Nursing Home Litigation –

Defense Perspective

 

 

 

 

 

PETER A. MONAHAN

Alholm, Monahan, Keefe & Klauke, L.L.C.

DAWN L. HAGHIGHI

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Previously published as Chapter 7 in the IICLE volume

entitled Issues in Long Term Care.

 


I.          OVERVIEW

 

            A.        Long-Term Care Statutes and Regulations

                        1.         Illinois Nursing Home Care Act

                        2.         Federal Nursing Home Reform Provisions of OBRA '87

            B.         Definition of "Long-Term Care Facility"

            C.        Long-Term Care Management

                        1.         Nursing Home Administrator

                        2.         Director of Nursing

                        3.         Director of Food Services

                        4.         Medical Director

                        5.         Physicians

                        6.         Nursing Staff

                        7.         Social Service

 

II.        PARTIES TO LAWSUIT

 

            A.        Plaintiff

            B.         Defendant

 

III.       CAUSES OF ACTION

 

            A.        Theories of Liability

                        l.          NHCA

                        2.         OBRA '87 Provisions

                        3.         Common Law Negligence and the Standard of Care

                        4.         Breach of Contract

                        5.         Consumer Fraud

                        6.         Survival Statute and Wrongful Death Act

                        7.         Negligent Hiring, Supervision, and Retention

                        8.         Healing Art Malpractice

                        9.         Liability

                                    a.         Strict Liability

                                    b.         Actual Agency

                                    c.         Apparent Agency

                        10.       Other Forms of Liability

                        11.       Other Remedies

            B.         Typical Cases and Defenses

                        1.         Fall Cases

                                    a.         Allegations

                                                (1)        Failure to assist and attend

                                                (2)        Failure to properly use a restraint

                                                (3)        Failure to properly use side rails

                                    b.         Defenses

 

                        2.         Injuries Due to Use of Restraints

                                    a.         Allegations

                                    b.         Defenses

                        3.         Wandering Resident Cases

                                    a.         Allegations

                                    b.         Defenses

                        4.         Suicide and Attempted Suicide Cases

                                    a.         Allegations

                                    b.         Defenses

                        5.         Decubitus Ulcer Cases

                                    a.         Allegations

                                    b.         Defenses

 

IV.       GENERAL DEFENSES

 

            A.        Statute of Limitations

            B.         Compliance

 

V.        INVESTIGATION AND DISCOVERY

 

            A.        Securing the Documents and Evidence

                        l.          Medical Records

                        2.         Other Facility Documents

                                    a.         The Business File

                                    b.         The Policies and Procedures Manual and Index

                                    c.         Incident Reports Regarding the Resident

                                    d.         Statements

                                    e.         Other Documents That Relate to the Resident

                                    f.          Staffing Records and Staffing Assignment Calculation Sheets

                                    g.         Surveys and Plans of Correction

                                    h.         Personnel Files of Key Caregivers

                                    i.          Consultants' Reports

                                    j.          The Floor Plan

                                    k.         Marketing Material

                                    1.         Visitor Sign-In Sheets

                                    m         Residents' Advisory Council Meeting Minutes

                                    n.         Photographs

                                    o.         Surveillance Tapes

                                    p.         Menus for the Time Period in Question

                        3.         Documents Not in the Control of the Facility

                        4.         Former Employees' Testimony

                                    a.         Identifying Key Witnesses

                                    b.         Interviewing Former Employees

 

            B.         Discovery Tools

                        1.         Document Requests

                        2.         Interrogatories

                        3.         Requests To Admit

                        4.         Notice for Deposition

            C.        Scope of Defendant's Discovery

            D.        Other Discovery-Related Issues

                        1.         Informal Discovery

                        2.         Statements

            E.         Checklist of Information To Be Obtained in Written and Oral Discovery

 

VI.       EXPERT TESTIMONY

 

            A.        Explaining the Difference Between Hospital Care and Long-Term Care

            B.         Explaining the Difference Between Physician Care and Nursing Care

            C.        Explaining Long-Term Care Facility Charting Practices

            D.        Explaining the Life Care Plan

 

VII.     CASE EVALUATION AND SETTLEMENT ISSUES

 

            A.        Evaluation in General

            B.         Jury Sympathy

            C.        Settlement and Release

            D.        Liens

                        1.         IDPA Liens

                        2.         Medicare Super Liens

            E.         Attorneys' Fees and Costs

 


I.          OVERVIEW

 

A.        Long-Term Care Statutes and Regulations

 

Long-term care facilities are governed by both federal and state regulations. In fact, long-term care facilities are subject to more regulations than any other health care institution. The regulations are comprehensive and complex and regulate all forms of care and services provided to a resident. In order to effectively defend a long-term care facility, the defense counsel must be well versed in the applicable regulatory provisions that apply to a long-term care facility. At a minimum, defense counsel should have a strong working knowledge of the Illinois Nursing Home Care Act, 210 ILCS 45/1-101, et seq.; the Illinois Department of Public Health regulations, 77 Ill.Admin. Code, Part 300; and the federal nursing home reform provisions, 42 C.F.R. Part 483.

Other potentially relevant state statutes include the Abused and Neglected Long Term Care Facility Residents Reporting Act, 210 ILCS 30/1, et seq.; Elder Abuse and Neglect Act, 320 ILCS 20/1, et seq.; Long Term Care Peer Review Protection Act, 745 ILCS 55/1, et seq.; medical studies statute, 735 ILCS 5/8-201; Nursing and Advanced Practice Nursing Act, 225 ILCS 65/5­1, et seq.; and Nursing Home Administrators Licensing and Disciplinary Act, 225 ILCS 70/1, et seq. Other relevant federal statutes and regulations include the Americans with Disabilities Act, 42 U.S.C. §12101, et seq.; Civil Rights Act, 42 U.S.C. §1983; Occupational Safety and Health Act of 1970, 29 U.S.C. §651, et seq.; so-called "Patient Self-Determination Act of 1990," 42 U.S.C. §§ 1395cc and 1396a, passed as part of the Omnibus Budget Reconciliation Act of 1990, Pub.L. No. 101-508, §4206, 104 Stat. 1388; Safe Medical Devices Act of 1990, Pub.L. No. 101­629, 104 Stat. 4511; and Title VII, 21 U.S.C. §1701, et seq. Also relevant may be the National Fire Protection Association Life Safety Code (see 77 Ill.Admin. Code §200.906).

1.         Illinois Nursing Home Care Act

In 1979, the Illinois legislature enacted the Illinois Nursing Home Reform Act of 1979, Ill.Rev.Stat. (1988), c. 111˝, 4151-101, et seq., which was amended in 1988 to become the Nursing Home Care Act (NHCA), 210 ILCS 45/1-101, et seq. The legislation, sponsored by Senators Richard M. Daley (D, Chicago) and Lynn Martin (R, Rockford), went into effect March 1, 1980. The NHCA repealed the old Homes for the Ill and Physically Infirm Persons Act, which had been in existence since 1945.

The NHCA provides a legislative scheme that governs the operations of long-term care facilities in Illinois. The NHCA expanded the prior legislation in four major areas: (a) it created a residents' bill of rights; (b) it expanded the enforcement powers of the regulatory agencies enforcing the provisions of the Act, specifically the Illinois Department of Public Health (IDPH); (c) it set forth minimum qualifications for skill levels and training for the nursing assistants and technicians; and (d) it provided policing powers for community groups, relatives, or friends to become involved in monitoring the quality of care provided. The NHCA also extended the enforcement power of the Act to residents by creating a private right of action. The state agency in charge of the enforcement of the NHCA is the IDPH.

2.         Federal Nursing Home Reform Provisions of OBRA '87

Federal nursing home reform amendments, sometimes referred to as the "Nursing Home Reform Act," were enacted by Congress as part of the Omnibus Budget Reconciliation Act of 1987 (OBRA '87), Pub.L. No. 100-203, 101 Stat. 1330. 42 U.S.C. §§1395i-3(a) through 1395i­3(h) (Medicare), 1396r(a) - 1396r(h) (Medicaid). Unlike the NHCA, the OBRA '87 amendments do not provide a resident with a private right of action. See also Section III.A.2. below.

OBRA '87 and the regulations promulgated thereunder redefined the existing nursing home law by setting forth the following:

a.         the requirements for participating in the Medicare and Medicaid program;

b.         federal and state compliance procedures; and

c.         enforcement mechanisms.

The federal agency in charge of the enforcement of the OBRA '87 regulations is the Centers for Medicare and Medicaid Services (CMS), formerly known as the Health Care Financing Administration (HCFA) of the U.S. Department of Health and Human Services (HHS). The OBRA '87 regulations were implemented on September 26, 1991.

The OBRA '87 regulations, like the NHCA, are numerous and include regulations on all aspects of nursing home care and services provided. They require the nursing home to provide at a minimum for "the highest practicable physical, mental, and psychosocial well-being" of the resident. See 42 C.F.R. §483.25. The OBRA '87 standards can best be summarized by referring to 42 C.F.R. §§483.25(a) - 483.25(m), which address 13 specific aspects of care.

