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-XXXX 

Expiration Date: XX/XX/XXXX

ACL response to 60 day Public Comment 

 No complaint codes were removed. Two additional complaint codes were added: I05-“Housekeeping, laundry and pest abatement;” 

and L03-“Request to transition to community setting.” 

 Complaint code numbering was reformatted to a 2 digit number, i.e. A01 

 Complaint code labels were revised in accordance with comments. Most complaint code definitions and reporting tips were revised in 

response to comments. 

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. 

Label Code Comments ACL Response

Abuse, Gross Neglect, 

Exploitation

A

Throughout Table 2, use language that is clear and does not contain 

negative labels. For example, change labels to read...

We recommend ensuring that all definitions for each type of abuse 

include the federal elder abuse definitions and include a statement 

that allows for States to use their own definitions for abuse, such 

as, “and includes the state definition for this type of abuse.”

See comments below

Code labels changed as requested.

The abuse complaint codes are consistent with 

other federal definitions such as those found

in National Adult Maltreatment Reporting 

System (NAMRS) ; the Center for Disease 

Control Elder Abuse Surveillance: Uniform 

Definitions and Recommended Core Data 

Elements; and the definitions found in the 

revised nursing home regulations 42 CFR

§483.5 Definitions.
2 

Label Code Comments ACL Response

All sections should state if they are directly related to the facility or 

not, i.e. A, K, L are not, B –D, I, J are related to the facility, E- is not 

clear, F-H does not state but should.

A - Complaint codes require the selection of a 

perpetrator, which includes facility staff as one 

option.

B-J complaint codes are for complaints against 

the facility.

K complaint codes are for complaints about an 

Outside Agency (non-facility)

L complaint codes are for “System/Others 

(non-facility)”

Additional coding questions can be addressed 

in training and technical assistance provided 

by the Ombudsman Resource Center. 

Abuse, physical A1 Several commenters agreed with above comments. 

Code A1 and A3 – Abuse, physical and Abuse, Verbal/psychological

Issue: Many residents are experiencing bullying both from staff and 

other residents. 

Recommendation: Add to Examples and Reporting Tips an addition 

of bullying to the descriptions provided.

Agree. Revised “Examples and Reporting 

Tips.”

Abuse, Sexual A2 Issue: includes language in the Examples and Reporting Tips about 

“sexually explicit photographing.”

Recommendation: In the Examples and Reporting Tips, add 

language based on the recent guidance from CMS on posting 

pictures to social media

No change in definition made. Revised 

“Examples and Reporting Tips.”

A2 From what I could tell, the proposed changes do not appear to 

address “resident-to-resident physical or sexual abuse” (complaint 

State Ombudsman programs will be required 

to select a type of perpetrator for each abuse, 
3 

Label Code Comments ACL Response

code A.6) as well as in “resident conflict (including roommates) and 

inappropriate behaviors that impact other resident’s quality of life” 

(complaint code I.66). 

Recent studies have shown that distressing and harmful residentto-resident interactions (DHRRI) in nursing homes are prevalent 

(Lachs et al. 2016) and injurious (Shinoda-Tagawa et al. 2004

neglect and exploitation complaint. 

See Table 1.

A2 We recommend adding “verbal” to the definition and the examples. 

We also recommend changing the examples to more clearly define 

the three types of sexual abuse. Hands on offenses, hands off 

offenses (ex. taking naked photos of an elder and distributing them 

on social media, requiring a resident to watch another masturbate), 

and harmful genital practices (those offenses that can occur during 

peri-care)

Revised “Examples and Reporting Tips.”

A2 Additional instruction and guidance is needed as to how to code 

complaints of sexual activity between individuals with cognitive 

impairment or involving an individual who is unable to consent

This issue lends itself to complaint 

investigation training. 

Concern noted and will be shared with the 

National Ombudsman Resource Center; they 

are developing training on the new NORS 

codes. 

Abuse, 

verbal/psychological

A3 Abuse, verbal or psychological. Move “including punishment and 

seclusion” to Examples and Reporting Tips.

Abuse, verbal/psychological (including punishment, seclusion)

Issue: Code A3 – Examples and Reporting Tips includes oral, written 

or gestured language that willfully includes disparaging and 

derogatory terms used against residents but does not specifically 

Revised “Examples and Reporting Tips.”
4 

Label Code Comments ACL Response

address the misuse of social media.

