Failure to Assess, Order, and Care Plan Bed Rail Use Resulting in Fatal Entrapment
Summary
The deficiency involves the facility’s failure to follow its own policy and regulatory requirements for the assessment, ordering, care planning, and safe use of bed rails for a cognitively impaired resident. The resident was an elderly female with severe dementia, repeated falls, a fractured neck of the left femur, cognitive communication deficit, and a need for assistance with personal care. Her admission MDS showed a BIMS score of 03, indicating severe cognitive impairment, and documented that she required substantial staff assistance with bed mobility and was completely dependent on staff for transfers from bed to chair. Despite these needs, her care plan addressed ADL self-care performance deficits related to dementia and included interventions for bed mobility requiring one staff member to assist with repositioning, but it did not mention bed rails or any risk of entrapment. The facility obtained a bed rail consent form signed by the resident’s family member, which listed multiple potential dangers of bed rail use, including suffocation and various forms of entrapment that could cause injury or death. However, from the time of admission through the date of the incident, there was no documented bed rail safety or entrapment risk assessment for this resident, no physician order for bed rails, and no inclusion of bed rail use in the resident’s care plan. Maintenance staff reported that a charge nurse verbally requested installation of bed rails on the resident’s bed, and he believed the usual clinical steps—assessment, IDT review, consent, and physician order—had already been completed, but he had no documentation of when the rails were installed. The DON later confirmed that, for this resident, the required risk of entrapment assessment, physician order, and care plan focus for bed rails were not completed, and alternatives to bed rails were not attempted prior to installation, contrary to facility policy. On the night of the incident, a CNA observed the resident resting calmly around 2:00 a.m. During a subsequent round close to 5:00 a.m., the CNA found the resident partially out of bed with her head pinned between the assist bar/bed rail and the mattress, and notified the LVN. The LVN’s written statement described finding the resident seated on the floor on the right side of the bed, off the mattress, with her head resting between the side rail and the mattress, unresponsive. CPR was initiated and EMS was called, but the resident was later pronounced deceased. The county medical examiner reported that the resident had bruising and abrasions around the neck and jawline and hemorrhaging in the neck muscles, injuries consistent with being trapped between the mattress and bed rails, and indicated that the likely cause of death would be strangulation on the bed rails or asphyxiation on the mattress. Subsequent observation of the bed showed 1/3 bed rails of the same make and model as the bed frame and a low air loss mattress; while the rails were not loose and there was little space when the mattress was fully inflated, the air mattress could be compressed enough to create significant space between the mattress and rails. The facility’s failure to conduct a bed rail entrapment risk assessment, obtain a physician order, and incorporate bed rail use into the care plan prior to installation led to the resident’s entrapment and death, and constituted noncompliance identified as past Immediate Jeopardy. The facility’s written bed rail policy required that appropriate alternatives be attempted before installing bed rails, that the IDT assess each resident for entrapment risk, that risks and benefits be reviewed with the resident or representative, that informed consent be obtained prior to installation, and that manufacturer instructions and compatibility of bed, mattress, and rails be verified. It also required updating the care plan to reflect the need or choice for bed rails. In this case, staff interviews and record review showed that these steps were not followed for the resident involved. The DON acknowledged that the process did not occur as required, that the IDT did not meet to assess the resident for entrapment risk, and that the bed rails were installed based on the responsible party’s request without the mandated clinical review and documentation. This sequence of omissions and deviations from policy directly preceded the resident’s fatal entrapment between the bed rail and mattress.