B.        Definition of "Long-Term Care Facility"

A "long-term care facility" is defined as

a private home, institution, building, residence, or any other place, whether operated for profit or not, or a county home for the infirm and chronically ill operated pursuant to Division 5-21 or 5-22 of the Counties Code, or any similar institution operated by a political subdivision of the State of Illinois, which provides, through its ownership or management, personal care, sheltered care or nursing for 3 or more persons, not related to the applicant or owner by blood or marriage. 210 ILCS 45/1-113.

210 ILCS 45/1-124 defines "sheltered care" as "maintenance and personal care." 210 ILCS 45/1-116 defines "maintenance" as "food, shelter and laundry services," and 210 ILCS 45/1-120 defines "personal care" as

assistance with meals, dressing, movement, bathing or other personal needs or maintenance, or general supervision and oversight of the physical and mental well­ being of an individual, who is incapable of maintaining a private, independent residence or who is incapable of managing his person whether or not a guardian has been appointed for such individual.

To fall within the definition of "sheltered care," the facility must provide both maintenance and personal care. The courts have held that a retirement home that provides only food, shelter, and laundry services is not a "facility" as defined by the NHCA. People ex rel. Lumpkin v. Frantz, 306 Ill.App.3d 267, 714 N.E.2d 1068, 239 Ill.Dec. 771 (3d Dist. 1999). The Lumpkin court held that only when food, shelter, and laundry services are combined with "personal care" does a facility become a "sheltered care" facility, thereby coming under the NHCA. Id.

The courts have found that residential institutions with independent living units for individuals who are capable of independent living do not fall under the provisions and protections of the NHCA even when these institutions provide assistance to residents with meals, dressing, movement, bathing, and other personal needs and services. See Grampp v. Friendship Manor of Illinois Branch of Kings Daughters & Sons, Inc., 679 F.Supp. 828 (C.D.Ill. 1988). In Grampp, the resident was in an independent living unit. She received some assistance with meals and housecleaning but was capable of taking care of herself. Therefore, because of her self-sufficiency, the court found that she was not protected by the NHCA because she did not receive "personal care, sheltered care or nursing" as defined by the Act. Id.

The NHCA does not apply to or govern institutions that have their own licensing statutes. The NHCA specifically excludes the following from the definition of "facility":

(1)        A home, institution, or other place operated by the federal government or agency thereof, or by the State of Illinois, other than homes, institutions, or other places operated by or under the authority of the Illinois Department of Veterans' Affairs;

(2)        A hospital, sanitarium, or other institution whose principal activity or business is the diagnosis, care, and treatment of human illness through the maintenance and operation as organized facilities therefor, which is required to be licensed under the Hospital Licensing Act;

(3)        Any "facility for child care" as defined in the Child Care Act of 1969;

(4)        Any "Community Living Facility" as defined in the Community Living Facilities Licensing Act;

(5)        Any "community residential alternative" as defined in the Community Residential Alternatives Licensing Act;

(6)        Any nursing home or sanatorium operated solely by and for persons who rely exclusively upon treatment by spiritual means through prayer, in accordance with the creed or tenets of any well-recognized church or religious denomination. However, such nursing home or sanatorium shall comply with all local laws and rules relating to sanitation and safety;

 (7)       Any facility licensed by the Department of Human Services as a community-integrated living arrangement as defined in the Community-Integrated Living Arrangements Licensure and Certification Act;

(8)        Any "Supportive Residence" licensed under the Supportive Residences Licensing Act;

(9)        Any "supportive living facility" in good standing with the demonstration project established under Section 5-5.01a of the Illinois Public Aid Code;

(10)      Any assisted living or shared housing establishment licensed under the Assisted and Shared Housing Act; or

(11)      An Alzheimer's disease management center alternative health care model licensed under the Alternative Health Care Delivery Act. 210 ILCS 45/1-113.

C.        Long-Term Care Management

1.         Nursing Home Administrator

The NHCA defines the "administrator" as the person who is charged with the general administration and supervision of the facility. 210 ILCS 45/1-105. All long-term care facilities are required to have a licensed nursing home administrator. 77 Ill.Admin. Code §300.510. Pursuant to the Nursing Home Administrator's Licensing Disciplinary Act, 225 ILCS 70/1, et seq., the administrator is the person who is directly responsible for planning, organizing, directing, and supervising the operations of the nursing home.

2.         Director of Nursing

Each skilled nursing facility is required to have a director of nursing services (DON) who is a registered nurse. 77 Ill.Admin. Code §300.1220. Each intermediate care facility is required to have a director of nursing who is either a registered nurse or a licensed practical nurse. Id. The DON is charged with overseeing the nursing services of the facility, including (a) assigning and directing the activities of the nursing service personnel; (b) overseeing the comprehensive assessment of the residents' needs; (c) planning an up-to-date resident health care plan for each resident; (d) recommending to the administrator the number and levels of nursing personnel to be employed; (e) participating in planning for budgeting in nursing services; (f) developing and maintaining nursing services' objective standards of nursing practice, written policies and procedures, and written job descriptions for each level of nursing personnel; (g) coordinating health services and nursing services with other resident care services; (h) planning in-service education and orientation training; (i) participating in the development and implementation of resident care policies; (j) bringing resident care problems requiring changes in policy to the attention of the facility policy development group; and (k) participating in the screening of perspective residents and their placement in terms of services at the facility. Id.

3.         Director of Food Services

Each facility is required to have a director of food services who is either a dietitian or a dietetic service supervisor who is responsible for the food services. If the director of food services is not a dietitian, the person shall have frequent and regularly scheduled consultations from a dietitian consultant. 77 Ill.Admin. Code §300.2010.

4.         Medical Director

Under federal guidelines, a facility must appoint a medical director. 42 C.F.R. §483.75. The medical director assists in the development of policies and procedures at the facility, participates in the quality assurance committee, and, if available, assists in medical emergencies. The medical director serves as an advisor to the administrator and/or DON. The role of the medical director is administrative. Excluding an emergency situation, the medical director does not provide medical care to the residents in the capacity of medical director.

5.         Physicians

A facility is not licensed to provide physician services. However, the facility must ensure that each resident is under the care of an attending physician and that formal arrangements to provide for medical and behavioral emergencies at all times are in place. 77 Ill.Admin. Code §390.1030.

6.         Nursing Staff

The nursing staff consists of registered nurses, licensed practical nurses, and certified nursing assistants. Each facility establishes its own administrative framework; however, each facility usually designates a nursing supervisor or charge nurse for each shift depending on the size of the facility. See 77 Ill.Admin. Code §300.1210, et seq., for the state regulations regarding nursing service.

7.         Social Service

All facilities licensed for more than 120 beds must employ a full-time qualified social worker. 42 C.F.R. §483.15(g)(2).

II.        PARTIES TO LAWSUIT

A.        Plaintiff

If the resident is alive and does not have a power of attorney or an appointed legal representative, the resident is usually the plaintiff. If the resident has a legally appointed representative, the suit will be brought in the name of the representative. If the resident is deceased, then the matter is brought on behalf of his or her estate.

B.        Defendant

Nursing homes are sued in the name of the licensee and/or owner of the facility: The holder of the license is referred to as the "licensee," which, under 210 ILCS 45/1-115, is defined as "the individual or entity licensed by the [IDPH] to operate the facility."

210 ILCS 45/1-119 defines the "owner" as

the individual, partnership, corporation, association or other person who owns a facility. In the event a facility is operated by a person who leases the physical plant, which is owned by another person, "owner" means the person who operates the facility, except that if the person who owns the physical plant is an affiliate of the person who operates the facility and has significant control over the day-to-day operations of the facility, the person who owns the physical plant shall incur jointly and severally with the owner all liabilities imposed on an owner under this Act.

The NHCA recognizes that there can be more than one owner of a facility. Often the facility is operated by one entity that leases the physical plant from another entity that owns the physical property of the facility. If there is no connection between these entities, then the operator is considered the owner. However, if the person or entity who owns the physical plant has some type of affiliation with the operator, then both entities are jointly and severally liable. 210 ILCS 45/1-119.

Liability for violations of the NHCA can be imposed only on the owner or licensee of the facility, not on an individual employee. 210 ILCS 45/3-601. See also Wills v DeKalb Area Retirement Center, 175 Ill.App.3d 833, 530 N.E.2d 1066, 125 Ill.Dec. 657 (2d Dist. 1988). The NHCA specifically provides that "the owner and the licensee are liable to a resident for any intentional or negligent act or omission of their agents or employees which injures the resident." 210 ILCS 45/3-601. The courts have interpreted this provision as protecting individual nursing home employees from liability for civil damages for violations of the NHCA. In an effort to protect the facility being named as a defendant in a lawsuit, most long-term care facilities have created very complex corporate structures regarding the ownership and operation of the facility. It is not unusual for nursing homes to be a part of large conglomerates. It is always important for defense counsel to determine if the facility is owned by a parent corporation. An extensive review of public records is recommended in order for the parties to determine the entities involved and whether the entities sued have any liability exposure. Before filing an appearance or answer, defense counsel should verify that the proper entity was sued. It is recommended that defense counsel work closely with the facility's corporate counsel or risk manager in this regard.

