In this edition of The State of IJs, we’re spotlighting Immediate Jeopardy (IJ) citations issued to nursing homes across Michigan. These citations represent the most serious level of noncompliance, where resident safety is at immediate risk. Understanding the patterns behind these citations can help providers proactively address vulnerabilities and improve care outcomes.
Top Areas of Noncompliance
The most frequently cited IJ deficiencies in 2025 in Michigan include:
- F689 – Free of Accident Hazards/Supervision/Devices
- F600 – Free from Abuse/Neglect
I am sure neither of these areas come as a surprise to any of us reading this – but today’s spotlight is going to be on Accidents as approximately 50% of IJs in Michigan are at F689.
F689 – Accidents (Hot Water Temperatures)
Accident prevention is always on the mind of Administration in any nursing home, and this is because a negative outcome for a resident many times has harm associated with it when cited by the State Agency. F689 was discussed last week during a look at what was cited in Arkansas from the perspective of a transportation incident. This week we are going to look at Accidents from a totally different point of view resulting in a scope and severity citation of “J” for one facility, but a for a high-risk area every Maintenance/Engineering Department.
A facility had excessive hot water temperatures identified on a Dementia Unit, which obviously has a vulnerable population. One resident room’s bathroom water temperature was 144.6 degrees Fahrenheit, and another was tested with results at 150 degrees Fahrenheit. (I hope everyone is saying “WOW” here.) DOH documented in the Statement of Deficiencies (SOD) that both residents were ambulatory – meaning they could easily have gone into the shower in their room and turned on the hot water with the possibility of sustaining a burn. Couple that with the facility-wide bathroom water temperature being temped at greater than 120 degrees Fahrenheit and you end up with a very bad situation.
Additional major concerns were identified with the routine monitoring of water temperatures throughout the building, content of logs to validate temperature were being obtained as well as the device used to monitor the temperature breaking and the maintenance staff member responsible for testing using a digital thermometer instead. In this case, some logs were not available, and some entries indicated high temperature readings without follow-up.
The State Agency included in the SOD references to the content of the State Operations Manual related to water temperatures as well as noted that some states have regulations specific to the maximum allowable water temperature. Also referenced was a table that illustrated damage to skin in relationship to temperature of the water and the time of exposure. I think we all get the message and the type of systems that need to in place to maintain the hot water temperature in the range of 100-120 degrees Fahrenheit or State-specific temperature safe hot water range.
Compliance Insights
To prevent issues being identified with your hot water temperature here are some recommendations to consider, if not already in place, to avoid a citation in this area:
Maintenance needs to have a monitoring system in place for testing of water temperatures in random locations, including public areas, resident bathrooms, shower rooms.
- A log needs to be maintained for location of testing, test results, any unacceptable findings as the corrective action
- The logs should be fully completed and maintained in a file
- Responsibility should be assigned for reviewing the content of the logs on a routine basis
Any complaint of the water “feeling too hot” requires prompt follow-up.
Of note in another State, a State Agency Surveyor was the person to report that the water felt “hot” in the staff bathroom and requested the water be temped and requested the results of the testing, directed additional testing be completed and cited the facility at an IJ level as well.
- Make sure that the Engineering/Maintenance staff is familiar with your State’s maximum hot water temperature allowance.
- Routine monitoring of the boiler’s temperature should be completed by the Engineering/Maintenance staff – a call to an outside plumbing vendor may be necessary – maybe you need more than adjusting the mixing valve.
- Have an appropriate temperature monitoring device available for staff use and educate staff of their responsibility to ensure that the Maintenance Supervisor is made aware of the device not functioning.
🚨 Immediate Jeopardy? We’re the Team You Call First
When a nursing home receives an Immediate Jeopardy citation, every moment counts. CMS Compliance Group has the deep regulatory expertise and hands-on experience to help you respond effectively and restore compliance—fast.
Our IJ consulting services include:
- Immediate Response Support – We help you assess the situation, develop a targeted Plan of Correction, and communicate with surveyors.
- Root Cause Analysis & Documentation Guidance – We’ll help you identify clear, defensible findings that satisfy CMS expectations.
- Post-IJ Recovery – Strengthen systems, retrain staff, and prevent repeat deficiencies.
We’ve supported facilities nationwide through the most serious survey outcomes—and helped them come out stronger.
Call (631) 692-4422 or visit cmscompliancegroup.com to connect with our team.
