NORS Table 2

Administration for Community Living/Administration on Aging- Office of Long-Term Care Ombudsman Programs
National Ombudsman Reporting System (NORS)
Table 2: Complaint codes and definitions

OMB Control Number 0985-0005
Expiration Date: 10/31/2024

Complaint: an expression of dissatisfaction or concern brought to, or initiated by, the Ombudsman program which requires Ombudsman
program investigation and resolution on behalf of one or more residents of a long-term care facility.
Abuse, Gross Neglect, Exploitation (Code A)

Use this section for serious complaints of willful mistreatment of residents by facility staff, resident representative/ family/friend, other
residents or an outside individual. Indicate who appears to be the cause of the abuse, neglect or exploitation: (1) Facility staff, (2) another
resident (3) resident representative, family, friend or (99) other.
Label

Code

Definition

Examples and Reporting Tips

Abuse: physical

A01

The intentional use of physical force that
results in acute or chronic illness, bodily
injury, physical pain, functional impairment,
distress, or death.

Abuse: sexual

A02

Forced and/or unwanted sexual interaction
Includes, but not limited to unwanted or
(touching and non-touching acts) of any kind. inappropriate touching, sexual coercion,
sexually explicit photographing, and sexual
harassment. Sexual harassment includes any
form of unwanted sexual attention (e.g., sexual
advances, suggestions, requests or threats) that
is deemed inappropriate, offensive, intimidating
or humiliating. Harassment includes contact
and non-contact acts.

Includes hitting, slapping, and pinching, kicking,
etc. and/or controlling behavior through
corporal punishment.

Label
Abuse: psychological

Code

Definition

Examples and Reporting Tips

A03

The infliction of anguish, pain, or distress
through verbal or nonverbal acts. This
includes but is not limited to verbal assaults,
insults, threats, intimidation, humiliation, and
harassment.

Includes, but is not limited to: oral, written or
gestured language that willfully includes
disparaging and derogatory terms used against
residents regardless of their ability to
comprehend; humiliation; bullying; harassment;
threats of punishment or deprivation; and
involuntary seclusion, which is the separation of
a resident from other residents or from his/her
room against the resident’s will.
It also includes abuse that is facilitated or
caused by the taking or using photographs or
recordings in any manner that would demean or
humiliate a resident; posting these photos on
social media networks, or sending these photos
through multimedia messages.
Use D03 (Dignity and respect) for less severe
forms of staff rudeness or insensitivity.
Use F02 (Response to requests for assistance) if
staff is unavailable, unresponsive to residents.

Financial exploitation

A04

The illegal or improper use of an individual’s
funds, property, or assets for another
person’s profit or advantage.

Includes, but is not limited to, depriving a
resident of rightful access to, information about,
or use of personal benefits, resources, personal
needs allowance, belongings, or assets.

2

Label
Gross neglect

Code

Definition

A05

Failure to protect a resident from harm or the
failure to meet needs for essential medical
care, nutrition, hydration, hygiene, clothing,
basic activities of daily living or shelter, which
results in a serious risk of compromised
health and/or safety, relative to age, health
status, and cultural norms.

Examples and Reporting Tips
Use the appropriate categories under Resident
Care (F) or, in some cases, Facility Policies,
Practices and Procedures( J) and for similar
complaints but gross neglect is not clearly
indicated.

3

Access to Information (Code B)

Use this category for complaints against the facility regarding access to information made by or on behalf of the resident. Use for willful
interference with ombudsman duties.
Label
Access to information and
records

Code
B01

Definition
Access to information or access to resident
records is denied or delayed.

Examples and Reporting Tips
Examples of records include medical, financial
and similar documents. Access to information
includes public benefits, or any information
regarding medical condition, advance directives
or treatment.
Includes access to the administrative records,
policies, and documents, to which the residents
have, or the general public has access, of longterm care facilities.

