Failure to Follow Protocols for Physical Restraint Use During Dental Procedures
Penalty
Summary
The facility failed to ensure that physical restraints were implemented in accordance with regulatory requirements and facility policy for three residents with intellectual disabilities who received dental care. Specifically, the use of physical restraints such as hand restraints, leg wraps, and body wraps during dental procedures was not supported by documented medical symptoms warranting their use, nor were provider orders obtained for the specific type of restraint applied. Additionally, there was no evidence that less restrictive interventions were attempted prior to the application of restraints, as required by both facility policy and federal guidelines. For each of the three residents reviewed, medical records and dental progress notes lacked documentation of the necessary assessments, provider orders, and justification for restraint use. The residents involved had significant cognitive impairments and, in some cases, additional diagnoses such as cerebral palsy, epilepsy, and anxiety. Despite these complex needs, the records did not reflect individualized assessment or documentation of behaviors that would necessitate restraint, nor did they show that alternative, less restrictive measures were considered or tried before restraints were used during dental procedures. Interviews with facility staff, including the DON and dental hygienist, confirmed that the required processes for restraint implementation were not being followed. Staff acknowledged that provider orders were not obtained, the restraint orders and monitoring form was not completed, and least restrictive measures were not consistently attempted. Annual consents were obtained from resident representatives, but this did not substitute for the required documentation and clinical justification for each instance of restraint use. The deficiency was further confirmed by the facility administrator, who stated that the correct process for implementing physical restraints during dental procedures was not being followed.