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The Centers for Medicare and Medicaid have issued statements to all SNF that they will be held liable for violations to resident privacy related to photographs and audio/video recordings by nursing home staff. This includes full time, part-time, and/or contracted employees. Excerpts from the memorandum are below, or click here for the full report.

Develop and Implement Written Policies and Procedures

Each nursing home must develop and implement written policies and procedures that prohibit all forms of abuse, including mental abuse.  Each nursing home must review and/or revise their written abuse prevention policies and procedures to include and ensure that nursing home staff are prohibited from taking or using photographs or recordings in any manner that would demean or humiliate a resident(s).  This would include using any type of equipment (e.g., cameras, smart phones, and other electronic devices) to take, keep, or distribute photographs and recordings on social media.   

Training on Abuse Prevention 

Each nursing home must provide training on abuse prohibition policies for all staff who provide care and services to residents, including prohibiting staff from using any type of equipment (e.g., cameras, smart phones, and other electronic devices) to take, keep, or distribute photographs and recordings of residents that are demeaning or humiliating. 

The provision of in-service education on abuse prohibition alone does not relieve the nursing home of its responsibility to assure the implementation of these policies and procedures.  The nursing home must provide ongoing oversight and supervision of staff in order to assure that these policies are implemented as written.   

Surveyors will be required to request to review nursing home policies and procedures during any survey or as necessary based upon identified concerns and/or complaints beginning 30 days after issuance of the memorandum (August 5th. 2016).