Language and communication
barriers

B02

Willful interference

B03

Information (written, verbal or other formats)
is not provided in a language or format that
the resident can understand; facility does not
provide an interpreter. Language barrier on
the part of facility staff making it difficult for
the resident to understand and communicate
with a staff person, and similar complaints.
Actions or inactions taken by an individual or
entity in an attempt to intentionally prevent,
interfere with, or attempt to impede a
resident or complainant from accessing the
Ombudsman program.

Use when the resident is not provided with
auxiliary aids and services.

Includes when an employee or other
representative of a facility interferes with the
Ombudsman program having immediate access
to the facility, access to records, or to meet with
a resident in person, in private, or by phone.
Use B01 (Access to information and records)
when the resident is having difficulty accessing
records and other information.

4

Admission, Transfer, Discharge, Eviction (Code C)

Use this category for complaints against the facility involving issues regarding Admission, Transfer, Discharge and/or Eviction.
Label

Code

Definition

Examples and Reporting Tips

Admission

C01

Resident is admitted to a facility or section of
a facility against his or her wishes. The
admission agreement or contract is missing or
contains illegal provisions.

Use when the facility requires or requests
waivers of rights as a condition of admission.
Use for violation of Medicaid rules or other
improper or illegal provisions such as
discrimination in admission based on pay
source, sexual orientation, gender identity, or
similar issue.

Appeal process

C02

Resident did not receive information on
appeal rights, or assistance from facility staff
to file an appeal. The facility failed to follow
appeal ruling and similar problems.

Use when facility fails to inform resident of
appeal rights under Medicaid, Medicare,
managed care or other.

Discharge or eviction

C03

Resident received a discharge notice and
does not want to leave. Resident was
transferred or discharged without notice or
due process; resident was transferred to the
hospital and not advised of bed hold policy,
or was not readmitted post hospitalization
and similar problems.

Use when facility fails to provide a written
discharge notice; notice is incomplete or
incorrect; if the transfer or discharge is for
inappropriate reasons; or to an inappropriate
environment.

Room issues

C04

Resident requests a room change and the
request is denied or resident objects to
planned room change; there is no notice or
inadequate notice of change.

Use for issues with room assignments, forced
room changes or intra-facility transfers;
complaints involving roommate choice; and
similar problems.

5

Autonomy, Choice, Rights (Code D)

Use this category for complaints involving facility staff failure to honor and promote a resident’s right or preferences.
Label
Choice in health care

Code
D01

Live in less restrictive setting

D02

Dignity and respect

D03

Definition

Examples and Reporting Tips

Resident is denied the right to choose own
physician/pharmacy/hospice or other health
care provider.

Use when the resident’s preferred care or
treatment schedule is not accommodated.

Resident is not offered transition planning
services to return to a less restrictive setting;
request to return to community is denied,
ignored, or inadequately addressed; facility
staff prevents the resident from moving from
the facility; and similar problems.
Resident is treated with rudeness,
indifference or insensitivity.

Use for nursing home complaints about MDS
Section Q (request for information to return to
community) and when facility fails to refer
resident to the Local Contact Agency for
assistance.

Use L02 (Services from outside provider) if the
resident is permitted to choose her personal
physician but that physician is unavailable.

Facility staff fails to knock before entering room,
posts signs relating to individual’s care and
similar problems. Use when interactions are not
age-appropriate or person-centered.
Use codes A02 (Abuse: sexual) or A03 (Abuse
psychological) for inappropriate posts on social
media.

6

Label
Privacy

Code
D04

Definition
Failure to ensure privacy during provision of
care or treatment, or in other aspects of life.

Examples and Reporting Tips
Use when facility staff: discloses confidential
information; shares resident information in a
newsletter or other format without consent;
opens resident mail; fails to close doors/privacy
curtains when giving personal care; monitors
phone calls or e-mails.
Use for lack of privacy when meeting with
visitors and if couples denied privacy and similar
problems.
Use code B03 (Willful interference) if a lack of
privacy is related to visits from the Ombudsman
program.

Response to complaints

D05

Facility staff ignores or trivializes a resident
complaint or there is no facility grievance
process thereby limiting the resident's ability
to resolve a problem directly with the
administration.

