Room and Roommate Changes – What You Need to Know

October 2023

As many of you know, a major focus on the regulatory changes contained within the Requirements of Participation (ROP) involve Resident Rights and the facility’s need to ensure each resident remains the locus of control regarding decision-making, their care and services, and discharge planning. An area to highlight is room/roommate changes, this was a Phase 1 requirement.

Residents have a right to share a room with whomever they wish, as long as both residents agree. According to federal guidance, these arrangements could include “opposite-sex and same-sex married couples or domestic partners, siblings, or friends.” There are some limitations to these rights, however. Residents do not have the right to demand that a current roommate is displaced to accommodate the couple that wishes to room together. In addition, residents are not able to share a room if one of the residents has a different payment source for which the facility is not certified (if the room is in a distinct part of the facility, unless one of the residents elects to pay privately for his or her care) or one of the individuals is not eligible to reside in a nursing home.

According to the Federal Register/Vol.81, No.192, Resident Rights 483.10, each resident must receive written notice from the facility, including the reason for the change, before the resident’s room or roommate is changed. The resident also has the right to refuse to transfer to another room of the facility for the following specific reasons outlined in the rule:

• To relocate a resident of a SNF from the distinct part of the institution that is a SNF to a part of the institution that is not a SNF, or
• To relocate a resident of a Nursing Facility (NF) from the distinct part of the institution that is a NF to a distinct part of the institution that is a SNF, or
• Solely for the convenience of staff.
• The Washington Administrative Code (WAC), Chapter 388-97-0580 requires the facility to ensure residents receive three days’ notice of change in room or roommate except:
• For room changes when the move is at the resident’s request
• When a longer or shorter notice is required to protect the health or safety of the resident or another resident; or
• An admission to the facility is necessary, and the resident is informed in advance.

The WAC also requires the facility to recognize that the change may be traumatic for the resident and take steps to lessen the trauma. The requirements related to roommates and room moves are outlined in F559 and F560. The guidance to surveyors also calls out the need for facility staff to recognize and address resident trauma, clearly stating the following:

“Moving to a new room or changing roommates is challenging for residents. A resident’s preferences should be taken into account when considering such changes. When a resident is being moved at the request of facility staff, the resident, family, and/or resident representative must receive an explanation in writing of why the move is required. The resident should be provided the opportunity to see the new location, meet the new roommate, and ask questions about the move. A resident receiving a new roommate should be given as much advance notice as possible. The resident should be supported when a roommate passes away by providing time to adjust before moving another person into the room. The length of time needed to adjust may differ depending upon the resident. Facility staff should provide necessary social services for a resident who is grieving over the death of a roommate.”

Each facility needs to have an established system and ensure that both the federal and the state requirements are met for all room and roommate changes. Documentation needs to reflect that residents and their representatives received the necessary notice and any rationale for the change and action taken.

Keep in mind if there is a complaint investigation by Residential Care Services (RCS) staff regarding this issue, one of the first things a facility will need to produce is evidence of written notice that meets the federal requirements, as well as documentation as to why a resident’s refusal did/did not meet the criteria outlined, and that the resident received three days’ notice of the change as required by the State of Washington. Facilities should have a policy and procedure to ensure that both the state and the federal requirements are met, and that staff are trained to implement the policy accordingly. Resident record documentation needs to reflect the steps taken to mitigate resident trauma and any necessary follow up.

If you have questions regarding the SNF requirements, please contact Elena Madrid or call at (800) 562-6170, extension 105.