 

 

III.       CAUSES OF ACTION

A.        Theories of Liability

1.         NHCA

The private right of action is one of the most significant provisions of the NHCA. It gives Illinois nursing homes residents whose rights pursuant to the NHCA have been violated a private statutory cause of action for "actual damages and costs and attorney's fees." 210 ILCS 45/3-602. Harris v. Manor Healthcare Corp., 111 Ill.2d 350, 489 N.E.2d 1374, 95 Ill.Dec. 510 (1986). The NHCA also gives the resident the right to seek other redress from the court such as injunctive and declaratory relief (210 ILCS 45/3-603) and the right to bring a class action (210 ILCS 45/3-604). Any waiver of the resident's right to commence an action is null and void (210 ILCS 45/3-606), as is any waiver of the resident's right to a trial by jury (210 ILCS 45/3-607). 210 ILCS 45/3-608 prohibits retaliation against a resident who brings or testifies in an action.

Residents also have a private right of action for violations of their rights set forth in the "resident's bill of rights" (210 ILCS 45/2-101, et seq.). 210 ILCS 45/3-602. Many of the provisions in the Illinois NHCA resident's rights provisions, which apply only to facilities funded through the Medicaid and Medicare programs, mirror the federal Bill of Rights. The resident's bill of rights does not set forth quality-of-care provisions; rather, it focuses on residents' rights of privacy and confidentiality. Many of the rights are basic rights afforded to all citizens. The most litigated provisions of the resident's bill of rights are the right to be free from abuse and neglect (210 ILCS 45/2-107) and the right to be free from restraints (210 ILCS 45/2-106).

The NHCA guarantees that all residents have the following rights:

a.         No resident may be deprived of any rights, benefits, or privileges guaranteed by law or the Illinois or U.S. Constitution solely on account of his or her status as a resident of a facility. 210 ILCS 45/2-101.

b.         All new residents and their spouses must be informed upon admittance of their spousal impoverishment rights as defined in Illinois Public Aid Code (305 ILCS 5/5-4) and in 42 U.S.C. § 1396r-5. 210 ILCS 45/2-101.1.

c.         All residents have the right to manage their own financial affairs. 210 ILCS 45/2-102.

d.         All residents have the right to use and wear their own personal property and to have adequate storage space for such property. If any items of personal property are missing, the facility must initiate an investigation. 210 ILCS 45/2-103.

e.         All residents have the rights to retain the services of their own personal physicians at their own expense; to obtain complete and current information regarding medical diagnosis, treatment, and prognosis in terms they can understand; to participate in the planning of their total care and medical treatment; and not to be subjected to experimental medical treatment and research. 45 ILCS 45/2-104(a).

f.          Residents have the right to have all medical treatment and procedures administered as ordered by a physician. 210 ILCS 45/2-104(b).

g.         Every resident shall be permitted to refuse medical treatment and to know the consequences of that action unless the refusal would be harmful to the health and safety of others and the harm is documented by a physician in the resident's clinical record. 210 ILCS 45/2­104©.

h.         Every resident (or a parent or guardian) must be permitted to inspect and copy all clinical or other records concerning his or her care and maintenance. 210 ILCS 45/2-104(d).

i.          All facilities are required to have a policy for the implementation of physicians' orders limiting resuscitation methods. 210 ILCS 45/2-104.2.

j.          Residents have the right to privacy in their medical and personal care program. 210 ILCS 45/2-105.

k.         All residents have the right to be free from physical and chemical restraints. No physical restraints may be used on a resident unless ordered by a physician. 210 ILCS 45/2-106.

l.          Residents have the right not to be given unnecessary drugs. 210 ILCS 45/2-106.1.

m.        A resident identification wristlet may not be used without a physician's order documenting its necessity. 210 ILCS 45/2-106a.

n.         All residents have the right to be free from abuse and neglect. 210 ILCS 45/2-107. (Note that 210 ILCS 45/3-601 requires that all nursing home employees or agents who become aware of abuse or neglect must report it to the facility administrator. The administrator must report it to the resident's representative or to the IDPH.)

o.         Residents have the right to conveniently receive and mail correspondence and to have reasonable access to telephones; to have private visits at any reasonable hour unless not medically advisable and to have space for such visits; to have facility personnel knock, except in an emergency, before entering their room; and to have unimpeded, private, and uncensored communication by mail, public telephone, and visitation unless reasonably restricted by a physician. 210 ILCS 45/2-108. In addition, married residents have the right to be placed in the same room unless there is no room available in the facility or it is deemed medically inadvisable by the residents' attending physician and so documented in the residents' medical records. Id.

p.         Residents must be permitted the free exercise of religion. 210 ILCS 45/2-109.

q.         Any employee or agent of a public agency, any representative of a community legal services program, or any other member of the general public must be permitted access at reasonable hours to any individual resident of any facility as long as there is no commercial purpose or effect to such access and the access is for any of certain specified purposes. 210 ILCS 45/2-110.

r.          A resident has the right to be discharged from a facility after giving the administrator, a physician, or a nurse of the facility written notice of his or her desire to be discharged. 210 ILCS 45/2-111.

s.          A resident shall have the right to present grievances to the facility without the fear of retaliation. 210 ILCS 45/2-112.

t.          The resident may not be compelled to perform labor for a facility. 210 ILCS 45/2-113.

Not only does the NHCA grant certain rights to the resident, but it also holds the facility responsible for protecting the resident's rights. 210 ILCS 45/2-201, et seq. The NHCA requires the facility to take certain steps to ensure that the residents' rights are not infringed and provides that all residents shall be given a written explanation of their rights enumerated in the Act "at the time of admission to a facility or as soon thereafter as the condition of the resident permits, but in no event later than 48 hours after admission, and again at least annually thereafter." 210 ILCS 45/2-211. The nursing home is required to specify in the nursing home contract the rights, duties, and obligations of the resident, except that the specification of a resident's rights may be furnished on a separate document that complies with the requirements of §2-211. 210 ILCS 45/2­202(g)(6).

2.         OBRA '87 Provisions

Unlike the NHCA, the OBRA '87 provisions do not provide a private right of action. See Nichols v. St. Luke Center of Hyde Park, 800 F.Supp. 1564 (S.D. Ohio 1992) (Title IX of the Social Security Act (42 U.S.C. § 1396r) does not create private right of action enforceable against private nursing homes for violations of its provisions); Illinois Hospital Association v. Edgar, 765 F.Supp. 1343 (N.D.Ill. 1991) (private right of action does not exist against Secretary of HHS for alleged violation of waiver provision of 42 U.S.C. § 1396a(a)(13)(A) allowing states to develop programs for reimbursement of medical expenses).

3.         Common Law Negligence and the Standard of Care

The standard of care that nursing homes are held to is set forth in Stogsdill v. Manor Convalescent Home, Inc., 35 Ill.App.3d 634, 343 N.E.2d 589 (2d Dist. 1976). The Stogsdill court held:

The proprietors of a convalescent home, somewhat like those of a private hospital, are under a duty to exercise reasonable care to avoid injury to patrons, and the reasonableness of such care is to be assessed in the light of the patron's physical and mental condition. 343 N.E.2d at 610.

In addition to proving that the facility's conduct fell below the requisite standard of care, the plaintiff must show that the conduct was the proximate cause of the harm suffered by the resident. The Stogsdill court also set forth that the facility could allege the defense of contributory negligence. Contributory negligence is conduct by the resident that falls below the standard to which the resident should conform for his or her own protection and that is the proximate cause of the harm suffered by the resident. The facility has the burden of proving contributory negligence. The Stogsdill court noted that in regards to the typical nursing home resident, the standard for contributory negligence and/or assumption of the risk is a very subjective and relaxed standard. Id.

Each case should be reviewed to determine whether the defense of contributory negligence should be raised. Since many residents are disabled, it is usually a little more difficult to raise this defense in long-term care cases. Defense counsel should evaluate the jury appeal of a negligence defense before filing.

In situations in which the resident has some mental incapacity but has not been found formally to be mentally ill or incapacitated, whether the person was capable of contributory negligence is a question for the jury. Biundo v. Christ Community Hospital, 104 Ill.App.3d 670, 432 N.E.2d 1293, 60 Ill.Dec. 394 (1st Dist. 1982). In Biundo, the plaintiff alleged negligence against the hospital for the death of the patient, who jumped from his hospital window because of excessive postoperative pain. Id.

The following is a list of allegations related to contributory negligence that defense counsel should consider:

a.         failure to follow physician's orders and advice;

b.         failure to report symptoms;

c.         failure to follow through with recommended treatment;

d.         refusal of treatment (Newell v. Corres, 125 Ill.App.3d 1087, 466 N.E.2d 1085, 81 Ill.Dec. 283 (lst Dist. 1984) (refusal of treatment by competent adult patient fully cognizant of potential consequences of refusal after physician advises on reasonableness of necessity of preferred treatment is defense to charge of malpractice resulting from physician's failure to give treatment);

e.         failure to obtain a second opinion; and

f.          assumption of the risks, which occurs when a resident assumes the risk of harm from the negligent conduct of the facility defendant (e.g., when in the absence of an emergency a resident calls for assistance and the facility does not answer the call within a reasonable period of time (i.e., in less than a couple of minutes) and the resident attempts to get out of bed and injures himself or herself.