Removal Plan
- Notify Medical Director
- Notify Ombudsman
- Conduct ad hoc QAPI
- DON to provide education to trainers regarding abuse and neglect
- Review admissions processes regarding bed rails and complete in-service with DON, ED, and IDT
- Provide in-service to all nurses involved with admissions process regarding bed rails
- Audit bed rails currently in use
- Inspect bed rails currently in use
- Verify consent on file for all bed rails in use
- Verify order and care plan for all bed rails
- Complete bed rail safety evaluation for all residents with bed rails
- Audit low air loss mattresses currently in use
- Verify order and care plan for all low air loss mattresses in use
- Complete fall risk assessment for all residents with low air loss mattress
- Provide staff education regarding use of enabler/bed rail
- Provide staff education regarding false safety
- Provide staff education regarding low air loss mattress
- Audit admissions for completion
- Audit low air loss mattresses and bedside rails
- Conduct ongoing monitoring for improvement to be reviewed at QAPI
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Bed rails were used for three residents without the required documentation and authorization. One resident with hemiplegia and fluctuating decision-making capacity had bilateral half side rails in use, but RN and DON stated there was no current physician order or care plan for side rail use. Two other residents, including one with Alzheimer's disease and seizures and another with hemiplegia and intact cognition, had orders and assessments for 1/4 rails, but were observed or documented with 1/2 rails instead; the DSD and DON stated the specific 1/2 rail use lacked the proper order, informed consent, assessment, and care plan.
A resident with intracranial hemorrhage, respiratory failure, and hypertensive emergency was observed with all four bed rails raised, even though the physician's order and informed consent only addressed bilateral upper half side rails. Staff interviews confirmed the resident was being positioned with four side rails without a specific order or consent for that setup, and the facility policy required informed consent before bed rail use.
The facility failed to complete ongoing accurate assessments for bedrail use for two residents. One resident had weakness, a right BKA, and bilateral enabler bars, while another had CVA with left-sided paralysis and a left enabler bar. Both residents’ last Enabler/Assist Rail/Device Evaluation - V2 assessments were completed about a year earlier, and the ADON confirmed assessments should be done quarterly.
A resident with intact cognition and multiple serious diagnoses had half bedrails placed on both sides of his bed without a documented side rail assessment, informed consent, or evidence that alternatives were tried first. Staff interviews showed the Maintenance Supervisor was told to install the rails without being shown a signed consent, while RN and ADON staff were unaware the rails were in place or that the required documentation was missing. The resident stated he did not request the bedrails and was never spoken to about them.
A resident with severe cognitive impairment and a history of recent falls was repeatedly observed asleep in bed with bilateral upper grab rails elevated. The care plan, updated after the falls, included side rails as grab bars for fall prevention and assistance with repositioning, but the bed rail assessment documented that side rails or assist bars were not indicated, and no bed rail entrapment risk assessment was found. Staff interviews confirmed that the resident used the grab rails for turning and repositioning and that the care plan called for grab bars despite the assessment indicating otherwise, resulting in a deficiency for failing to ensure safe and properly assessed side rail use.
The facility failed to document alternative measures, risk-benefit discussion, and informed consent before side rail use for two residents. One resident with ESRD and severe cognitive impairment and another resident with dementia and intellectual disabilities were observed with side rails raised in bed, but records showed no current order for side rails and no documented evidence that alternatives were explored or that risks and benefits were reviewed with the resident or RP.
Bed rails used without required orders, consent, assessments, and care plans
Penalty
Summary
The facility failed to safely use bed rails for three sampled residents by not ensuring the required physician orders, informed consent, bed rail assessments, and care plans were in place for the specific bed rail use observed. The report states that the facility used bed rails without meeting its own criteria for use, and that staff and leadership acknowledged the need for a resident assessment, entrapment assessment, consent, physician order, and care plan before bed rails are used. Resident 11 was admitted with diagnoses including hemiplegia, hemiparesis following cerebral infarction, type II DM, and generalized muscle weakness. The H&P noted fluctuating capacity to understand and make decisions. The MDS showed the resident needed supervision or touching assistance with toileting, personal hygiene, showering, and lower body dressing, and was independent with rolling and sit-to-lying. During observation, the resident was seen in bed with bilateral side rails elevated, and CNA 4 stated the resident requested the side rails be elevated at all times. RN 5 reviewed the record and stated there was no current physician order for side rail use and no care plan documented for side rail use. The DON stated side rail use required assessment for risks and benefits, entrapment assessment, consent, a physician order, and inclusion in the comprehensive person-centered care plan. Resident 22 had diagnoses including Alzheimer's disease, contracture, and seizures, and the H&P stated the resident did not have capacity to understand and make decisions. The MDS indicated severely impaired cognition and dependence for mobility and ADLs. The OSR contained an order for padded side rails up times 2 top of quarter for mobility/enabler every shift for seizures, and the BRERO assessed quarter rails. However, during observation the resident's bed rails were identified as 1/2 length. The DSD stated the resident had an order for 1/4 padded side rails/bedrails but no order for the 1/2 bed rails actually in use, and that the BRERO and consent were for a 1/4 bed rail. Resident 163 had diagnoses including hemiplegia, hemiparesis following cerebral infarction, and disorders of bone density and structure of the left hand. The MDS showed intact cognition and dependence to partial assistance with mobility and ADLs. The OSR ordered may have 1/4 side rails up x 2 for mobility aid, and the BROA assessed bilateral 1/4 bedrails, but the DSD stated the resident was on 1/2 bed rails without a specific order, informed consent, bed rail assessment, or care plan for that use.
