strategies on developing and implementing an effective Risk Management program.


Written by Janine Lehman, RN, RAC-CT, CLNC

Learn more about the rest of the Proactive team.