CMS SOM App. U, Tag R109

Interpretive Guidelines: §403.730(c)(4)

Restraint and seclusion use may constitute an accident hazard. Professional standards of

practice have eliminated the need for physical restraints except under limited medical

circumstances. RNHCIs may not use restraints.

The facility may not use restraints in violation of the regulation solely because a

surrogate or representative has approved or requested them.

Restraints means any manual method or physical or mechanical device, material, or

equipment attached or adjacent to the patient’s body that the individual cannot remove

easily which restricts freedom of movement or normal access to one’s body.

Restraints include, but are not limited to, leg restraints, arm restraints, hand mitts, soft

ties or vests, lap cushions and lap trays the patient cannot remove. Also included as

restraints are facility practices such as:

• Using bed rails to keep a patient from voluntarily getting out of bed as opposed to

enhancing mobility while in bed;

• Tucking in a sheet so tightly that a bed bound patient cannot move;

• Using wheelchair safety bars to prevent a patient from rising from the chair;

• Placing a patient in a chair that prevents rising; and

• Placing a patient who uses a wheelchair so close to a wall that the wall prevents

the patient from rising.

Survey Procedures:

• Interview staff and ask them to describe use of restraints. Does staff allude to the

use of restraints?

• If a patient is considered to be at risk for harm to self or others, ask staff to

describe processes used to ensure patient safety.