Failure to Obtain Consent and Order for Four Side Rails
Penalty
Summary
The facility failed to obtain consent and a physician's order for the use of four side rails for Resident 116. Resident 116 was admitted with diagnoses including nontraumatic intracranial hemorrhage, respiratory failure, and hypertensive emergency. The MD progress notes dated 7/9/2025 indicated the resident did not have the capacity to understand and make decisions. The physician's order dated 1/8/2026 directed bilateral upper half siderails up and locked when in bed for ADL changes, and the resident's informed consent dated 7/9/2025 also addressed bilateral upper half side rails up when in bed secondary to involuntary movement by gravity due to elevated head of bed for management and provision of enteral feeding. During observation on 4/20/2026, Resident 116 was seen in bed with upper and lower bed side rails raised on both sides, and later with the left and right upper side rails raised and the right lower side rail raised while CNA 3 stated the resident was supposed to have all four side rails raised up. DSD later stated the resident should only have upper side rails up per the physician's orders. ADON 1 reviewed the informed consent and stated there was no informed consent or physician's order for all four side rails, and that a specific informed consent and physician's order were required for four side rails. The facility policy stated bed rails are prohibited unless criteria are met and that informed consent must be obtained before using bed rails.
Failure to Reassess Bedrail Use and Risk
Penalty
Summary
The facility failed to conduct ongoing accurate assessments to ensure that bedrails were used to meet residents’ needs and to evaluate the risks associated with bedrail use for two residents. Facility policy titled Proper use of Bed Rails, dated 1/15/26, required resident assessment of risk from using bed rails, including risk of entrapment between the mattress and bed rail or in the bed rail itself, with reassessments at least quarterly, after a significant change in status, or when the type of bed, mattress, or rail changed. Resident R3 was admitted with diagnoses including high blood pressure, hyperlipidemia, and muscle weakness, and the care plan identified an ADL self-care deficit related to weakness/deconditioning and a right below-the-knee amputation, with bilateral enabler bars used to assist mobility. The last Enabler/Assist Rail/Device Evaluation - V2 assessment for R3 was completed on 4/11/25, yet bilateral enabler bars were observed on the bed during an observation on 4/13/26. Resident R7 was admitted with diagnoses including high blood pressure, hemiplegia, and CVA, and the care plan identified an ADL self-care deficit related to CVA with left-sided paralysis, with a physician order for a left enabler bar to assist with mobility and positioning. The last Enabler/Assist Rail/Device Evaluation - V2 assessment for R7 was also completed on 4/11/25, and a left enabler bar was observed on the bed during the same observation date. The ADON stated that enabler bar assessments should be done quarterly and confirmed the facility failed to conduct ongoing accurate assessments for these two residents.
