Administration for Community Living/Administration on Aging- Office of Long-Term Care Ombudsman Programs

National Ombudsman Reporting System (NORS) OMB Control Number 0985-0005

Table 2: Complaint codes and definitions Expiration Date: 04/30/2021

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 A01The intentional use of physical force that 

results in acute or chronic illness, bodily 

injury, physical pain, functional impairment,

distress, or death.

Includes hitting, slapping, and pinching, kicking, 

etc. and/or controlling behavior through 

corporal punishment.

Abuse: sexual A02Forced and/or unwanted sexual interaction 

(touching and non-touching acts) of any kind. 

Includes, but not limited to unwanted or 

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. 
2

Label Code Definition Examples and Reporting Tips

Abuse: psychological A03The 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 A04The 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.
3

Label Code Definition Examples and Reporting Tips

Gross neglect A05Failure 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.

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. 
4

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 Code Definition Examples and Reporting Tips

Access to information and 

records 

B01 Access to information or access to resident 

records is denied or delayed. 

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 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.

Use when the resident is not provided with 

auxiliary aids and services.

Willful interference B03 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.

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.
5

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.
6

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 Code Definition Examples and Reporting Tips

Choice in health care D01 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.

Use L02 (Services from outside provider) if the 

resident is permitted to choose her personal 

physician but that physician is unavailable. 

Live in less restrictive setting D02 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. 

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.

Dignity and respect D03 Resident is treated with rudeness, 

indifference or insensitivity. 

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. 
7

Label Code Definition Examples and Reporting Tips

Privacy D04 Failure to ensure privacy during provision of 

care or treatment, or in other aspects of life. 

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.
8

Label Code Definition Examples and Reporting Tips

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.

Includes cohabitation, smoking/non-smoking, 

right to refuse care or treatment and other civil 

rights issues or preferences. Use D4 for 

complaints involving privacy.
9

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 

overcharging, raising rates without notice, 

deposits not refunded, and billing for services 

or supplies that were not provided, and 

similar complaints. 

Use for billing for items or services that should 

be covered by Medicaid, Medicare or other 

insurance.

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. 
10

Care (Code F)

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

Label Code Definition Examples and Reporting Tips

Accidents and falls F01 Any unexpected or unintended incident or 

injury of unknown origin, which may result in 

injury or illness to a resident. 

Example: A resident who self-propels catches a 

finger in wheelchair spoke and fractures a 

finger; resident falls 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.
11

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. 

Use for lack of nail care and grooming and 

similar problems

Use A05 (Gross neglect) if there is failure to 

meet essential care.

Access to health related 

services

F06 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. 

Services such as podiatry, dental, vision, 

hearing, mental health, hospice. 

Use D01 (Choice in health care) if denied choice 

of medical provider.

Symptoms unattended F07 Failure to accommodate, identify or provide 

services related to a change in resident's 

condition. Use if symptoms are not addressed 

and care is not provided. 

Use for failure to identify and address symptoms 

such as pain, skin integrity, pressure sores, 

fever, and infection.

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. 
12

Label Code Definition Examples and Reporting Tips

Incontinence care F08 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. 

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.)

Assistive devices or equipment F09 Failure to provide access to assistive devices 

and similar equipment and supports. Failure 

to maintain adaptive equipment. 

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.

Rehabilitation services F10 Failure to provide or arrange for 

rehabilitation therapies or services. The 

resident is not assisted or encouraged to 

improve or maintain his or her function or is 

not assisted or encouraged to ambulate when 

appropriate. 

Services such as physical, occupational and 

speech therapy; range of motion and exercise 

programs and similar.
13

Label Code Definition Examples and Reporting Tips

Physical restraint 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.
14

Activities, Community Integration and Social Services (Code G)

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

Label Code Definition Examples and Reporting Tips

Activities G01 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. 

Use D07 (Visitors) if the complaint is about 

interaction with visitors. 

Transportation G02 Failure to assist resident in obtaining 

transportation to participate in community, 

attend health care appointments, and similar 

complaints. 

Use L02 (Services from outside provider) if 

complaint is about a transportation provider 

other than the facility. 

Conflict resolution G03 Disagreement between residents where the 

assistance of the Ombudsman is requested by 

the residents or facility staff to achieve a 

resolution.

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. 
15

Dietary (Code H)

Use this category for complains regarding food service, assistance.

Label Code Definition Examples and Reporting Tips

Food services H0I Food quantity, quality, variation, choice, 

temperature and timing of meals and snacks

are substandard or do not meet resident 

expectations.

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. 
16

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 the room 

or water temperature is too hot or cold or 

ventilation is inadequate. 

Use for cigarette smoke or other unpleasant 

odors; noise; and similar problems.

Building structure I02 Building interior or exterior is not maintained, 

or there are building hazards such as poor 

lighting, building not secure and similar 

complaints.

Use for complaints about elevator problems or 

malfunctioning automatic doors.

Use for fire safety concerns such as inadequate

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.

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.

Accessibility I04 Complaints regarding building and grounds 

accessibility. 

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.
17

Label Code Definition Examples and Reporting Tips

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.

Pests include: bedbugs; cock roaches; rodents 

etc. 

Use E02 (Personal property) for lost laundry.
18

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 Code Definition Examples and Reporting Tips

Administrative oversight 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.

Fiscal management J02 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. 

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,

over-use of temporary agencies, etc. Use for 

complaints about the skills or training of staff 

and similar complaints

Includes all staff, direct care, nursing 

housekeeping, etc. 

Use J01 (Administrative oversight) if the 

administrator is absent or on site infrequently. 
19

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 

of services or other issues related to a 

managed care plan.

Includes problems with coverage areas, 

enrollment and dis-enrollment, and the 

grievance and appeals process.

Medicare K04 Complaints regarding Medicare eligibility, 

coverage or other issues related to the 

Medicare program.

Includes complaints about observation status.
20

Label Code Definition Examples and Reporting Tips

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.

Includes Long-Term Care insurance, disability 

insurance, Medicare supplemental and similar 

types of private insurance
21

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

Label Code Definition Examples and Reporting Tips

Resident representative or 

family conflict

L01 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.

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). 

Services from outside provider L02 Problems with services provided to a resident 

from an individual or entity not associated 

with or arranged by the facility.

Use for complaints about services that are 

typically arranged by the resident or family 

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.