Use if the grievance procedure is not followed
or made known to residents.

Retaliation

D06

Acts of retaliation/revenge by facility staff in
response to a complaint to the facility,
Ombudsman program, or state survey
agency.

Use for threat of discharge, lack of care,
requests ignored, call lights unanswered, rough
handling, monitoring resident's phone, mail or
visits without resident's permission.
Use for retaliation in response to actions taken
by a resident, family, or another person acting
on behalf of a resident. May add additional
complaints if resident feels abused, or neglected
due to the retaliation.

7

Label

Code

Definition

Visitors

D07

Restrictions on a resident’s ability to choose
who to associate with and when to visit,
either in the facility or in the community.

Resident or family council

D08

Interference with or prevention of the
formation of a resident or family council.
Staff does not assist in the promotion of
councils or exerts too much control; does not
respond or follow-up on council requests and
similar problems.

Other rights and preferences

D09

The deprivation of any right, not defined in
D1-D8, such as personal liberty or freedom of
choice, right of assembly, speech, religious
freedom, the right to vote.

Examples and Reporting Tips

Includes cohabitation, smoking/non-smoking,
right to refuse care or treatment and other civil
rights issues or preferences. Use D4 for
complaints involving privacy.

8

Financial, Property (Code E)

Use this category for complaints involving facility staff mismanagement of residents’ funds and property or billing problems.
Label

Code

Definition

Examples and Reporting Tips

Billing and charges

E01

Incorrect or improper billing such as
Use for billing for items or services that should
overcharging, raising rates without notice,
be covered by Medicaid, Medicare or other
deposits not refunded, and billing for services insurance.
or supplies that were not provided, and
similar complaints.

Personal property

E02

Loss or mismanagement, by the facility, of
resident property including resident‘s money
or trust fund.

Use for lost personal items such as laundry,
prostheses, dentures, hearing aid, glasses, radio,
watch, and cigarettes.
Use if the facility staff withholds or damages
resident property and similar problems.
Use for failing to reimburse resident for lost or
damaged items.
Use A04 (Financial exploitation) if improper use
of property or money is for the benefit of
others.

9

Care (Code F)

Use this category for any complaint involving facility staff failure to provide care including, poor quality care, planning and delivery.
Label
Accidents and falls

Code
F01

Definition

Examples and Reporting Tips

Any unexpected or unintended incident or
Example: A resident who uses a wheelchair
injury of unknown origin, which may result in independently catches a finger in wheelchair
spoke and fractures a finger; resident falls
injury or illness to a resident.
while getting out of bed; pinches hand in
doorjamb and sustains a skin tear.
Use A05 (Gross neglect) if this is a repeated
problem which facility staff fail to address.

Response to requests for
assistance

F02

Failure to promptly respond to call light or
call bell or requests for assistance goes
unanswered.

Such as, requests for returning to resident's
room, transfers to chair or bed, and similar
problems.

Use D06 (Retaliation) if slow response in
reaction to a resident complaint or actions taken
by the resident, family, or other person involved
in the resident’s care.
Care planning

F03

Facility does not create or follow a personcentered care plan. Care planning does not
include the resident or resident
representative, or staff disregards or is not
informed of the plan. s

Use if the nursing home resident’s Specialized
Services an indicated by a PASRR level II screen
are not included in the care plan.
Use if care plans are not scheduled, not enough
time allowed at the meeting, or a copy of plan is
not provided to the resident, etc.

10

Label

Code

Definition

Examples and Reporting Tips

Medications

F04

Medication given in error, or not given on
time or at all. Medication administration not
documented or incorrectly documented.

Medications not secured, incorrect medications
including expired; not filled in a timely manner;
incorrectly labeled and similar problems.

Personal hygiene

F05

Failure to provide hygiene services such as:
not bathed in a timely manner or at all, or is
allowed to remain in soiled clothing or
incontinent briefs; hands and face not
washed; teeth or dentures not cleaned.
Failure to obtain or maintain healthcare
services based upon a change in resident's
condition, or at the residents’ request, or if
the service is not obtained in a timely manner
and similar complaints.