Recommendation: Add language to Examples and Reporting Tips for 

A3 about postings to social media that includes disparaging and 

derogatory terms used against residents.

A3 Under examples and tips, recommend adding ‘actions’ to broaden 

the scope as psychological abuse may take many forms. Add at end 

“Actions that confuse, disrupt, ignore the resident. 

Revised “Examples and Reporting Tips.”

A3 Abuse, verbal/psychological (including punishment, seclusion) A3

We recommend adding abduction to the Definition and including 

abduction in the examples and reporting tips. 

Helpful to add ‘involuntary seclusion’ is not considered abuse when 

it is medically directed for infection control.

Definition was not changed. 

Revised “Examples and Reporting Tips.”

Financial Exploitation A4 Delete ‘trusting relationship to the resident.” Abuse is abuse 

whether it is from a person in a ‘trusted relationship’ or not and one 

is left wondering how a ‘trust relationship’ is involved.

Agree – the definition was changed to be 

consistent with the National Adult 

Maltreatment Reporting System (NAMRS).

Gross Neglect A5 Delete “in a trust relationship” Agree

Access to Information/

Communication

B

Access to information, 

including records 

B1 Issue: The Definition and Examples and Reporting Tips need clarity 

and alignment with the Older Americans Act.

Recommendation: Use language from §712(b) of the reauthorized 

OAA.

Revised “Examples and Reporting Tips.”

B1 There is a significant difference between access to a resident’s own 

medical/personal records at a facility and records that are not 

No additional definitions were added in this 

category. Past complaint history indicates that 

the numbers are too small. Total access 
5 

Label Code Comments ACL Response

specific to a particular resident, such as the licensing survey.

We recommend creating a second category for this code to clarify 

the difference between complaints about resident access to their 

own records (medical), and access to other records such as survey, 

etc. that are not resident specific.

complaints are less than 3% with no current 

category rising above 1% of all complaints.

Language/

communication barrier 

B2 Under Examples and Reporting Tips, add examples. Revised “Examples and Reporting Tips.”

Willful interference with 

Ombudsman duties

B3 Issue: The definition for willful interference with ombudsman duties 

does not include examples that fully address an ombudsman’s 

immediate, private, and unimpeded access to facilities, residents, 

and records. 

Recommendation: Revise the Examples and Reporting Tips to state, 

“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.” 

Cod Agree. Revised “Examples and Reporting Tips.”

B3 Willful interference is frequently a corporate decision or upper 

management decision as opposed to a decision made by an 

individual who works in a care facility. We recommend adding the 

term “entity” to the definition of who may be responsible for willful 

interference. “Willful interference means actions or inactions taken 

by an individual or entity in an attempt...”

We also recommend including access to facility or resident records 

to the definition and the description to clarify that interference can 

include those items. 

Complaints regarding Interference with Ombudsman duties would 

generally be a complaint made by the Ombudsman as opposed a 

No additional definitions were added to this 

category. The total number retaliation 

complaints are .35% (less than 700 annually) 

and while an important matter it does not 

need to be singled out in a separate 

complaint code.
6 

Label Code Comments ACL Response

complaint made by the resident. 

Recommendation:

Create a separate complaint code section for ‘Interference with 

Ombudsman duties’ with sub-categories encompassing retaliation 

against the resident or the complainant, retaliation against staff 

cooperating with the investigation / resolution; interfering with the 

Ombudsman’s duties by refusing access to the building, refusing 

private space for interviewing or ease-dropping, refusing access to 

records, verbal threats to the ombudsman, other actions impeding 

the investigation and false accusations against the ombudsman etc. 

Issue: The definition for willful interference with ombudsman 

duties does not include examples that fully address an 

ombudsman’s immediate, private, and unimpeded access to 

facilities, residents, and records. 

Recommendation: Revise the examples and reporting tips to 

state, “Includes when an employee or other representative of a 

facility interferes with Inability to access the 

Ombudsman/representative having immediate access to the 

facility, access to electronic and paper records, or to meet with 

a resident in person, in private, or by phone.” 

See above comments.

Add example for threats to residents after meeting with LTC 

ombudsman.

Admission, Transfer, 

Discharge, Eviction

C
7 

Label Code Comments ACL Response

Admission C1 Issue: Examples in Definition do not address admission to facility 

without legal authority.

Recommendation 1: Revise Definition to read: “Complaints related 

to admission to a facility.” 