 

4.         Breach of Contract

Nursing home residents are able to bring a cause of action against a nursing home for breach of contract. The Illinois Administrative Code provides residents the right to contract with the facility. 77 Ill.Admin. Code §§300.630, 300.3280. Further, the Nursing Home Care Act provides that a resident is able to bring a cause of action for the violation by the facility of any of the rights of a resident under Part 1 of Article II of the Act (210 ILCS 45/3-602), and §2-101 of the NHCA provides that no resident shall be deprived of a right guaranteed by law simply because he or she is a resident of a nursing home. Thus, the right to contract is a right guaranteed by the IDPH and by law (except, of course, in cases of incompetency). A resident of a nursing home is able to sue the facility for breach of contract as long as the resident can make the proper allegations for breach of contract, evidence of a contract, plaintiff's performance of all conditions under the contract, defendant's breach, and existence of damages as a result of the breach. Berg & Associates, Inc. v. Nelson Steel & Wire Co., 221 Ill.App.3d 526, 580 N.E.2d 1198, 162 Ill.Dec. 779 (1st Dist. 1991) (delineating pleading requirements for breach of contract). One count of the complaint in Harris v. Manor Healthcare Corp., 111 Ill.2d 350, 489 N.E.2d 1374, 95 Ill.Dec. 510 (1986), sounded in breach of contract; however, the matter was appealed to the Illinois Supreme Court for reasons of constitutionality.

5.         Consumer Fraud

The authors' research has presented no cases in Illinois in which a resident has alleged violation of the Illinois Consumer Fraud and Deceptive Business Practices Act (Consumer Fraud Act), 815 ILCS 505/1, et seq. To state a claim under the Consumer Fraud Act, the plaintiff must allege a deceptive act or unfair practice, intent on the defendant's part, reliance by the plaintiff on the deception, and occurrence of the deception during trade or commerce. Saunders v. Michigan Avenue National Bank, 278 Ill.App.3d 307, 662 N.E.2d 602, 214 Ill.Dec. 1036 (1st Dist. 1996). Of import is whether the cause of action implicates consumer protection concerns. If a cause of action were pursued against a facility based on the Consumer Fraud Act, the cause of action against the facility would most likely sound in contract. Illinois courts have held that when a plaintiff attempts to allege a violation of the Consumer Fraud Act in a case that on its face appears to involve a breach of contract, the relevant inquiry is whether the alleged conduct implicates consumer protection concerns. Scarsdale Builders, Inc. v. Ryland Group, Inc., 911 F.Supp. 337 (N.D.Ill.1996).

Please note Ardt v. State, 292 Ill.App.3d 1059, 687 N.E.2d 126, 227 Ill.Dec. 203 (1st Dist. 1997), which analogizes the attorneys' fees provision of the NHCA to the fees provision in the Consumer Fraud Act.

6.         Survival Statute and Wrongful Death Act

The survival statute, 755 ILCS 5/27-6, and the Wrongful Death Act, 740 ILCS 180/0.01, et seq., are similar, so Illinois case law examines these statutes together much of the time. The distinction between the causes of action is that a survival action allows for recovery of damages for injury sustained by a decedent up to the time of death, whereas the wrongful death action allows a decedent's next of kin to recover damages for their loss based on wrongful actions of another that were committed against the decedent. Damages in a wrongful death action do not accrue until after death and address injuries suffered by the next of kin due to loss of the decedent. The survival statute maintains a cause of action that accrued to the decedent, so under it a cause of action is brought on behalf of the estate. Kaufman v. Cserny, 856 F.Supp. 1307 (S.D.Ill.1994).

Wills v. DeKalb Area Retirement Center, 175 Ill.App.3d 833, 530 N.E.2d 1066, 125 Ill.Dec. 657 (2d Dist. 1988), examined the Wrongful Death Act and the survival statute in relation to the NHCA. The court specifically held that the NHCA allowed actions, including actions for punitive damages, under the survival statute, but since the NHCA allowed for treble damages, the estate could not also recover for common law punitive damages under the survival statute. The court further held that a Wrongful Death Action could be maintained against the facility based on the allegations of the complaint; however, since the Wrongful Death Act does not include a provision for punitive damages, the court would not expand the legislature's intent. Thus, a claim for wrongful death based on the alleged negligent acts of the nursing home would stand but a claim for punitive damages would not. See also Lloyd v. County of DuPage, 303 Ill.App.3d 544, 707 N.E.2d 1252, 236 Ill.Dec. 682 (2d Dist. 1999) (complaint adequately pled wrongful death cause of action against nursing home facility).

7.         Negligent Hiring, Supervision, and Retention

In Illinois, there is no case law that examines the issue of negligent hiring in a nursing home situation. However, in Starr v. Leininger, 198 Ill.App.3d 622, 556 N.E.2d 266, 144 Ill.Dec. 799 (3d Dist. 1990), the estate of a deceased nursing home resident brought a cause of action against the home to recover the value of a ring stolen by a home employee. The plaintiff argued that the facility was liable for the property damage under the theory of respondeat superior for negligent hiring practices, among other violations of the Nursing Home Care Act. The appellate court determined that although the facility may be liable for the negligent, willful, or even criminal acts of its employees when such acts are committed in the course of employment and in the furtherance of the business of the employer, the employer is not liable to an injured party when the acts were committed solely for the benefit of the employee. Thus, in Starr, the appellate court decided that the facility could not be held responsible for the theft by an employee. Significantly, the Starr court further limited the definition of "injury" under §3-601 of the NHCA to personal injuries, which did not include the theft of a ring.

Although seemingly the NHCA does not provide liability for negligent hiring, it still is possible to assert a cause of action for negligent hiring outside of the Act. To assert a cause of action for negligent hiring, a resident must allege and prove (a) that the employer knew or should have known that the person hired had a particular unfitness for the job that would create a foreseeable danger to others and (b) that this particular unfitness was the proximate cause of the plaintiff's injury. Strickland v. Communications & Cable of Chicago, Inc., 304 Ill.App.3d 679, 710 N.E.2d 55, 237 Ill.Dec. 632 (1st Dist. 1999). Strickland does note that the NHCA protects residents from the criminal acts of employees of a facility; however, it does not state that the Act provides a cause of action for negligent hiring. See Section V.A.2.h. below for more discussion.

8.         Healing Art Malpractice

Section 2-622 of the Code of Civil Procedure, 735 ILCS 5/2-622, sets forth the requirement that all complaints of medical negligence be accompanied with a written report of a health care professional. This provision, which was enacted ten years after the Nursing Home Care Act, also limits the amount of attorneys' contingent fees that can be recovered and bars the recovery of punitive damages. The NHCA through the private right of action provision encourages litigation. Based on this conflict between the statutes, many plaintiffs' attorneys take the position that §2-­622 does not apply in a nursing home case.

The Fourth District Appellate Court is the first court to address this issue. In Eads v. Heritage Enterprises, Inc., No. 4-99-0954, 2001 WL 1145161 (4th Dist. Sept. 26, 2001), an appeal was taken pursuant to Illinois Supreme Court Rule 308. The certified question presented was

In a case where the [p]laintiff has sued a nursing home for injuries sustained as a result of alleged violations by the nursing home, its staff[,] and employees, of the [Nursing Home Act] and the regulations promulgated pursuant thereto [77 II1.Adm.Code § 300 et seq. (West 2001)], is the [p]laintiff required to comply with the mandate of [section 2-622 of the Code]? 2001 WL 1145161 at *2.

The Eads court discussed the conflicts in the statutes noted above and found that the Nursing Home Care Act was more specifically applicable to the facts of the case before it and therefore controlled over §2-622 of the Code of Civil Procedure. Since the Nursing Home Care Act applied, the plaintiff was not required to file a §2-622 certificate.

The specific acts of negligence alleged in Eads were that the defendants failed to

l.          adequately supervise plaintiff's activity;

2.         ensure that she did not walk without assistance;

3.         respond to her call light when she requested assistance;

4.         equip her bed with a pressure release to alert staff that Eads had risen from her bed; and

5.         adequately staff the facility to ensure appropriate assistance would be provided.

The defendants, i.e., the nursing home and its owners, moved to dismiss Eads' amended complaint arguing that her claim sounded in "healing art malpractice." The trial court granted defendants' motion and dismissed Eads' amended complaint allowing her leave to amend. Eads chose instead to seek an interlocutory review under S.Ct. Rule 308, and the appeal was allowed.

The court construed a conflict in the statutes, i.e., that the Nursing Home Care Act encourages litigation against owners and licensees of a nursing home for the protection of nursing home residents, while §2-622 discourages litigation in the area of medical malpractice.

Eads contended that the portions of the Nursing Home Act that outline residents' rights, the liability of the owner/licensee, and damage recovery implied that all negligence-type actions, including healing art malpractice, could be pled under the Nursing Home Care Act. Since the Nursing Home Care Act did not require a physician's certificate to initiate any type of suit, any action brought under the Nursing Home Care Act did not require such a certificate.

