Comment from Alexandria Lewis

A bed rail in of itself is not dangerous. For older adults who may have had a stroke, for example, and need to use a quarter or assist type bedrail to help get out of bed or to move around in bed, these devices are beneficial. Without these types of bedrails, it would limit mobility for residents who rely on them for independence. Side rails are also used by individuals who may be obese and need help pulling him/herself into an upright position; or to help staff assist him/her out of bed. Devices can be therapeutic and beneficial when used appropriately. CMS regulations under F323- Accidents/Supervision, has a section on use of devices and assessing for safe use of devices. The regulation provides information that residents most at risk for entrapment are those who are frail elderly, and those with cognitive impairment. It also provides a guideline/requirement that hazards and risks should be identified, evaluated/analyzed, interventions implemented and monitoring for effectiveness. The cases where residents become entrapped are often due to lack of assessment and/or supervision by the nursing home staff. The types of side rails in use when these unfortunate incidents happen are probably a full or half side rail, as a quarter/assist rail does not prevent one from exiting a bed. Since everyone in a nursing home isn't cognitively impaired or frail, an across the board ban would negatively impact those who do use side rails to increase their independence (i.e. bed mobility, getting in and out of bed independently from wheelchair to bed, etc). As a former nursing home surveyor, I agree that when used inappropriately, these devices do pose a safety risk. However, CMS regulations already address this. Most states have regulations as well about safety and protective oversight. This is another reason why I do not believe a ban is warranted.