Bedrails Installed Without Assessment or Informed Consent
Penalty
Summary
The facility failed to attempt alternatives before installing half bedrails on both sides of Resident #9's bed, failed to obtain informed consent before installation, and failed to ensure correct installation and maintenance of the bedrails. Record review showed that Resident #9 was a cognitively intact male with a BIMS score of 15 and diagnoses including type 2 diabetes mellitus, cerebrovascular accident, bilateral below-the-knee leg absence, and dependence on renal dialysis. His MDS did not address bedrail use, and his care plan addressed bed mobility assistance but did not reflect bedrails. The EHR also showed no side rail evaluation. Observation on 04/14/26 showed half bedrails on both sides of Resident #9's bed. The Maintenance Supervisor stated that the previous DON told him to place the bedrails on the resident's bed, but he was not shown a signed consent despite asking for it. He stated he understood consent was needed to show the resident had been evaluated and agreed to the bedrails, and he said he should have notified the Administrator before installing them when consent was not provided. He also stated he checks the rails weekly to ensure they are securely placed. Interviews showed staff were unaware of the bedrails or the required documentation. RN B stated she did not know Resident #9 had half bedrails and said she did not believe they were a restraint, though she acknowledged a resident could get an arm stuck and be hurt and that an assessment should be completed before bedrails are placed. ADON C stated Resident #9 should have had an assessment, care plan, and consent, and the DON stated residents with half bedrails should have a bedrail assessment, consent, care plan intervention, and nurse documentation. Resident #9 stated he did not request the bedrails, no staff spoke with him about them, and he was not given a consent or assessment. The facility policy stated alternatives should be attempted before installing bedrails and that assessment, informed consent, and proper installation and maintenance were required.
Inconsistent Bed Rail Assessment and Use After Resident Falls
Penalty
Summary
The deficiency involves the facility’s failure to ensure that a resident’s use of side rails was consistent with the facility’s bed safety policy and the resident’s own assessments and care plan. The facility’s policy required the IDT to assess the resident’s sleeping environment, consider safety, medical conditions, comfort, freedom of movement, and input from the resident/family, and to use side rails only when needed to manage a medical symptom or to assist with repositioning or transfers when no other reasonable alternatives were identified. Surveyors observed the resident on multiple occasions lying in bed asleep with bilateral upper grab rails elevated. The resident’s MDS showed severe cognitive impairment, no impairment to upper or lower extremities, and a need for staff supervision for bed mobility. Progress notes documented that the resident was found on the floor on one occasion and kneeling on a floor mat on another occasion. Following these falls, the resident’s plan of care was updated with a problem addressing an actual fall, and the interventions included providing side rails to be used as grab bars. However, the resident’s Bed Rail Assessment dated the same month indicated that side rails or assist bars were not indicated for this resident, and there was no documentation of a bed rail entrapment risk assessment being conducted at that time. During interviews, a CNA confirmed that the resident used the grab rails to hold on when turning and repositioning, and an RN confirmed that the fall care plan interventions included grab bars while also verifying that the bed rail assessment showed grab rails were not indicated. This inconsistency between the care plan, the bed rail assessment, and the actual use of side rails led to the cited deficiency for failing to ensure the resident was free from accident hazards related to side rail use.
Failure to Document Alternatives, Risk-Benefit Discussion, and Informed Consent for Side Rail Use
Penalty
Summary
The facility failed to ensure that alternative measures were tried before side rails were used, and failed to document discussion of risks versus benefits and obtain informed consent for side rail use for two residents. The report states that these issues were identified for R3 and R6 during observation, interview, record review, and policy review. The deficiency involved side rail use without a current physician order and without the required documentation in the residents’ records. R3 was admitted with end stage renal disease and had a BIMS score of 3, indicating severe cognitive impairment. R3’s care plan listed upper side rails for mobility, and during observation R3 was resting in bed with the head of bed upright and side rails up on both sides. The side rail/entrapment evaluation for R3 showed no documentation that alternatives were explored before bed rail use, and there was no documentation of risks versus benefits or informed consent. The RNN stated the facility did not try alternatives before bedrail use for R3, did not discuss risks and benefits, and had nothing for the resident to sign for informed consent. R6 was admitted with mild intellectual disabilities and dementia and also had a BIMS score of 3. R6’s care plan included side rails up while in bed to aid in bed mobility and transfers, and during observation R6 was lying in bed with the head of bed elevated and bilateral half side rails raised. The side rail evaluation completed after the surveyor identified concern showed side rails were used, but the record contained no documented evidence of what alternatives were explored before implementation and no documented evidence that risks versus benefits were explained to the responsible party or that informed consent was obtained. The facility policy stated bedrails could be considered a form of physical restraint and that the need for bedrails should be identified in the resident assessment and plan of care.
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