Recommendation 2: Move examples to Examples and Report Tips 

and change to read: “Examples include: resident is admitted to a

facility or section of a facility against their wishes or without legal 

authority, including admission to a secured or locked unit. Contract 

is missing or contains illegal provisions, such as requiring or 

requesting waivers of rights, or a violation of Medicaid rules other 

improper or illegal provisions including discrimination in admission 

determinations and similar problems.”

Did not accept recommendation to include the 

term “without legal authority.” 

Revised “Examples and Reporting Tips.”

C1 Recommendation 2: Move examples to Examples and Report Tips 

and change to read: “Examples include: resident is admitted to a 

facility or section of a facility against their wishes, without legal 

authority, or to an overly restrictive setting, including admission to 

a secured or locked unit...” 

“Overly restrictive" is too vague a term to 

include. 

Definition and “Examples and Reporting Tips” 

revised.

Discharge appeal process 

- absent or not followed 

C2 Discharge appeal process - absent or not followed 

Issue 1: Definition is incomplete and includes examples. 

Recommendation 1: Revise Definition to read: Complaints related 

to the discharge appeal process or lack of appeal process. 

Recommendation 2: Move examples to Examples and Reporting 

Tips and change to read, Examples include: “the required number of 

days to appeal a discharge was not followed; the facility failed to 

follow appeal ruling; there was no appeal process in place; and 

similar problems.” Use this code when facility fails to inform 

Definition revised.

Revised “Examples and Reporting Tips.”
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Label Code Comments ACL Response

resident of appeal rights. 

Issue 2: Examples and Reporting Tips section is incomplete. 

Recommendation: Under Tips section, include when the facility fails 

to inform residents of appeal rights under Medicaid, Medicare, 

managed care or other.

C2 Issue 1: Appeal process is too similar to C3, Discharge and Eviction. 

Appeal code may be confusing to the ombudsman reporting work 

and only fits if it is against the facility. Other parts of the appeal 

process could be a problem with the system, state agency, or 

managed care organization.

Recommendation 1: Combine the two codes into one. In the 

combined C2 and 3, add discharge planning to the definition.

Recommendation 2: Correct “behold” to “bed hold.”

Definition revised.

“Examples and Reporting Tips” revised.

Error corrected.

Include a separate numeric for transfer to a different facility rather 

than one that is a community or less restrictive setting (some 

residents believe that a facility wants to retain them for payment or 

other reasons and therefore do not advocate for a resident to 

relocate to a different facility);

Did not accept this suggestion; it is too specific 

and would cause code confusion. 

Discharge/Eviction C3 No comments Label changed to “Discharge or Eviction”

Room assignment/room 

change/intra-facility 

transfer

C4 Move “Use for issues with room assignments, forced room changes 

or intra-facility transfers” under Examples and Reporting Tips.

Accepted suggestion.

Autonomy, Choice, Rights D
9 

Label Code Comments ACL Response

Exercise choice: care, 

treatment, schedule, 

health care provider 

D1 Issue: Clarify definition and move examples to the correct section.

Recommendation: Change the definition to read “Resident is denied 

the right to choose or schedule their care, treatment or healthcare 

provider.” Under Examples and Reporting Tips add the examples 

listed in the definition.

Definition modified with part moved to 

“Examples and Reporting Tips.” 

Choice to live in less 

restrictive setting

D2 Issue: Definition references “discharge planning”, which is confusing 

with Code C2 and 3 about discharge.

Recommendation: Delete reference to “discharge planning” in the 

definition. Replace the beginning of the definition with, “Resident is 

not offered choice of where they live, request to return to 

community...”

Definition revised.

“Examples and Reporting Tips” revised.

D2 Issue: Examples and Reporting Tips section needs additional 

examples to clarify.

Recommendation: Clarify Examples and Reporting Tips for those 

not familiar with MDS Section Q. Add examples to clarify when to 

use this code

Definition revised.

“Examples and Reporting Tips” revised.

D2 Change verbiage to “Resident is not offered discharge planning, 

request to return to community is denied; ignored; or inadequately 

addressed; corrected or the facility staff prevents the resident from 

leaving facility and similar problems.

Definition revised.

“Examples and Reporting Tips” revised.

Not being treated with 

dignity, respect 

D3 Move “Use when resident is not treated with dignity or respect.” 

under Examples and Reporting Tips.

