This week’s “Ftag of the Week” is F610 Investigate / Prevent/ Correct Alleged Violations, which is part of the Freedom from Abuse, Neglect, and Exploitation regulatory group. While the regulation itself was not changed when the Requirements of Participation (RoPs) were updated, the Interpretive Guidance (IG) has been significantly expanded to state what providers are required to do in response to an allegation of abuse, neglect, exploitation or mistreatment. The facility must conduct a thorough investigation, prevent further abuse/ neglect/ exploitation/ mistreatment from occurring while the investigation is being conducted, and take appropriate action based on the findings of the investigation.
The facility’s responsibility for investigation includes conducting observations of the alleged victim and associated people and locations where the alleged situation occurred. The facility also needs to conduct interviews, as appropriate, with the alleged victim/representative, the alleged perpetrator, and other witnesses or others who may be able to provide insight. Additionally, a record review of information related to the alleged incident needs to be reviewed. It remains the responsibility of the facility to conduct its own investigation even if law enforcement has been notified related to reasonable suspicion of a crime, but the facility needs to ensure that it does not impede a law enforcement investigation.
While the investigation is underway, the facility is also responsible for ensuring that further potential abuse/ neglect/ exploitation/ mistreatment does not occur, depending on the nature of the allegation. This includes taking measures to protect residents and ensure that they feel safe. The resident should be immediately assessed, and notification immediately provided to the alleged victim’s practitioner and representative/family, as needed. Ensuring that the alleged perpetrator does not have access to the alleged victim and that immediate steps have been taken if necessary to alleviate the alleged victim’s fear is also expected.
Once the investigation has concluded, appropriate steps to protect residents should be taken if the alleged violation is verified. Corrective actions should be monitored by the facility and the QAA Committee to determine their effectiveness, and the QAA Committee should also monitor to ensure that the residents are protected from future incidents.
The guidance really lays out what should be your actions following any allegation of abuse, neglect, exploitation or mistreatment. If these actions are not routine practice in your facility, they should be with immediate attention given to the protection of the alleged victim. Once you have conducted a thorough investigation a comprehensive, well-organized investigative summary should finish off your investigation and be readily available for any agency to which you have made an appropriate report.