11/12/2026

Survey Tip of the Week: Involuntary Seclusion

Residents residing in secured or locked units, including memory care units, have the right to be free from involuntary seclusion. Under F603 (§483.12(a)(1)), facilities must ensure that placement in a secured unit is clinically justified, individualized, and not based solely on a diagnosis, family request, or staff convenience. 

Involuntary seclusion is defined as separation of a resident from other residents or from her/his room or confinement to her/his room (with or without roommates) against the resident’s will, or the will of the resident representative. Involuntary seclusion could mean a resident placed in a secured area of the facility, but does not meet the criteria for the unit and is not provided with access codes or other information for independent egress. 

CMS identifies specific considerations for determining whether placement in a secured unit constitutes involuntary seclusion. Facilities should ensure the following are in place: 

• Established clinical criteria: The facility has identified clinical criteria for placement in the secured unit. Placement decisions are individualized and not based on a diagnosis alone. 
• Clinical justification: The medical record includes documentation from the resident's physician, along with information from the interdisciplinary team, supporting how the resident meets the criteria for placement. 
• Resident/representative involvement: Documentation reflects the resident's and/or representative's involvement in the decision to place the resident in the secured unit and in developing the care plan. 
• Least restrictive approach: Documentation supports that placement in the secured unit is the least restrictive reasonable approach to protect the resident's health and safety. 
• Resident response: The interdisciplinary team documents the resident's reaction or response to placement, including any concerns or objections. 
• Ongoing evaluation: The interdisciplinary team periodically reviews whether the resident continues to meet the criteria for secured placement and revises the care plan as necessary. 
• Access and visitation: Family members, representatives, and other visitors have immediate access, subject to reasonable clinical and safety restrictions and the resident's right to refuse visitation. 

A resident who chooses to live in the secured/locked unit (e.g., the spouse of a resident who resides in the area), and does not meet the criteria for placement, must have access to the method of opening doors independently. The chosen method for opening doors (e.g., distribution of access code information) is not specified by CMS. Staff should be aware of which residents have access to opening doors and monitor their use of the access to ensure other residents’ safety.