Use for lack of nail care and grooming and
similar problems

Access to health related
services

Symptoms unattended

F06

F07

Use A05 (Gross neglect) if there is failure to
meet essential care.
Services such as podiatry, dental, vision,
hearing, mental health, hospice.
Use D01 (Choice in health care) if denied choice
of medical provider.

Failure to accommodate, identify or provide Use for failure to identify and address symptoms
such as pain, skin integrity, pressure sores,
services related to a change in resident's
condition. Use if symptoms are not addressed fever, and infection.
and care is not provided.
Use if resident’s health care provider is not
notified of changes in resident condition;
resident representative is not notified of
changes in resident condition.
Use for lack of monitoring and care for
individuals with nasal gastric tubes and similar.
Includes changes in mental health or cognitive
changes.
Use A05 (Gross neglect) if there is failure to
meet essential care that threatens the health,
safety or welfare of the resident.

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Label

Code

Definition

Incontinence care

F08

Assistive devices or equipment

F09

Failure to provide incontinence care or
catheter care in a timely manner as
requested, or as directed by the care plan.
Not providing necessary bowel and bladder
training.
Failure to provide access to assistive devices
and similar equipment and supports. Failure
to maintain adaptive equipment.

Rehabilitation services

F10

Examples and Reporting Tips
Resident is not assisted to the bathroom or is
provided with incontinence briefs or catheters
rather than receiving assistance to go to the
bathroom (for purposes of staff convenience.)
Use if the facility creates barriers in accessing or
keeping a service animal.
Equipment and devices can include but are not
limited to: Hoyer lifts; handrails; grab bars;
raised toilet seat; elevators; ambulation aids;
wheelchairs; hearing or visual aids and
communication devices.

Failure to provide or arrange for
Services such as physical, occupational and
rehabilitation therapies or services. The
speech therapy; range of motion and exercise
resident is not assisted or encouraged to
programs and similar.
improve or maintain his or her function or is
not assisted or encouraged to ambulate when
appropriate.

12

Label
Physical restraint

Code

Definition

Examples and Reporting Tips

F 11

Use of any device, material or equipment
attached to or near the resident’s body, that
cannot be controlled or easily removed by the
resident which deliberately prevent or are
deliberately intended to prevent free body
movement to a position of choice and/or a
normal access to their body

Physical restraints include, but are not limited
to: leg restraints; arm restraints; hand mitts; soft
ties or vests; lap cushions, and lap trays the
resident cannot remove easily. Physical
restraints include any other device that a
resident cannot control or remove without
assistance including reclining chairs and
improper use of bed rails.
Use this code for issues involving the
assessment, use and monitoring of physical
restraints.

Chemical restraint

F 12

Use of any for discipline or convenience that
is not required to treat medical symptoms.

Includes inappropriate use of antipsychotics,
anti-anxiety or hypnotic medication.
Use this code for issues involving the
inappropriate assessment, use or monitoring of
chemical restraints.

Infection control

F 13

Insufficient measures to prevent or
control infection

Includes failure to follow infection control
procedures; staff not wearing, or not
properly wearing, necessary personal
protective equipment (PPE); facility not
providing necessary PPE; spread of
infection; infection unreported or not
treated appropriately; and similar problems.

13

Activities, Community Integration and Social Services (Code G)

Use this category for any complaint involving activities, community integration or social services.
Label
Activities

Code
G01

Transportation

G02

Conflict resolution

G03

Definition

Examples and Reporting Tips

Lack of choice and appropriate activities for
each resident; facility fails to consider
individualized preferences; variety of
activities is limited or not offered; posted
activities not conducted;

Use for any complaint related to activities either
individual or group.

Failure to assist resident in obtaining
transportation to participate in community,
attend health care appointments, and similar
complaints.
Disagreement between residents where the
assistance of the Ombudsman is requested by
the residents or facility staff to achieve a
resolution.

Use L02 (Services from outside provider) if
complaint is about a transportation provider
other than the facility.