Issue: Examples and Reporting Tips section is incomplete.

Recommendation: Clarify under Examples and Reporting Tips 

section that posts on social media are related to abuse code under 

A2 or A3.

Definition modified with part moved to 

“Examples and Reporting Tips.” 

Additional coding tips added with regards to 

social media.
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Label Code Comments ACL Response

Privacy D4 Issue: Examples and Reporting Tips section is incomplete. 

Recommendation: Clarify under Examples and Reporting Tips 

section that if related to Ombudsman visits, the complaint should 

be coded under B3 – Willful interference with Ombudsman duties.

“Examples and Reporting Tips” revised.

D4 Add, “Social media posts that are made without a resident’s 

permission and do not meet criteria for abuse.”

Did not include, this can be addressed in a 

training example. 

We recommend expanding the Examples and Reporting Tips to 

include failure to close doors/privacy curtains when giving personal 

care.

“Examples and Reporting Tips” revised.

Response to complaints, 

grievance-process

D5 The Definition is unclear and removes helpful definitions for 

current NORS complaint code L88 and L89. 

Recommendation: End the Definition after the words, “...grievance 

process.” Add to the definition, “Use if the grievance procedure is 

not followed or made known to residents.”

No change in definition. “Examples and 

Reporting Tips” added to include “Use if the 

grievance procedure is not followed or made 

known to residents.”

Freedom from Retaliation D6 Issue: The title, Definition, and Examples need clarification. 

Recommendation 1: Change the title to “Retaliation.” 

Recommendation 2: In the Definition, strike “and similar problems” 

and add “to the facility, ombudsman, or state survey agency. 

Includes retaliation in response to actions taken by a resident, 

family, or another person acting on behalf of a resident.” 

Recommendation 3: Revise the last sentence in Examples and 

Reporting Tips to more clearly direct when the ombudsman should 

report retaliation as abuse or neglect.

Title changed to “Retaliation.” 

Definition revised as suggested.

“Examples and Reporting Tips” revised.
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Label Code Comments ACL Response

Include removal of cigarettes as an example of retaliation rather 

than in the list of possessions in E2.

Do not include specific example, this can be 

included in a training example.

Visitors D7 Issue: The definition does not address the resident’s right to have 

visitors at the time of their choosing. 

Recommendation: Revise the definition to say, “Restrictions on a 

resident’s ability to choose who to associate with, and when to visit, 

either in the facility or in the community.”

Revised definition based on suggested 

language. 

Resident or Family Council D8 D8: include "staff dominance over rather than support of" resident 

or family council.

Definition modified.

Exercise other rights and 

preferences

D9 No comments Accepted suggested label change to “Other 

rights and preferences.”

Financial, Property E

Billing/charges E1 Issue: The Definition needs clarity and contains examples.

Recommendation: Move examples to Examples and Reporting Tips, 

and add “Billing for items or services which should be covered by 

Medicaid.”

Accepted. 

“Examples and Reporting Tips” revised.

Personal property lost, 

destroyed

E2 Issue: Clarifying language is needed in Definition and in Examples 

and Reporting Tips.

Recommendation: Revise the definition to read, “Resident property 

lost or destroyed including resident money or trust fund 

mismanaged. Move all the examples listed in the definition to the 

Examples and Reporting Tips section and add failing to reimburse 

resident for lost or damaged items.

Accepted. Definition modified with part 

moved to “Examples and Reporting Tips.” 

E2 Move all the examples listed in the definition to the Examples and 

Reporting Tips section and add failing to reimburse resident for lost 

or damaged items. Remove laundry from this section and include in 

Accepted – See I05- Housekeeping, laundry 

and pest abatement
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Label Code Comments ACL Response

new I5 section on “Housekeeping and Pest Abatement”. Add tip 

that laundry should be coded under this new section.

E2 Remove cigarettes from this list of items that are for resident 

wellbeing.

See revised “Examples and Reporting Tips.” 

E2 The proposed E2 has combined the current E37 Personal funds –

mismanaged, access/information denied, deposits and other money 

not returned with the current E38 Personal property lost, stolen, 

used by others, destroyed, withheld from resident; however the 

concepts and issues encompassed in the current E37 and E38 are 

not fully evident in the proposed E2. 

