F700 Guidance—Bedrails

The Phase 2 changes and Phase 3 Requirements of Participation (ROP) that took effect in October 2022 for all nursing homes included clarification and regulatory requirements around a facility’s use of bedrails/siderails. In F700, the Centers for Medicare and Medicaid Services (CMS) spells out that facilities must attempt to use appropriate alternatives prior to installation or the “use” of bedrails. Additional requirements and clarifications are outlined below:

CMS makes it clear that the intent of F700 is to ensure that prior to the installation or use of bed rails, the facility attempts to use alternatives. If the attempted alternatives are not adequate to meet the resident’s needs, the resident is then assessed for the use of bed rails, which needs to include a review of risks including entrapment. Informed consent must be obtained from the resident or if applicable, the resident representative.

In the guidance, CMS notes that after a facility has first attempted to use appropriate alternatives to bed rails and determined that these alternatives do not meet the resident’s needs, the facility must assess the resident for the risks of entrapment and review possible risks and benefits of bed rails prior to installation or use. In determining whether to use bed rails to meet the needs of a resident, the following components of the resident assessment should be considered including, but not limited to:

In addition, the resident assessment must include an evaluation of the alternatives that were attempted prior to the installation or use of a bed rail and how these alternatives failed to meet the resident’s assessed needs. The facility must also assess the resident’s risk from using bed rails. Additional information regarding risks associated with side/bedrails can be found in the F700 Guidance.

The facility is expected to maintain evidence that they have provided sufficient information so that the resident or resident representative was able to make an informed decision. Information that the facility should provide to the resident, or resident representative should include, but is not limited to the following:

CMS encourages facilities to refer to published information from recognized authorities such as the Food and Drug Administration, which has identified the following alternatives to bed rail use: “Alternatives include roll guards, foam bumpers, lowering the bed and using concave mattresses that can help reduce rolling off the bed.” More information and resources with links to alternatives can be found in F700 Guidance. If no appropriate alternative was identified, the medical record must include evidence of the following:

CMS places a focus on the correct installation and maintenance of bed rails being an essential component in reducing the risk of injury resulting from entrapment or falls. According to CMS, the FDA, and the United States Consumer Product Safety Commission (CPSC) has recommended the following initial and ongoing actions to prevent deaths and injuries from entrapment and/or falls from bed rails:

Before bed rails are installed, the facility should:

NOTE: If a facility is unable to identify the manufacturer and access the manufacturer information and guidance for bed rails that they use, they would not meet requirements to follow the manufacturers’ recommendations and specifications for installing and maintaining bed rails.

When installing and using bed rails, the facility should:

Facilities must also conduct routine preventive maintenance of beds and bed rails to ensure they meet current safety standards and are not in need of repair. CMS expects facilities to have a process for determining whether beds, including mattresses and rails, are appropriate and safe for their residents.

Also, facilities should follow manufacturers’ recommendations/instructions regarding disabling or tying rails down. CMS regulations do not specify that bed rails must be removed or disabled when not in use. However, CMS clearly states that if bed rails are not appropriate for the resident and the facility chooses to keep the bed rail on the bed, but in the down position, raising the rail even for episodic use during care would be considered noncompliance if all of the requirements (assessment, informed consent, appropriateness of bed, and inspection and maintenance) are not met prior to the episodic bedrail use for the resident.

Another component necessary to ensure facility compliance is the expectation of ongoing monitoring and supervision of the resident when bed rails are in use. This should be evidenced in the residents’ records, including their care plan. Information should include, but not limited to the following information:

SNF Questions?

Please email Elena Madrid, or call her at 1-800-562-6170 extension 105.