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.

Includes hitting, slapping, and pinching, kicking,

etc. and/or controlling behavior through

corporal punishment.

Abuse: sexual A02 Forced 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 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.
3

Label Code Definition Examples and Reporting Tips

Gross neglect 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.

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.

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.
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. 

Includes problems with a facility planning and 

implementing an all hazards approach to 

disaster preparedness and response. 

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.