Correct the title of E2 as ‘Personal Property Lost, Destroyed’ does 

not convey funds mismanaged, withheld etc.. For example:

E2 Personal property including resident funds mismanaged, lost, 

stolen, used by others, destroyed, withheld from resident

The definition was revised but we did not add 

“funds mismanaged code” as a separate code 

Funds mismanaged is 1.3% of all complaints

and can be adequately identified within 

personal property.

Care F

Accidents, falls F1 Issue: In the Examples and Reporting Tips, the use of “A selfpropelling resident” should be changed to use more personcentered language. 

Recommendation: Under Examples and Reporting Tips change “A 

self-propelling resident” to A resident using a wheelchair.

No change. “Self-propelling “ is a more active 

description than “A resident using a 

wheelchair.”

The definition does not match the ‘title’ of the code. The definition 

needs to include ‘injury of unknown origin’ and not simply 

unexpected or unintended incidents. 

Recommendation: Include ‘injury of unknown origin’ in the 

Label changed to “Accidents and Falls.” 

Definition modified to include “injury of 

unknown origin.”
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Label Code Comments ACL Response

definition of F1 and not simply ‘unexpected or unintended 

incidents’.

Failure to respond to 

requests for assistance

F2 Issue: Differentiate from D6-retaliation

Recommendation: Add in Examples and Reporting Tips, “If lack of 

response to request for assistance is in response to a resident 

complaint or actions taken by the resident, family, or other person 

involved in the resident’s care, use D6, (Retaliation).”

“Examples and Reporting Tips” revised.

Failure to provide 

adequate care planning

F3 Issue: Does not include person-centered planning.

Recommendation: Add to Definition, “Facility does not create or 

follow a person-centered care plan.” 

Definition revised to be inclusive of “person -

centered care plan.”

“Examples and Reporting Tips” revised.

Medications F4 No comment

Personal hygiene F5Issue: Need examples to be expanded. Think it is clear enough

Recommendation: Add Example to include infection control issues 

when related to poor hygiene. 

Added “Examples and Reporting Tips.” Did not 

get as specific as suggested recommendation.

Access to health-related 

services

F6

Issue: The Examples and Reporting Tips section needs to be 

expanded. I think it’s clear enough

Recommendation: Under Examples and Reporting Tips add 

including mental health services after psychosocial. Also add Use D1 

if denied choice of medical provider.

Definition revised.

“Examples and Reporting Tips” revised. 

Symptoms unattended F7 Issue: Nothing addressing wandering behaviors

Recommendation: Under Examples and Reporting Tips under area 

about lack of monitoring add “failure to redirect residents who

display wandering tendencies.”

Definition revised.

“Examples and Reporting Tips” revised. 
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Label Code Comments ACL Response

Toileting, incontinent 

care, catheter care

F8 Issue: In the description section the use of “toileted” should be 

changed to use more person-centered language. 

Recommendation: Under Definition change “toileted” to assisted in 

going to the bathroom. Assisted to going to the bathroom has a 

different connotation.

Definition revised as suggested.

“Examples and Reporting Tips” revised. 

Assistive devices, 

equipment, other 

supports

F9 No comments Label revised to “Assistive devices or

equipment.”

Rehabilitation Services F10 Issue: Add a reference to A5 to clarify when to use F10 or A5. 

Recommendation: Under Examples and Reporting Tips, add Use A5 

for contractures due to gross neglect. Contracture is a possible 

outcome of neglect or lack of care.

Definition revised.

Revised “Examples and Reporting Tips.” 

The contracture complaint code has received 

less than 100 complaints each year for the 

past 5 years. Prefer to address this detailed 

level of coding in training. 

Issue 1: The title is inconsistent with the definition because it only 

reflects rehabilitation services to maintain function, instead of also 

including services to improve function.

Recommendation: Change the title to “Rehabilitation Service” to 

make it consistent with the definition that includes rehabilitation 

services to improve and maintain a resident’s function.

Label revised to “Rehabilitation Services.”

Definition revised.

“Examples and Reporting Tips” revised. 

Physical restraintassessment, use, 

monitoring

F 11 The definition is unclear. 

Recommendation: Under Examples and Reporting Tips, add or any 

other devices a resident is unable to get out of without assistance 

including reclining chairs and bed rails. Also add Use this code for 

issues involving the assessment, use and monitoring of physical 

restraints. 

Definition revised.

“Examples and Reporting Tips” revised.