The Eads majority found an irreconcilable conflict between the Nursing Home Care Act and §2-622 by concluding that §2-622's requirement of the pre-suit determination by an expert that a cause of action is meritorious is an unreasonable burden on those who have a private right of action under the Nursing Home Care Act.

The majority opinion goes on to determine that the Nursing Home Care Act was more specifically applicable to the facts in the case before it and therefore controlled over §2-622.

Since the Nursing Home Care Act controlled and it does not require that a certificate be filed, the majority opinion held that no certificate was necessary in order for the plaintiff to proceed on its amended complaint.

Presiding Justice Steigmann dissented, noting that the plain language of §2-622 stated that it was to apply to "any action where damages are sought for injuries resulting from medical, hospital, or other healing art malpractice." [Emphasis in original.] 2001 WL 1145161 at *7. Further, Justice Steigmann noted that §1-108(b) of the Code provides that in matters in which the "procedure is regulated by statutes other than those contained in this [a]ct, such other statutes control to the extent to which they regulate procedure but [a]rticle II of this [a]ct applies to matters of procedure not regulated by such other statutes." [Emphasis added by Justice Steigmann.] 2001 WL 1145161 at *8.

Justice Steigmann points out that the Nursing Home Care Act contains no provision regulating pleadings; therefore, he concludes that there is no conflict in the Nursing Home Care Act and §2-622 of the Code.

According to Justice Steigmann, the relevant provisions of the Nursing Home Care Act and §2-622 of the Code are not in conflict and therefore if a- healing art malpractice claim arises in a facility covered by the Nursing Home Care Act, § 1-108b) of the Code governs and plaintiffs in those circumstances should be required to conform with the pleading requirements of §2-622 of the Code.

Justice Steigmann also notes that the certified question is very broad and majority opinion does not do a fact-specific analysis to determine whether a particular claim falls within the purview of the term "healing art malpractice."

Justice Steigmann does conclude that the allegations regarding defendants' lack of care and supervision in allowing the resident to fall did involve issues that were "inherently medical" and therefore the plaintiff's claim did sound in healing art malpractice and he would require that the plaintiff conform to the pleading requirements set forth in §2-622 of the Code.

As of this writing, there is a petition for leave to appeal pending before the Illinois Supreme Court.

Eads notwithstanding, defense counsel should continue to ask the court to require that a case for healing art malpractice brought under the Nursing Home Care act comply with §2-622.

Other cases that defense counsel should review on this topic include Owens v. Manor Health Care Corp., 159 Ill.App.3d 684, 512 N.E.2d 820, 111 Ill.Dec. 431 (4th Dist. 1987), and Kolanowski v. Illinois Valley Community Hospital, 188 Ill.App.3d. 821, 544 N.E.2d 821, 136 Ill.Dec. 135 (3d Dist. 1989) (distinguishing Owens and requiring §2-622 affidavit due to fact that resident was receiving skilled care), Taylor v. City of Beardstown, 142 Ill.App.3d 584, 491 N.E.2d 803, 96 Ill.Dec. 524 (4th Dist. 1986) (court determined that failure to provide bed rail restraints involved medical judgment of plaintiff's condition), and Stogsdill v. Manor Convalescent Home, Inc., 35 Ill.App.3d 634, 343 N.E.2d 589 (2d Dist. 1976) (pre-Act case finding medical judgment was required for nursing care provided to monitor ulcers on ankles).

9.         Liability

a.         Strict Liability

The NHCA, in contradiction to common law agency principles, imposes strict liability for both intentional and negligent torts. Specifically, 210 ILCS 45/3-601 states:

The owner and licensee are liable to a resident for any intentional or negligent act or omission of their agents or employees which injures the resident.

b.         Actual Agency

In order to establish an actual agency relationship in a hospital setting case, it must be shown that the hospital exercised control over the physician's treatment decisions and diagnosis. The courts look to see whether the hospital had any control over the way the physician performed the following functions:

1.         conducting the medical examination;

2.         taking the medical history;

3.         evaluating the patient's condition;

4.         prescribing medications;

5.         ordering tests;

6.         determining what consultant to call in; and

7.         making a medical diagnosis.

c.         Apparent Agency

The NHCA holds the facility harmless for the negligence of the resident's personal physician. See 210 ILCS 45/2-104. According to both federal and state law, long-term nursing care facilities as institutions are not licensed to provide physician services and in fact are prohibited from doing so. Despite these provisions, plaintiff's counsel may attempt to impose liability on the facility for the physician's negligence through the theory of apparent agency. The federal and state regulations and many of the long-term care documents address the relationship between the facility and the presiding physician and can be used by either the plaintiff or the defendant to establish an apparent agency relationship. The regulations that address this issue include the Medical Practice Act of 1987, 225 ILCS 60/1, et seq.; the Nursing and Advanced Practice Nursing Act, 225 ILCS 65/5-1, et seq.; the OBRA '87 regulations; the NHCA; and the IDPH regulations. Other documents that should be reviewed when faced with an apparent agency issue include the long-term care facility contract with the resident, the documents granting privileges to the attending physicians to practice at the facility, and brochures and advertisements.

Apparent agency flows from the acts of a principal and arises when, by words or conduct, the principal creates the reasonable impression in a third party that the agent has the authority to perform a certain act on its behalf. When establishing the relationship of apparent agency, the key element to be satisfied is justifiable reliance on the part of the plaintiff on a representation made by the principal or agent.

10.       Other Forms of Liability

A violation of NHCA regulations may subject the violator (licensee) to other sanctions imposed by the Illinois Department of Public Health. Violations may be of three basic types:

Type A violation. A “Type ‘A’ violation” means a violation of the NHCA or of the rules promulgated thereunder that creates a condition or occurrence relating to the operation and maintenance of a facility presenting a substantial probability that death or serious mental or physical harm to a resident will result therefrom. 210 ILCS 45/1-129.

Type B violation. A “Type ‘B’ violation” means a violation of the NHCA or of the rules promulgated thereunder that creates a condition or occurrence relating to the operation and maintenance of a facility directly threatening to the health, safety, or welfare of a resident. 210 ILCS 45/1-130.

Administrative warning. If the IDPH finds a situation, condition, or practice that violates the NHCA but does not directly threaten the health, safety, or welfare of a resident, an administrative warning shall be issued. 210 ILCS 45/3-303.2.

Criminal penalties exist only for an intentional failure to correct Type A or Type B violations within the time specified in the notice of approved plan of correction, not for the original violation. People v. Gurell, 98 Ill.2d 194, 456 N.E.2d 18, 74 Ill.Dec. 516 (1983).

11.       Other Remedies

Section 3-601 of the NHCA holds the owner of the facility as well as the licensee liable for any intentional or negligent act or omission of their agent or employees that injures a resident.

Section 3-603 of the Act permits a resident to maintain an action under the Act for any other type of relief, including injunctive and declaratory relief.

Section 3-604 of the Act allows class actions for violations of rights.

Section 3-701 provides that the operation or maintenance of a facility in violation of the Act is a public nuisance that may be enjoined.

Section 3-714 provides that remedies provided by the Act are cumulative and do not restrict a party from seeking any other remedy.

B.        Typical Cases and Defenses

1.         Fall Cases

Fall cases are the most prevalent type of cases. Most of these cases involve allegations of failure to assist and attend, failure to use or improper use of a restraint, or failure to properly use side rails.

a.         Allegations

(1)        Failure to assist and attend

One of the most common allegations of negligent care is the failure to assist and attend a resident. A typical case is one in which the resident suffers injury after falling when the resident had been designated as in need of assistance or was known to be recovering from a procedure. Other typical cases include allegations that the nursing home failed to recognize that the resident required assistance with ambulation or needed to be restrained. These types of cases usually involve occurrences in which the resident is injured while undressing or using toilet facilities. Other situations include allegations that the facility failed to answer a call for assistance in a reasonable time frame.

            (2)        Failure to properly use a restraint

Cases involving falls usually concern allegations of lack of supervision after the resident has been left unrestrained and/or unattended in a chair, wheelchair, or Geri-chair. Allegations of injury involving a fall also occur when a resident is injured while being transferred with the assistance of the facility staff.

            (3)        Failure to properly use side rails

Cases involving falls from bed often involve mixed allegations of failure to restrain, failure to supervise, failure to use side rails, and failure to assist and attend. In some of these cases, the resident had some type of restraint but the allegations state that the partial restraint was inadequate.

b.         Defenses

The following are potential defenses to the various allegations in fall cases:

·        Federal and state regulations prohibit the use of restraints except as necessitated by the medical condition of the resident and as ordered by the physician.

·        The facility complied with federal and state regulations and the facility's policies and procedures manual.

·        There was no order for a restraint by the physician, or, in the alternative, if there was an order, the circumstances at the time of the occurrence did not permit the use of a restraint.

·        The family and/or resident did not give the appropriate permission for the use of restraints. (Documents supporting this defense are usually found in the resident's acknowledgment of receipt of the resident's bill of rights, the contract, and the resident's business file.)

·        The resident had a history and tendency of falling that was addressed in the resident's care plan, which included an overview and assessment of the resident's condition.

