Issue 36 – March 2012
In 2011, guidance notes were inserted into NZS 8134.2:2008 Health and disability services Standards – Health and disability services (restraint minimisation and safe practice) Standards to clarify the intention that residents are not subject to environmental restraint unless this is clearly supported by clinical assessment and when no other solutions are available.
The guidance notes are titled Appendix A: Ministry of Health's clarification of NZS 8134.2:2008 Health and Disability Services (Restraint Minimisation and Safe Practice) Standards environmental restraint.
The Ministry of Health recently issued further guidance as below, to help auditors to interpret Appendix A consistently.
Environmental restraint guidelines
Residents should not be subject to environmental restraint unless it is clearly supported by clinical assessment and when no other solutions are available. To clarify this intention, guidance notes have been added as Appendix A to the Restraint minimisation and safe practice Standard (NZS 8134.2:2008).
The following advice is offered to help auditors interpret these guidelines consistently.
Where a provider has a locked door (not in a secure unit), include the following criteria in the audit.
Under HDSS 2.1 Restraint minimisation, criterion 126.96.36.199 specifically refers to policies and procedures in relation to restraint.
- Is the locked door rationale documented?
- What minimisation strategies are implemented? These may include staffing rationales and use of alternative interventions.
- What are the risks associated with a locked door and with an unlocked door?
- How often is the locked door rationale reviewed?
Under HDSS 1.3.3, where a door is locked for a specific resident, that resident's care plan should detail clinical justification for the restraint. Rationale, interventions, and review may be evidenced in the short-term or long-term care plan. The audit evidence is recorded in 1.3.3 or 188.8.131.52. Consider links to medicine management (1.3.12) for therapeutic medicine management.
Tracer methodology can be applied unless there are other priority areas for the audit.
For a number of residents, using a locked door as an environmental restraint is clinically justified. However, there must be evidence of appropriate assessment and/or referral to external agencies for reassessment, where applicable.
Where there is a locked door for a resident (or a group of residents), interviews with other residents and families should validate that those other residents can freely enter and exit the facility.
Audit evidence must verify the locked door is linked to fire systems (HDSS 184.108.40.206).
Where a provider has a locked door but it is used only in emergencies, the rationale should be noted within policy. In addition, the protocol for such use should be documented.
As with any audit type, the scope of the audit can be widened – refer section 7.4 of the DAA Handbook (August 2011).
Note: If there is a fenced property with a locking gate mechanism and the external door to the facility is unlocked, the guidelines still apply.
Summarised from the Ministry of Health's HealthCERT Bulletin, Issue 5, December 2011.