Recommendation: Under definition add “Use this code for issues “Examples and Reporting Tips” revised.
15

Label Code Comments ACL Response

involving the inappropriate assessment, use and monitoring of 

physical restraints.” Under Examples and Reporting Tips, after 

“easily” add “or any other devices a resident is unable to get out of 

without assistance including reclining chairs and bed rails”. 

Chemical Restraint F-12 Issue: Clarify under the definition that is code is to be used for 

inappropriate assessment, use, monitoring and reduction of 

chemical restraints.

Recommendation: Under definition add “Use this code for issues 

involving the inappropriate assessment, use, monitoring and 

reduction of chemical restraints.”

Definition revised.

“Examples and Reporting Tips revised.” 

Activities/Community 

Integration and Social 

Services

G

Activities -choice and 

appropriateness

G1 Issue: Include choice and appropriateness in the definition of this 

code.

Recommendation: Under definition, after “Lack of” add “choice 

and”

Definition revised.

“Examples and Reporting Tips revised.” 

Include individual use of e-readers, personal music devices, and 

computers as essential components of activities that residents must 

be able to access if desired. 

These are examples that can be used in 

training.

Transportation G2 Issue: Alternate code option is mislabeled.

Recommendation: Revise Examples and Reporting Tips to read, 

“Use L2 L3 if complaint is about a transportation service.”

Corrected

Tip refers to L3 if complaint is about a service. Presumably L2 was 

intended. However, while there are outside transportation 

providers, there is also Medicaid Brokered transportation provision 

which should be coded as a complaint against Medicaid services. 

Some specificity in usage and differentiations is helpful with using 

This complaint is about the failure of the 

facility to assist the resident in obtaining 

transportation, not about the payment source 

or the transportation service. Agree that if the 

complaint was about a Medicaid service it 
16

Label Code Comments ACL Response

complaint codes to inform the ‘picture’ of long term care in locales, 

and state. Specificity is also helpful to Programs in addressing 

systems issues.

could be coded as K2 Medicaid. The NORS 

codes and reporting tips do not cover every 

potential complaint variable. 

Conflict resolution G3 This complaint and the accompanying description do not seem 

appropriate for Activities, Community Integration and Social 

Services. It would be more appropriate as a new section L3 under 

System/Others (non-facility). This section replaces “resident 

conflict, including roommates” from the current complaint codes. 

Recommendation: Move to System/Others (non-facility). Create a 

new code L3 and add examples to clarify. Include a Definition to 

read, “A complaint involving a disagreement between residents or 

resident and another party where the assistance of the 

Ombudsman is requested by the residents to achieve a resolution.”

Add Examples and Tips such as roommate disagreement over the 

volume of the TV or visitors in the room.

Definition revised.

“Examples and Reporting Tips” revised.

The code remains G03 within the “Activities, 

Community Integration and Social Services” 

category. The facility staff has a responsibility

to assist residents to resolve conflicts.

G3 Add examples such as, “roommate disagreement over the volume 

of the TV, visitors in the room, and conflict between residents about 

a resident council.”

“Examples and Reporting Tips” revised.

If the disagreement is between resident / or their legal decision 

maker where appropriate and the facility staff and the ombudsman 

is requested by either entity to assisted with conflict resolution / 

mediation, where would one code this? The above definition only 

applies G3 to an issue between residents. 

Recommendation: Broaden the definition to include requests for 

conflict resolution for issues between residents, resident and family 

or resident and staff etc.

Conflict between a resident and their family or 

legal decision maker is code L01 “Resident 

representative or family conflict.”
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Label Code Comments ACL Response

Social Services G4 : Need to define what is meant by social services and add examples 

in the appropriate section. 

Recommendation: Under Examples and Reporting Tips add, For 

example, discharge planning, family support, and grief counseling.

“Examples and Reporting Tips” revised.

G4 The term “social services” means different things in various 

settings. Provide a description of social services in the Definition 

section. Add examples in the appropriate section.

Recommendation: Under the Definition add “Social Services means 

services typically provided by a social worker, counselor or 

discharge planner.” 

Under Examples and Reporting Tips add, “Examples include but are 

not limited to: admission process, discharge planning, making 

medical appointments, arranging for escorts to appointments, 

family support, and grief counseling.”

The definition did not change. This definition 

is intended to apply to both nursing facilities 

who have staff such as social workers and to 

residential care communities who may not 

have dedicated social work staff. 