·        Reasonable procedures were used to prevent the fall while still allowing the resident the least restricted environment.

·        The resident was receiving adequate assistance from the facility staff and transferring when the accident occurred.

·        If the fall was caused by equipment malfunction, the equipment was properly maintained and had no prior history of a malfunction.

2.         Injuries Due to Use of Restraints

a.         Allegations

Cases involving injuries due to use of restraints involve allegations of failure to properly apply the restraint or follow the doctor's order regarding the restraint. The most common type of case is one in which the resident strangles or severely injures himself or herself in the restraint.

b.         Defenses

The following are possible defenses to restraint injury cases:

·        The restraint was ordered by a physician, and the order and physician's notes document the justification for the restraint order.

·        The restraint ordered was appropriate for the resident's condition and/or personal safety.

·        The restraints were checked and released on a regularly scheduled basis in conformance with the physician's order.

·        All federal/state regulations relative to restraint use were complied with.

·        The regulations prohibit a facility to utilize restraints for convenience.

·        Restraints may be used only to treat medical symptoms.

·        The regulations require that if a restraint is needed, the facility must use the least restrictive restraint.

·        The type of restraint used by the facility was in conformance with the physician's order for the restraint.

·        The restraint was properly applied and in conformance with the physician's order.

·        The staff was trained in the proper application of the restraint use and monitoring.

·        The need for the restraint was addressed in the care plan and authorized by the resident and/or family.

·        Even if the restraint were properly applied, injury would have occurred to the resident if the resident loosened portions of the restraint (which can be established through expert testimony).

 

3.         Wandering Resident Cases

a.         Allegations

Wandering resident cases include allegations that the facility negligently allowed the resident to wander or escape from the facility unattended or unnoticed and failed to take proper precautions to protect the resident's safety.

b.         Defenses

Possible defenses to wandering resident cases include the following:

·        Without a physician's order prohibiting the resident from moving about the facility and/or outside the facility, the facility was prohibited by federal and state regulations from making such prohibitions.

·        The facility is not required to have one-on-one nursing care or a one-on-one nursing attendant to follow the resident at all times.

·        Federal and state regulations and the fire code prohibit exit doors from being locked from the inside.

·        There must be a physician's order detailing the need to put the resident on a locked wing in a facility.

·        The resident had no prior history of wandering that would put the resident at risk of hurting himself or herself.

·        The facility had taken precautions to prevent the resident from harming himself or herself while moving about the facility.

·        It is more favorable for the resident to move about the facility unrestricted (which can be established through expert testimony).

·        The facility had installed an alarm system that was in good working order.

·        The facility had a resident monitoring device that triggered exit alarms.

·        The Alzheimer's unit had a coded exit panel.

·        The facility had recognized any potential for wandering in the care plan and implemented appropriate responsive action to prevent harm to the resident.

·        The facility had alerted staff to the potential of any type of wandering and had trained staff to look out particularly for residents who were more mobile than others.

·        The staff had checked the whereabouts of the resident on a routine basis and then notified the facility immediately if the patient's location could not be ascertained.

·        The facility had at the doorway a picture board with pictures of residents who were known to leave the facility on a routine basis.

4.         Suicide and Attempted Suicide Cases

Cases against facilities for a resident's suicide or attempted suicide usually are brought against ICF/MI-designated facilities. These types of facilities are delegated to care for residents who are mentally ill. Most of these facilities have a psychiatrist on staff.

a.         Allegations

These cases are relatively rare but usually involve failure to note suicidal tendencies, failure to follow the doctor's recommendations regarding restraints or surveillance, or some defect in maintenance of the premises such as unlocked windows in a unit that is located on an upper floor.

b.         Defenses

Common defenses to these cases are that the physician did not diagnose suicidal tendencies and that the premises were safe and conformed to all regulations.

5.         Decubitus Ulcer Cases

a.         Allegations

With regard to decubitus ulcers, the plaintiff usually alleges that the facility failed to properly monitor, care for, and render treatment for the ulcers. Many residents are admitted with no skin breakdown or a minimal amount of skin breakdown. During their stay, as their preexisting medical conditions progress, the residents' skin integrity deteriorates and they develop more ulcers, which are classified in four different stages. Due to the nature of the skin breakdown, this type of case creates a lot of jury appeals.

b.         Defenses

Potential defenses in decubitus cases include the following:

·        Due to the resident's preexisting condition, development of decubitus ulcers was inevitable. (The prior medical records, facility chart, physician records, and expert testimony should be utilized to develop this defense. Diabetes, pneumonia, vascular disease, and paralysis are conditions that put a resident at high risk of developing skin breakdown.)

·        The facility complied with federal and state regulations and with the facility's policies and procedures manual.

·        The facility engaged in all appropriate preventative measures.

·        The potential for skin breakdown was addressed in the care plan.

·        The resident was properly hydrated (which preferably will be established thorough recorded intake and output documentation).

·        The resident suffered from skin breakdown at the time of admission.

·        The resident received adequate nutrition as ordered by the physician through recorded meal and supplement intake and/or tube feeding intake.

·        The resident was mobile in conformance with the physician's orders.

·        The resident was turned and repositioned every two hours or more frequently if ordered.

·        The facility provided protective devices ordered by the physician, including egg crate mattresses, heel and elbow protectors, etc.

·        The resident received skin treatments ordered by the physician, such as lotion application to prevent dryness and breakdown.

·        The resident was changed and cleaned after an incontinent episode at least every two hours.

·        The resident's skin breakdown was immediately reported to the nursing staff.

·        The nursing staff assessed the resident's skin condition on a regular basis for signs of breakdown.

·        The skin breakdowns were reported to the physician within a reasonable period, and the resident was receiving treatment as ordered.

·        The treatment's ineffectiveness was promptly reported to the physician to receive new treatment orders.

IV.       GENERAL DEFENSES

A.        Statute of Limitations

Many plaintiffs' attorneys will attempt to argue that the nursing home resident is not competent or has a legal disability so that they can avoid complying with the statute of limitations period. In general, the applicable statute of limitations period is two years. 735 ILCS 5/13-202. In a personal injury case, a person is not legally disabled if he or she can comprehend the nature of the injury and its implications. Sille v. McCann Construction Specialties Co., 265 Ill.App.3d 1051, 638 N.E.2d 676, 202 Ill.Dec. 808 (1st Dist. 1994). It is a recognized principle in Illinois that the fact that someone is suffering from an impairment, either physical or mental, does not overcome the presumption of competency and does not render the person legally disabled. Id. According to the Sille court, a broader definition of "legally disabled" would enable all persons who are either physically or emotionally challenged due to an injury to be immune from the law, and the wheels of justice would come to a halt every time a litigant broke a bone or caught a cold. Id.

The statute of limitations can be raised by a motion to dismiss when it affirmatively appears from the complaint that the action is time barred. Cundiff v. Unsicker, 118 Ill.App.3d 268, 454 N.E.2d 1089, 73 Ill.Dec. 840 (3d Dist. 1983). Moreover, once the defendant raises the statute of limitations as a defense, it becomes incumbent on the plaintiff to set forth facts sufficient to avoid the statutory limitation. Id. In Cundiff, the plaintiff failed to establish a factual basis for the application of the discovery rule to overcome the defendant's motion to dismiss on the ground of timeliness.

In Illinois every person is presumed competent to testify, and the burden is on the party challenging the competency to show that the witness is incompetent. People v. Williams, 147 Ill.2d 173, 588 N.E.2d 983, 167 Ill.Dec. 853 (1991). In making the decision of whether a party is competent, the courts evaluate whether the party

1.         receives correct impressions from the senses;

2.         recollects those impressions;

3.         understands questions; and

4.         appreciates the moral duty to tell the truth. Id.

Illinois courts have held that in order to establish a person as legally disabled, the record must contain sufficient allegations of fact from which one could conclude that the person seeking to be found legally disabled was incompetent and, therefore, "entirely without understanding or capacity to make or communicate decisions regarding his person and totally unable to manage his estate or financial affairs." Estate of Riha v. Christ Hospital, 187 Ill.App.3d 752, 544 N.E.2d 403, 405, 135 Ill.Dec. 907 (1st Dist. 1989). See also Sille, supra (plaintiff's complaint was properly dismissed when allegations that plaintiff, due to his alcohol abuse, was unable to manage his personal affairs at time of injury were held to be legal conclusions unsupported by evidence); Peach v. Peach, 73 Ill.App.2d 72, 218 N.E.2d 504 (2d Dist. 1966) (claim of mental retardation, by itself, was insufficient to establish requisite standard for tolling statute of limitations); Udstuen v. Patterson, 198 Ill.App.3d 67, 555 N.E.2d 750, 144 Ill.Dec. 391 (3d Dist. 1990) (plaintiff's allegations of confinement in health care facility were mere legal conclusions of legal disability).

B.        Compliance

Nursing home facilities are subject to causes of action filed in civil litigation and administrative proceedings filed in the Illinois Department of Public Health. The administrative litigation occurring in the IDPH is for violations of the NHCA found by the Department during the inspection of facilities. The NHCA provides procedures by which a facility may be reported for possible violations of the Act, necessitating an inspection by the Department under the Act; in addition, facilities are inspected during licensure and relicensure. 210 ILCS 45/3-212.

