06/26/2025

Survey Tip of the Week: Lift Transfers and Harm Citations

Recent harm-level citations have been issued when lift devices were not used according to the manufacturer's instructions or the facility’s internal policies. In these cases, issues were consistently related to gaps in nursing assistant competency and staffing practices. For example, staff did not fully understand the lift policy for all device types, used manual transfers when the lift was not functioning, believed they were strong or capable enough to complete the transfer on their own or partially alone while waiting for help, applied the sling incorrectly or selected the wrong type of sling, or chose not to retrieve the lift or locate a second staff member due to time pressures.

Providers should remember that manufacturer guidelines can vary significantly depending on the type of lift. For example, a mechanical sit-to-stand lift may specify not only the number of staff required but also that a resident-specific clinical assessment must be completed by a qualified individual to determine whether the lift is appropriate for that resident. Under F-tag 689, §483.25 Accidents, CMS states that the facility must implement interventions, including adequate supervision and assistive devices, consistent with a resident’s needs, goals, care plan and current professional standards of practice in order to eliminate the risk, if possible, and, if not, reduce the risk of an accident.

Some providers choose to adopt a facility-wide policy requiring two staff members for all lift transfers, regardless of the type of lift used. This approach is part of a broader system-based effort to prevent injuries and improve resident safety. The CMS State Operations Manual Appendix PP further notes that a facility’s interdisciplinary and systematic approach may include:

• Identification of hazards, including inadequate supervision, and a resident’s risks of potentially avoidable accidents in the resident environment;
• Evaluation and analysis of hazards and risks;
• Implementation of individualized, resident-centered interventions, including adequate supervision and assistive devices, to reduce individual risks related to hazards in the environment; and
• Monitoring for effectiveness and modification of interventions when necessary.

A key element of a systematic approach is the consistent application of a process to address identified hazards and/or risks. Risks may pertain to individual residents, groups of residents, or the entire facility. Hazards may include, but are not limited to, aspects of the physical plant, equipment, and devices that are defective or are not used properly (per manufacturer’s specifications), are disabled/removed, or are not individually adapted or fitted to the resident’s needs. An effective system not only proactively identifies environmental hazards and the resident’s risk for an avoidable accident, but also evaluates the resident’s need for supervision.

LeadingAge Ohio encourages facilities to monitor compliance using the surveyor guidance found in the State Operations Manual Appendix PP. Additionally, the survey pathways can be found in the Survey Resources zip file on the CMS Nursing Home webpage and under the downloads section on this CMS webpage. LeadingAge Ohio has provided survey tips to help navigate the changes in the revised QSO-25-14- NH memo. The previously provided survey tips can be accessed on the LeadingAge Ohio webpage under the Communications tab, then The Source tab. CMS has updated the survey resources on the CMS Nursing Home webpage in accordance with the revised QSO-25-14- NH memo. LeadingAge has developed webinars and resources on the requirements of participation which are located on the LeadingAge learning hub. LeadingAge continues to add QuickCasts on the regulatory groups. Updated resources have also been added on the Nursing Home RoP Tools and Resources webpage.

For more information about the requirements of participation and citations occurring in Ohio, please join us on the monthly STAT: Survey Tips and Tactics call. Register now for the July 9 call at 11:00AM. LeadingAge Ohio is sharing tips to assist members during the survey process. Send questions you would like addressed in future Tips of the Week to Stephanie DeWees at sdewees@leadingageohio.org.