Use D07 (Visitors) if the complaint is about
interaction with visitors.

Use for roommate disagreement over the
volume of the TV, visitors in the room, and
conflict between residents about a resident
council.
Use L01 (Resident representative or family
conflict) for a resident conflict or disagreement
with their resident representative, family or
friend.

Social services

G04

Social services are not available or
appropriate. Facility staff fail to provide social
services to help a resident achieve his or her
goals; access supports, etc.

Includes problems with making medical
appointments, arranging for escorts to
appointments, family support, grief counseling
and similar problems.

14

Dietary (Code H)

Use this category for complains regarding food service, assistance.
Label
Food services

Code
H0I

Definition
Food quantity, quality, variation, choice,
temperature and timing of meals and snacks
are substandard or do not meet resident
expectations.

Examples and Reporting Tips
Includes posted menu is not served; alternate
selections not offered; servings too small; no
variety; quality is poor; food has little nutritional
value, presentation, utensils not provided and
similar complaints.
Use I03 (Supplies, storage and furnishings) if
there is a shortage of dining supplies

Dining and hydration

H02

Facility staff fails to assist with dining or
ensuring adequate hydration and similar
complaints.

Includes the facility staff has not provided
adaptive equipment for resident to maintain
independence in eating, meal set-up, i.e.,
opening milk cartons, tray not within reach or
staff not provide direct assistance; including
providing fluid and reminders or assistance to
stay hydrated.
Use A01 (Abuse: physical) or A05 (Gross neglect)
for willful instance of food deprivation.

Therapeutic or special diet

H03

Therapeutic diet is not served as indicated in
the care plan or a special request diet or food
preferences are not accommodated and
similar complaints.

Use when resident has specific dietary
preferences, i.e. vegetarian, or dietary
requirements based on religious practice or
food allergies and similar problems.

15

Environment (Code I)

Use this category for complaints involving the physical environment of the facility, including the resident’s space.
Label

Code

Definition

Examples and Reporting Tips

Environment

I01

The building environment including safety
hazards, room or water temperature is too
hot or cold or ventilation is inadequate.

Building structure

I02

Building interior or exterior is not maintained, Use for complaints about elevator problems or
or there are building hazards such as poor
malfunctioning automatic doors.
lighting, building not secure and similar
Use for fire safety concerns such as inadequate
complaints.
or non-functioning or expired fire extinguishers,
fire alarms, smoke detectors, or other
emergency equipment not available and any
other building maintenance problem.

Supplies, storage and
furnishings

I03

Furnishings in resident rooms or common
areas are lacking or in disrepair; inadequate
or inaccessible locked storage for valuables.
Shortage of supplies such as bed linens,
towels, toilet paper, etc.

Accessibility

I04

Complaints regarding building and grounds
accessibility.

Use for cigarette smoke or other odors;
noise; hazards such as cleaning supplies
improperly stored, and similar problems.

Use for inadequate dining supplies, utensils, etc.
Use if supplies such as linens are in poor
condition.
Use H01 (Food services) if there is not enough
food on hand in the facility.
Inappropriate door handles; electronic door
openers not available; sinks and toilets are
wrong height, lack grab bars, etc. inaccessible
entrances/exits or hallways and similar
complaints.

16

Label

Code

Definition

Housekeeping, laundry and pest
abatement

I05

Housekeeping services are inadequate or
absent. Resident and common rooms not
clean, and linens are not changed. Laundry is
not washed. Residents lack clean clothes.
Problems with pest control and similar
problems.

Examples and Reporting Tips
Pests include: bedbugs; cock roaches; rodents
etc.
Use E02 (Personal property) for lost laundry.

17

Facility Policies, Procedures and Practices (Code J)

Use this category for acts of commission or omission by facility leadership/owners including: administrators, resident managers, etc.
Label
Administrative oversight

Fiscal management

Code

Definition

Examples and Reporting Tips

J01

Mismanagement including but not limited to:
administrator is absent, unresponsive,
inadequately trained or not supervising staff;
incomplete, missing or falsified record
keeping: background screening not
performed; illegal policies/practices and
similar complaints.