Inspections in response to complaints are generally shorter in duration than licensure surveys and focus primarily on those areas reported to be deficient. During these inspections, if the Department has determined that the facility has failed to comply with all applicable state and federal licensure requirements, the facility will be cited for the deficiencies. When the Department cites deficiencies, the facility has the opportunity rebut those allegations. When deficiencies are cited, the IDPH requires that the facility submit a written plan of correction within ten days detailing how the deficiencies will be corrected. When those deficiencies are disputed, due process requires an evidentiary hearing with respect to the alleged deficiencies. Altenheim German Home v. Turnock, 902 F.2d 582 (7th Cir. 1990). In hearings before the IDPH, compliance under the statute is a defense. Appeal of the Department's administrative findings may be had to the circuit court; subsequent appeals go to the appellate court.

V.        INVESTIGATION AND DISCOVERY

A.        Securing the Documents and Evidence

Immediately upon notification of a potential action or a pending lawsuit, one of the first things that should be done from a defense standpoint is to secure all of the documents and/or evidence relating to the allegations. The process is very similar to the investigation process conducted in a medical negligence case, but there are certain documents and inquiries that need to be made that are unique to the long-term care setting. Many documents generated in a long-term care setting are not required to be maintained pursuant to a regulation. Therefore, the facility discards these documents in the normal course of business. Often, these documents may be some of the most beneficial documents from a defense standpoint.

1.         Medical Records

77 Ill.Admin. Code §300.1810 requires that certain medical records be .maintained on all residents in a facility. The individual making an entry in the records must authenticate it. The record shall contain all physician's orders and plans of treatment, all prior medical history, current medical status, physical and mental functional status, sensory and physical impairments, nutritional status and requirements, special treatments and procedures, mental and psychosocial status, discharge potential, rehabilitation potential, cognitive status, and drug therapy. Obviously, these records provide a blueprint to a resident's physical and mental well-being in a facility. These records can be most useful in determining whether appropriate treatments were utilized by the facility over time and whether the alleged negligent act was a single incident or the culmination of a series of events.

Typically, the resident's medical chart is kept at the nursing station located in the unit where the resident is assigned. However, it is important to note that many of the documents that make up the chart are not always maintained together. For example, when a resident has been at the facility for an extended length of time or has several admissions to the facility, older portions of the chart and/or prior admissions are periodically stored in the medical records department. This process is referred to as "thinning." In addition, treatment records and flow sheets are not always kept with the charts.

The regulations require that the resident's chart contain certain documents. The initial step of defense counsel is to obtain all of the documents and assemble the chart. Each section of the chart should be reviewed to determine whether the charting complies with federal and state regulations and the facility policies and procedures manual. In addition, special attention should be given to portions of the chart that can be used to further defense theories.

77 Ill.Admin. Code §300.1820 specifies the types of documents that must be included in the medical chart. In addition, certain other documents that may be included may be helpful to the defense.

Fact sheet. The fact sheet should include the resident's name, age, prior address, emergency contact persons, physicians' numbers, and date of admission. Typically, a new fact sheet is prepared for each admission.

Transfer forms. A transfer form must be filled out for all transfers between the facility and the hospital. It describes the resident's condition and reason for transfer. Facility transfers to the hospital should include a medication sheet. Hospital transfers back to the facility should include instructions for care and whether any follow-up care is needed.

Advance directives or consent for medical care documents. These documents include do­-not-resuscitate (DNR) orders, consents to withhold treatment, and/or living wills.

Medical history and physical examination forms. The physician must conduct an initial history and physical at the time of admission. The physician's notes should document that a complete physical was conducted. There also should be an annual history and physical and a history and physical for all readmissions to the facility. Special attention should be given to any references to preexisting conditions or changes of the diagnosis on readmission.

Physician's orders. The physician must maintain an order sheet that includes orders for medications, treatments, therapies, diet, activities, and special procedures required for the resident's safety and well-being.

Physician's progress notes. Depending on whether the resident is an intermediate or skilled resident and on the facility's policies and procedures manual, there should be physician's notes once every 30 - 60 days.

Physician-consultants' notes. These notes typically include the podiatry, dental, and ophthalmology consultants' notes. The frequency of these notes is usually determined by the attending physician's referral orders for the particular consultant.

Nursing admission assessment. The nursing admission assessment must include the completed minimum data set (MDS), the federally mandated assessment instrument that captures information about the resident's capacity to perform daily life functions and significant impairments in functional capacity. In addition, each facility usually has its own established admitting assessment forms that must be completed at the time of the initial nursing assessment. It is common practice for many facilities to take photographs of residents who have skin breakdown at the time of admission.

Nurses' notes. Regarding nursing and personal care, resident responses or developments should be recorded as they are noted. A notation should be made a minimum of once a month; if no development occurs for a month, that fact should be indicated in the record.

Care plan. The care plan is a document created by an interdisciplinary team at the facility with input from the resident's representative. The care plan addresses the care issues noted in the MDS and sets the interventions to deal with the areas of concern. Federal and state regulations mandate when the care plan must be updated.

Several documents that relate to the care plan, such as the minutes of the care planning meetings, attendance records, and correspondence sent to the resident's family members encouraging them to participate in the care plan process, are kept separate from the care plan. The facility care plan coordinator is usually the custodian of the records.

Treatment records. These records are used to document specific treatments ordered by the attending physician. The treatment records are most commonly used to record treatments for decubitus ulcers. Other types of treatment documentation may include care provided for a short-­term medical condition such as a broken bone or nutritional supplement treatments.

Laboratory and medical test results. When reviewing the laboratory documents, defense counsel should evaluate whether the facility reported all abnormal findings to the physician. If the case involves a fall, defense counsel should obtain all copies of the radiological films. Defense counsel should identify and review all films taken prior to the occurrence.

Social service notes. These notes are usually very helpful in attacking the claims made by the resident's family in a Wrongful Death Act case. The social service notes should contain information about the family relationships.

Dietary records. These documents typically include the resident's intake. The dietary supervisor usually has his or her own record on each resident, which is kept in the dietary department.

Therapy notes. Therapy notes are almost always kept with the medical chart. There are various therapy records, which might include physical, respiratory, recreational, speech, music, and/or occupational therapy. Many facilities contract out the therapy work to vendors. It should be noted that the therapy is often provided by a hospice provider.

Hospice records. Hospice provides a variety of services such as nursing and therapy. The hospice records are very important in addressing life expectancy issues.

Hospital records. Many hospital will send the key documents relating to the resident's hospital admission to the facility at the time of readmission.

Flow Sheets. Typically, flow sheets are not required to be kept pursuant to federal or state regulations. However, many facilities utilize them. Flow sheets are usually prepared by CNAs, who mark their initials on the forms. The flow sheets document activities of daily living (ADLs) such as bowel and bladder function, bathing, dressing, recreation participation, turning, walking, etc.

2.         Other Facility Documents

a.         The Business File

Facilities maintain a business file for each resident. This file is usually kept in the administrative offices and contains many of the administrative documents that the facility is required to have for each resident, such as the contract, DNR authorizations, advance directives, the resident's signed wishes regarding restraints, and the resident's acknowledgment of receipt of the resident's bill of rights and the policies and procedures manual.

The business file also contains communications between the facility and the resident's family or representative. These documents should be reviewed carefully by the defense counsel and not overlooked. Correspondence with the family often will demonstrate the family's lack of involvement in the resident's care. Many times, the business file will contain correspondence from the resident's family thanking the facility for providing wonderful care. The business file also contains billing information.

b.         The Policies and Procedures Manual and Index

It is imperative to secure the policies and procedures manual in place at the time of the occurrence. Pursuant to the NHCA, all licensed long-term care facilities are required to implement a set of written policies and procedures that regulate all of the care and services provided to the facility residents. 210 ILCS 45/2-210. The NHCA sets forth that the policies and procedures must include "the procedure for the investigation the resolution of resident complaints as set forth under Section 3-702." Id. The residents, the residents' family members and/or legal representatives, the staff, and the public all have the right to review the policies and procedures enacted by the facility.