Dietary H

Food Services H1 Issue: Need to add examples related to weight loss

Recommendation: Add an example that addresses weight loss 

related to food issues. 

If a resident is losing weight because the food 

is not palatable it is still a problem with the 

food service. 

Weight loss for other reasons is more closely 

related to care.

H1 Move examples to the appropriate section. 

Recommendation: Move “Examples include: the posted menu....and 

similar complaints” from the Definition section to the Examples and 

Reporting Tips section.

Definition revised.

“Examples and Reporting Tips revised.” 
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Label Code Comments ACL Response

Assistance with Dining 

and Hydration

H2 No comments. Code renamed “Dining and Hydration.”

Therapeutic/ special diet H3 No comments. “Examples and Reporting Tips added.”

Environment I

General comment: Proposed complaint code revisions in section ‘I’ 

have omitted Infection Control. Infection Control (current 81 

complaint code) is a critical issue and needs to be added to the 

proposed codes.

Infection control has not reached 1% of all 

complaints over the past 5 years. 

A new code I05 was added to address 

housekeeping complaints. 

Environmenttemperature ventilation

I1 No comments. “Examples and Reporting Tips added.”

Code renamed “Environment.”

Equipment/Buildings I2 This code combines the current 78 ‘Cleanliness, pests, general 

housekeeping’ with 79 ‘Equipment/Buildings – disrepair, hazard, 

poor lighting, fire safety, not secure’. These are two different 

categories of issues that are difficult to combine. A building in 

disrepair with an elevator malfunctioning is very different from 

housekeeping and/or pests. A state or local program needs some 

specificity in complaint codes in order to differentiate issues to 

apply data to systems change efforts. Some code combinations 

proposed would end up requiring state and local ombudsmen to 

have to read through numerous cases documentation to ascertain 

the scope of a ‘pest’ problem or the scope of physical plant 

disrepair in a particular chain provider that may for example have 

declared bankruptcy.

Recommendation:

Re-examine the proposed complaint codes that have combined 

current complaints codes with attention to the top complaint codes 

Agree. A new code I05, “Housekeeping, 

laundry and pest abatement,” was added to 

address housekeeping complaints.
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Label Code Comments ACL Response

utilized and need for specificity / meaningful data to inform systems 

advocacy efforts.

Inadequate Supplies and 

furnishings

I3 The definition seems unrelated to the code title. The current 

definition would seem more appropriate under the previous code, I 

– 2, Buildings/Equipment, which deals with maintenance and 

environment. The definition does not mention supplies. 

Recommendation: Change label to Supplies, Storage and 

Furnishings. Revise the definition to include lack of supplies such as 

bed linen, towels, toilet paper; lack of furnishings in resident rooms 

or common areas; and inadequate dining supplies.

Laundry issues (lost or damaged items, frequency, and process) 

remain a common complaint for many programs. There does do not 

appear to be an appropriate code (or related definition) to report 

these types of complaints. 

Recommendation: Create a label code I – 5, Housekeeping and 

Pests, and create a definition to include laundry issues, pests, and 

cleanliness.

Agree.

Code label changed to “Supplies, Storage and 

Furnishings.”

“Examples and Reporting Tips” added.

Laundry complaints are now in I05.

I3 I3 title indicates the complaint would be about supplies and/or 

furnishings; however, the definition only addresses furnishings. 

Current code has 85 Supplies and Linens – not available, in poor 

condition, shortage of supplies (soap, gloves, toilet paper,

incontinence products, nursing supplies which is a significant 

complaint category. 

Recommendation: Include supplies and linens issues in the 

definition of the proposed code or have separate codes for supplies 

and furnishings/ storage.

Definition now addressees shortage of 

supplies. 

“Examples and Reporting Tips” added.
20

Label Code Comments ACL Response

Accessibility I4 No comment

Facility Policies, 

Procedures and Practices

J

Administrative 

Oversight/leadership 

J1 Current codes have a category for administrator being unresponsive 

which is a frequent issue. Tip section should include failure to 

report incidents to the regulatory entity. 

Recommend: Revise definition to include ‘unresponsive’:

Agree. Definition and “Examples and 

Reporting Tips” amended. 

Fiscal Management J2 No comments “Examples and Reporting Tips” revised.

Staffing – inadequate J3 No comments Code name revised to J03: “Staffing.”

“Examples and Reporting Tips” added.