Use for failure of facility to report or investigate
suspected resident abuse, neglect or
exploitation to the specified authority.

Facility lacks fiscal resources that result in:
staff shortages, staff alerts of not being paid,
lack of food, or supplies, utilities cut off, etc.

Includes problems related to bankruptcy and
general insufficient funds to operate.

J02

Includes problems with a facility planning and
implementing an all hazards approach to
disaster preparedness and response.

Includes complaints about health care fraud,
waste, and abuse.
Use I03 (Supplies, storage and furnishings) if
there is a shortage of supplies not related to
fiscal management problems.
Use A04 (Financial exploitation) if the facility is
misusing resident funds.

Staffing

J03

Problems with shortage of staff, turn over,
Includes all staff, direct care, nursing
over-use of temporary agencies, etc. Use for housekeeping, etc.
complaints about the skills or training of staff
Use J01 (Administrative oversight) if the
and similar complaints
administrator is absent or on site infrequently.

18

Complaints about an Outside Agency (non-facility) (Code K)

Use this category for complaints involving decisions, policies, actions or inactions by the programs and agencies listed below; including private
and public benefits.
Label

Code

Definition

Examples and Reporting Tips

Regulatory system

K01

Complaints specific to actions or inactions of
the licensing and certification agency or
similar regulatory agency.

Complaints regarding access to survey
information; response to complaints and survey
process; failure to enforce and or sanction
facility; closure process, and similar.

Medicaid

K02

Complaints regarding Medicaid eligibility,
coverage or other issues related to the
Medicaid program.

Use for problems involving implementation of
the Pre-Admission Screening and Resident
Review (PASRR) requirements of the Nursing
Home Reform Act related to individuals with a
mental illness, intellectual, or a developmental
disability seeking admission to a Medicaidcertified nursing home. Use for denials of
Medicaid services.

Managed care

K03

Complaints regarding covered services, denial Includes problems with coverage areas,
of services or other issues related to a
enrollment and dis-enrollment, and the
managed care plan.
grievance and appeals process.

Medicare

K04

Complaints regarding Medicare eligibility,
coverage or other issues related to the
Medicare program.

Includes complaints about observation status.

19

Label

Code

Definition

Veterans Affairs

K05

Complaints about eligibility, coverage or
other issues related to the Department of
Veterans Affairs (DVA.)

Private insurance

K06

Complaints regarding any private insurance
company, covered services, denial of
payment, etc.

Examples and Reporting Tips

Includes Long-Term Care insurance, disability
insurance, Medicare supplemental and similar
types of private insurance

20

System: Others (non-facility) (Code L)

Label
Resident representative or
family conflict

Services from outside provider

Code
L01

L02

Definition
Resident representative, or family member
interferes with the resident’s decision
making, and preferences related to health,
welfare, safety, or rights but does not rise to
the level of abuse, gross neglect or
exploitation.

Examples and Reporting Tips
Includes complaints regarding resident decision
making such as guardianship, conservatorship,
durable power of attorney/power of attorney,
wills and similar complaints.
Use codes A01-A05 for any form of abuse, gross
neglect or financial exploitation and for the
perpetrator, select code 03 (Family, Resident
representative, Friend).

Problems with services provided to a resident Use for complaints about services that are
from an individual or entity not associated
typically arranged by the resident or family
with or arranged by the facility.
independent of facility services and may include,
companion services, hospice, therapies,
transportation and similar problems.
Use F06 (Access to health related services) if the
facility fails to arrange for services as directed by
care plan.

Request to transition to
community setting

L03

Barriers to transition to community,
inadequate assistance with accessing
housing, services and supports not related to
facility action or inaction.

Use when the resident requests assistance to
remove organizational barriers, including lack of
housing, unresponsive local contact agency, and
lack of personal care services that prevent or
delay a move.
Use D02 (Live in less restrictive setting) if the
facility is not providing assistance or discharge
planning.

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