This week on the CMSCG Blog, we will review four Ftags that are part of the Physical Environment regulatory group, including F911 Bedroom Number of Residents, F912 Bedrooms Measure at Least 80 Sq Ft/Resident, F913 Bedrooms have Direct Access to Corridor and F914 Bedrooms Assure Full Visual Privacy.
F911 Bedroom Number of Residents
F911 requires that bedrooms accommodate no more than four residents in them. For new construction or newly certified facilities (after 11/28/2016), bedrooms may not be used for more than 2 residents. Variances may be granted when a facility has applied for them and in the case of a natural disaster, a Section 1135 waiver may be granted.
How It’s Cited
Citations under F911 tend to be cited at a S/S of B as part of a variance review on survey. Surveyors will conduct observations during survey for rooms with more than four residents to see if residents have ample room to move around and for care to be provided. They will also speak to the residents to see how they feel about the space they have. One facility was denied the variance after a resident voiced his concerns that he did not have a bedside table and felt there was a lack of space and lack of room for care equipment, which meant that the variance was infringing on the resident’s special needs.
F912 Bedrooms Measure at Least 80 Square Ft/Resident
The regulation at F912 requires that each resident must have at least 80 square feet of useable living space in multiple resident rooms and at least 100 square feet of useable living space for single rooms. Like at F911, variances may be permitted when a facility provides written evidence that the variations are in accordance with residents’ special needs and will not adversely affect resident health or safety. Appendix PP clearly states that facility hardship is not considered a basis for granting a variance and that since residents’ needs or the residents in the rooms may change periodically, the variances will be reviewed and considered for renewal whenever there is a facility recertification. If no changes have been made since the last recertification survey, the variance may continue.
The Interpretive Guidance (IG) includes specific details related to how square footage should be measured:
- Useable living space is considered the floor’s measurements exclusive of toilet/bathing areas, closets, lockers, wardrobes, alcoves or vestibules (unless the alcove/vestibule provides useful living area).
- Non-permanent items of a resident’s choice should not be included in calculating useable living space.
- Moveable wardrobes should be excluded from the useable square footage unless the resident has chosen to have it and it is in addition to individual closet space in the resident’s room.
- The swing/arc of a door that opens directly into a resident’s room should be included in calculations.
- If the area involved in a protruding area of the room is minimal and does not negatively impact the resident’s health or safety, it can also be excluded from the useable square footage calculation. This means that protrusions – radiators, columns, ventilation systems, etc. – that do not protrude more than 6-8 inches from the wall or for columns, have more than 6-8 inches on each side.
How It’s Cited
- One facility received a widespread S/S deficiency (S/S: F) for having multiple residents in rooms with two beds after a waiver had been requested and denied.
- Another facility was cited at a S/S: E for having bedrooms without sufficient square footage, even after surveyors interviewed residents who stated that they loved their rooms, had been offered the ability to move to another room and did not have any issues. A recommendation to continue the room size waiver was made.
- Conversely, another facility was cited at a S/S: E under F912 when a resident interviewed during the initial pool process complained that his room was too small. The resident stated that he needed to move his bed to get to his nightstand and another resident had to be moved out into the hallway in her bed in order to accommodate a Hoyer lift.
F913 Bedrooms Have Direct Access to Exit Corridor
The regulation at F913 states that resident bedrooms must have direct access to an exit corridor. This means that residents must be able to pass directly into the hallway without having to go through another room. There are no variances available for this. A citation for F913 (S/S: B) was given to a facility that had multiple resident bedrooms that required residents to leave their rooms, enter another resident’s room and walk through that to get to the exit corridor. Surveyors noted that throughout survey, staff were able to provide treatments and services and residents were fully ambulatory. On interview, residents and their families did not complain about the lack of direct corridor access.
F914 Bedrooms Assure Full Visual Privacy
F914 requires that each bed must have ceiling-suspended curtains that extend around the bed to provide total visual privacy in combination with adjacent walls and curtains for all bedrooms in facilities certified after 1992 except for private rooms. Full visual privacy is defined in the IG as ensuring that residents have the means to completely withdraw from public view without staff assistance while they are in bed. The IG also notes that facilities are not limited to curtains and may design or equip the room however it meets the needs of the residents.
How It’s Cited
- Facilities are generally cited under F914 as a result of surveyor observations. Surveyors will identify curtains that are too short, missing entirely or not able to completely close.
- One facility was cited after an interview of a resident who stated that his roommate required total care and that the privacy curtain had a gap that meant he often saw his roommate receiving incontinence care and that he felt exposed to his roommate during bed baths and care.
While these regulations are not widely cited, they also shouldn’t be ignored. In some cases, citations were given after resident/representative interviews where they stated their discontent with their accommodations. There’s no reason to wait until survey to identify if your residents’ needs are not being met. Some of these citations also reflect the need to reviews systems around maintenance logs and who is responsible for reporting concerns that need to be addressed, such as the insufficiency of privacy curtains, so that these items may be addressed timely.