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 CMS Guidelines

Alarms and Restraints                           ​

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CMS Guidelines on Alarms & Restraints

Is upBed considered a restraint under the new CMS guidelines? The short answer no, but it is up to some interpretation and proper use. We've gathered information below to better inform you on the guidelines, and how best to use upBed to adhere with the guidelines. First and foremost, under the new guidelines a restraint is defined as follows:
"Any manual method or physical or mechanical device, material or equipment attached or adjacent to the resident’s body that the 
individual cannot remove easily, which restricts freedom of movement or normal access to one’s body"
upBed is attached to the residents body, so it meets the first criteria. But what about removal? CMS provides some clarification.
 “Remove easily” means that the manual method or physical or mechanical device, material, or equipment can be removed intentionally by the resident in the same manner as it was applied by the staff (e.g., side rails are put down or not climbed over, buckles are intentionally unbuckled, ties or knots are intentionally untied), considering the resident’s physical condition and ability to accomplish his or her objective (e.g., transfer to a chair, get to the bathroom in time).
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The resident’s physical condition and his/her cognitive status may be contributing factors in determining whether the resident has the ability to remove it.  For example, a bed rail is considered to be a restraint if the resident is not able to put the side rail down in the same manner as the staff.  Similarly, a lap belt is considered to be a restraint if the resident cannot intentionally release the belt buckle. 
upBed can easily be removed by the resident in the same way it's attached by staff. It's basically an article of clothing, so it doesn't qualify as a restraint given this criteria. It could be argued that a resident with cognitive impairment might not be able to remove it, but this comes down to proper use and documentation in treating a medical condition, which is discussed more below.

​But what about the last criteria? Does upBed restrict the residents freedom of movement? This is a little trickier as the guidelines include psychological restraints. Here is some clarification from CMS.
“Freedom of movement” means any change in place or position for the body or any part of the body that the person is physically able to control or access.
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Examples of facility practices that meet the definition of a physical restraint include but are not limited to: Using a position change alarm to monitor resident movement, and the resident is afraid to move to avoid setting off the alarm. “Position change alarms” are alerting devices intended to monitor a resident’s movement. The devices emit an audible signal when the resident moves in certain ways. 
upBed is certainly a position change alarm, but it alerts silently through nurse call, so the resident doesn't hear the alarm. In most cases the resident is not aware of the alarm or what upBed is doing at all. In this way upBed actually promotes movement versus restricts it.

The most important consideration is properly documenting the use of upBed with supporting measurable data. When done properly, upBed is not considered a restraint. Thorough documentation includes a physician’s order with appropriate diagnosis and signed consent from his/her responsible party. Additionally, the care plan should reflect upBed as an intervention for fall risk and reviewed periodically according to regulation and individual facility policy. Below is an example of proper documentation.

Sample Physicians Order
Apply upBed position monitoring device to ankle to be worn while in bed and remove upon rising.
Diagnosis: R29.6 “Frequent Falls”
** as opposed to Z91.81 “History of falling” because the former is a billable code that includes causative medical diagnoses for repeated falls

Care Planning
The best practice is to to use a Fall Risk Assessment tool such as the Morse Fall Risk Assessment with dementia or similar related diagnosis being the secondary diagnosis. upBed should not be considered for “low fall risk” results. Instead, other contributing factors should be reviewed and adjusted accordingly. This tool is completed upon admission, as needed, and at routine intervals determined by regulations and facility policy. 

Universal fall precautions are initiated for everyone. When a high fall risk is observed, individualized interventions are added to those universal precautions. The upBed language in the care plan should state:
  • The upBed position monitoring device is applied to (left or right) ankle at all times while in bed. When the care plan is reviewed or updated, documentation should reflect continued use and efficacy of upBed. Discontinuation (supported by a physician’s order) should occur if there has been no reduction in falls while using the device properly.
  • The MAR/TAR should include:
    • Apply upBed device to (left or right) ankle at bedtime
    • Remove upBed device upon rising
    • Check placement of upBed device every shift
    • Weekly or at other routine intervals, there should be a process for checking device functionality (the hub, anklet, nurse call). This would likely be based on the manufacturer/company recommendations as is done with other medical equipment. Example: Wanderguard transmitters are tested weekly.

Any time routine notes are written such as a monthly summary, the use of upBed and any pertinent details relative to the use should be included. It would also be good practice to care plan around risk for impaired skin integrity secondary to device placement. Minimally, there should be evidence of skin checks documented in the clinical record. Alternating between ankles may be a preventative measure. Despite the soft material, other commodities may place the resident at an increased risk for skin breakdown.

​We hope this helps. Please feel free to contact us with your feedback!
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