Complaints about an 

Outside Agency (nonfacility)

K

Certification/Licensing 

agency and regulatory 

system

K1 One commenter provided extensive comments regarding the 

reduction of K topic codes.

•This proposed code section appears to replace the current N, O & 

P sections without adequately covering the complaint categories 

currently covered. Essentially, the proposed code goes into 

specificity with various types of insurances but omits programs and 

agencies (though the definition indicates it is for “...complaints 

involving decisions, policies, actions or inactions by the programs 

and agencies”.

•This proposed arrangement loses the specificity of common 

Medicaid complaints of access to information, denial of eligibility, 

non-covered services, Personal Needs Allowance and the quality or 

These codes are not frequently used, for 

example, all complaints related to “State 

Medicaid agency “is less than 1%. If a state 

wishes to have a more granular code related 

to Medicaid they can add these codes in their 

software system and crosswalk it to the NORS

Medicaid code. 

ACL and their contractor have developed 

crosswalks to assist states in determining how 

old codes are mapped to new codes. 

We believe that reducing and combining 

complaint codes and removing codes that are 
21

Label Code Comments ACL Response

quantity of services or difficulty in obtaining services. Coding with 

the proposed code of K2 Medicaid will only provide reporting 

information that there were X number of complaints regarding 

Medicaid with no indication of what the issue may be such of denial 

of eligibility issues versus PNA. To have data to address any 

systems issue regarding Medicaid, will require the Ombudsman to 

read through each case with a K2 complaint to determine what the 

issue with Medicaid may be. 

•Current complaint code categories that appear to be omitted from 

the proposed complaint codes include: bed shortage – placement; 

facilities operating without an license; legal issues of guardianship, 

conservatorship, powers of attorney; problems with resident’s 

physician/assistant; Adult Protective Services; SSA, SSI or other 

benefits (an example of ‘other benefits’ would be a state specific 

program.).

•There appears to be an emphasis on insurance types in this section 

at the loss of ‘programs’ and ‘agencies’ complaint codes.

Recommendation:

Reassess the purpose and use of ombudsman program data at local, 

state and national levels and the degree of specificity of complaint 

codes needed to address issues. While there is value in combining 

some complaint code categories, there is loss and increased burden 

of ‘research’ in omitting some current complaint categories. 

rarely used will reduce states’ reporting 

burden.

Medicaid K2 No comments. “Examples and Reporting Tips” added.

Managed care K3 The definition is vague and refers to eligibility that is not a function 

of managed care. Problems with eligibility are likely to relate to 

Medicaid or Medicare. 

Agree. Definition and “Examples and Reporting 

Tips” amended.
22

Label Code Comments ACL Response

Recommendation: Revise the definition to read, Problems with 

managed care services, coverage areas, enrollment and disenrollment, and the grievance and appeals process.

Medicare K4 No comments. “Examples and Reporting Tips” added.

Veteran’s Administration K5 No comments.

Private Insurance K6 No comments.

Request to transition to 

community setting

K7 It is unclear whether this category should be used when the 

problem is not with the facility. 

Recommendation: Amend definition to add at the end, “... , not 

related to facility action or inaction.” 

Code does not seem to be appropriate under the “Complaints 

about an Outside Agency (non-facility)” category. 

Recommendation: Consider moving to general category L, 

“Systems/Others (non-facility)”. 

Agree K7 moved to L03 “Request to transition 

to community setting” under “System: Other 

(non-facility) category.

Definition and “Examples and Reporting Tips” 

amended.

System/Others (nonfacility)L

Resident

Representative/Family 

conflict; interference

L1 No comments. Code name revised: “Resident Representative 

or Family Conflict”

Services from outside 

provider

L2 The title may be misleading. 

Recommendation: Rename category to Non-facility persons, 

representatives or providers.

Category K is for complaints involving 

decisions, policies, actions or inactions by the 

programs and agencies listed in K01-K06, i.e. 

Medicaid and Medicare and other private and 
23

Label Code Comments ACL Response

Issue 2: Code does not seem to be appropriate under the “Systems” 

category.

Recommendation: Consider moving to general category K, 

“Complaints about an Outside Agency (non-facility).

public benefits.

L-System: Others (non-facility) is intended to 

capture those resident complaints that are not 

about the facility or a public or private benefits 

agency. 

The definition and “Examples and Reporting 

Tips” were amended.