Policies and procedures manuals are updated and changed as new regulations are promulgated. The regulations require that the facility review the policies and procedures on an annual basis. 77 Ill.Admin. Code §330.7710(a). The review committee typically includes the medical director, the DON, and the administrator. There is usually some type of record that is maintained and documentation that the review was conducted. In addition, it is important to ascertain what practices were utilized and what communications were sent to the staff to educate them regarding the implementation of new or changed policies and procedures.

c.         Incident Reports Regarding the Resident

When an incident occurs involving any resident, a facility is obligated pursuant to 77 Ill.Admin. Code §300.690 to notify the IDPH via telephone the day of the incident to make a report and to follow up that phone call with a narrative summary of the incident within seven days. The regulation further mandates that a summary report of the incident be kept in the patient's progress notes. These reports are useful in detailing any prior incidents in which a resident may have been involved. These incidents could be used by plaintiff's counsel to show that the substandard treatment of the resident was an ongoing occurrence and not a one-time incident.

d.         Statements

The statement of any person witnessing an occurrence is highly relevant. If the plaintiff has made a statement to an employee immediately after the occurrence, it is of utmost importance to have that employee record what the plaintiff said since this statement could negate one of the elements in a claim for negligence, proximate cause.

e.         Other Documents That Relate to the Resident

A thorough investigation should be conducted at the facility to identify any other records that were generated relative to the resident.

f.          Staffing Records and Staffing Assignment Calculation Sheets

Staffing records are to be kept by the facility pursuant to 77 Ill.Admin. Code §300.1230. These records are critical in reference to the nature and abilities of the staff present during an alleged occurrence and will reveal whether and how many skilled staff members were available at the time of the incident. That a certain number of skilled staffers were available at a certain time is of import since 77 Ill.Admin. Code §300.1230 provides that a certain number of skilled, general, and intermediate care (light) staff members must be present at a given time based on the number of residents in a facility. A plaintiff's claim of negligence could be made easier if the number of staff members available - particularly skilled staff - was insufficient at the time of an occurrence.

g.         Surveys and Plans of Correction

Defense counsel should take the position that surveys and plans of correction are protected by the medical studies statute, 735 ILCS 5/8-2101.

 

h.         Personnel Files of Key Caregivers

Personnel records are to be maintained according to 77 Ill.Admin. Code §300.650(b). Included in the records for each employee are the employee's date of employment, date of birth, home address, educational background, past experience and types of employment, type of position in the facility, and performance evaluations. For employees who are no longer employed, the records must contain the last date employed and the reason for leaving. These records are of import in considering claims for negligent hiring of an employee since they will show what the facility knew at the time a position was offered to the employee and will be helpful in determining whether the facility's hiring of that employee was indeed negligent. Further, if the care and treatment provided by an employee is at issue in a particular claim, the file will be of use in that the file contains performance evaluations. These evaluations could be critical if the resident alleges that a certain employee continually acted in a certain manner since they could show that the employee's superiors found that the employee acted in a manner consistent or inconsistent with that allegation.

i.          Consultants' Reports

Many facilities have outside consulting in various disciplines such as nutrition, risk management, therapy, overall nursing care, medication administration, and/or social services. Defense counsel should always evaluate whether these records are protected from production pursuant to the medical studies statute, 735 ILCS 5/8-2101.

j.          The Floor Plan

The floor plan could be relevant in wandering-patient cases or cases involving the negligent supervision of a resident.

k.         Marketing Material

The admissions director is usually the person who has knowledge about the marketing material.

l.          Visitor Sign-In Sheets

Visitor sign-in sheets may be helpful in showing that the family did not visit the resident as they assert.

m.        Residents' Advisory Council Meeting Minutes

77 Ill.Admin. Code §300.640 authorizes the creation of a residents' advisory council consisting of at least five resident members. The council shall be open to all residents and/or their representatives. No employee or person affiliated with the facility shall be a member on the council. The council shall review the facility's procedures and provide a forum for implementing residents' rights and facility responsibilities. 77 Ill.Admin. Code §300.649(l) provides that the council will be a forum for obtaining and disseminating information, soliciting and adopting recommendations for facility programming and improvements, early identification of problems, and recommending orderly resolution of problems.

n.         Photographs

Many times photographs are utilized to show the condition of the facility at the time of the occurrence. Also, photographs of the plaintiff's injuries may be shown to a jury in an attempt to elicit sympathy.

o.         Surveillance Tapes

Many family members often employ an undercover detective to take surveillance tapes documenting the care and services provided by the facility.

p.         Menus for the Time Period in Question

77 Ill.Admin. Code §300.2080 requires that the menus served to the residents be kept on file at the facility for not less than 30 days. The menus of the resident could be important if malnutrition is one of the plaintiff's allegations.

3.         Documents Not in the Control of the Facility

Documents not in the control of the facility that may be relevant and should be sought out and secured include

a.         police reports;

b.         a death certificate/coroner's report;

c.         ambulance records;

d.         diaries of family members or friends;

e.         records maintained by the physician's office;

f.          reports to governmental agencies; and

g.         statements (see Section V.A.2.d. above).

4.         Former Employees' Testimony

a.         Identifying Key Witnesses

Long-term care facilities are known for a high employee turnover rate. Therefore, identifying the key employees who will serve as witnesses at the outset of the investigation is very important. Defense counsel should go beyond review of the medical chart to determine the key witnesses.

Other documents that may assist in identifying employees who provided care to the resident include the resident's business file (see Section V.A. above) and care plan file (see Section IV.B. above).

The facility staff interviewer should be asked to identify the employees that he or she believes have knowledge of the facts of the service and care provided.

At a minimum, it is a good idea to identify the staff members who provided care to the resident during at least the two weeks before the occurrence and, if the resident was transferred out of the facility, the 48 hours after the occurrence or, if the resident remained in the facility, the two weeks after the occurrence.

b.         Interviewing Former Employees

Once the key employees are identified, they should be interviewed. This includes interviewing the key former employees. Plaintiffs' attorneys in long-term care cases are notorious for locating former employees and securing their statements. It is crucial to the defense to meet with and gain the cooperation of all former employees before the plaintiff's counsel has an opportunity to meet with them.

Prior to interviewing former employees (and/or current employees), defense counsel should review their personnel files, their notations in the medical chart, and all documents that they prepared that relate to the resident. Defense counsel should be familiar with the employees' employment history and identify any and all training that they received.

Even more so than in most legal cases, former employees in the long-term care setting are usually very reluctant to get involved in legal matters. Defense counsel should be very positive and nonthreatening when contacting former employees. Since many former employees may have left in unfavorable circumstances, it is important for defense counsel to be aware of their reasons for leaving employment with the facility before contacting them.

Defense counsel should explain to former employees that because they provided care to the resident, they will most likely be subpoenaed for a deposition and/or trial testimony by plaintiff's counsel, over whom defense counsel has no control. Former employees should be made to understand that by cooperating with defense counsel, defense counsel may be able to assist in scheduling the deposition and/or trial testimony. In some circumstances, it may be appropriate to compensate former employees for lost time from work while participating in the litigation and/or trial expenses to meet with defense counsel.

B.        Discovery Tools

It is important that defense counsel utilize the available discovery techniques as early as possible in the case. Usually, the general provisions applicable to civil actions govern. In actions filed in court, defense counsel should serve interrogatories, Rule 214 requests to produce, any requests to admit, and a notice for plaintiff's deposition no later than the date the responsive pleadings are filed. The purpose of initiating discovery at the earliest practicable moment is to confine the plaintiff to his or her version of the facts as early as possible and before it can be tailored to the testimony of another witness or the undue influence of counsel and before the plaintiff's counsel has had a chance to review the documents produced by the nursing home. The discovery process should be focused on obtaining information from the plaintiff and the witness that can be used by defense counsel to support a motion for summary judgment or other dispositive motion.

1.         Document Requests

Before taking the plaintiff's deposition, defense counsel should, at a minimum, have all of the documents he or she believes are pertinent to the claim. These documents will be used as a basis for deposition questions, will become exhibits at the deposition, and may also become exhibits at trial. Federal and state discovery rules pertaining to civil actions also allow for the production of things as well as documents, and document requests should include requests for all electronic storage of data including discs, tapes, and printouts of any information contained in the computer memory. The document request should be specifically tailored to the allegations contained in the paragraphs of the complaint and should include all documents relating to all communication between the plaintiff and the nursing home, all documents relating to the communications between the plaintiff and any other individual relating to the care and services provided by the nursing home, prior employment records when appropriate, medical records, all income tax records, pay stubs, payroll records, medical bills, and/or any records that may relate to the plaintiff's claim for damages.

2.         Interrogatories

Interrogatories are written questions to be answered in writing by the plaintiff. They are to be signed by the plaintiff, and the signature is to be notarized. The answers to interrogatories may constitute admissions and can be admitted as evidence at trial. In addition to seeking basic personal and background information, interrogatories should require the plaintiff to identify any and all individuals that he or she believes are witnesses to the case and to indicate any opinion witnesses he or she expects to call to testify at trial. The plaintiff should also be asked to detail the claim of damages.

3.         Requests To Admit

Requests to admit are statements of fact to be submitted to the plaintiff that the plaintiff is required to admit or deny. Requests to admit are permitted in civil actions under Illinois discovery rules. This discovery tool can be very effective in narrowing the issues and pinning down the plaintiff's story.

4.         Notice for Deposition

The notice for deposition of the plaintiff should be served as early as possible since the courts often rule that the party first served the notice for deposition must give its deposition first. It can be a substantial advantage to the defense to have the plaintiff deposed beforehand. This prevents the plaintiff from tailoring his or her testimony consistent with other depositions already given in the case.

C.        Scope of Defendant's Discovery

Regardless of the discovery tool utilized, defendant's discovery should elicit, at a minimum, a thorough background of the plaintiff's medical history, the plaintiff's version of the occurrence, the plaintiff's basis for the belief that improper care was provided, the plaintiff's own calculation of damages, and the identification of any and all pertinent witnesses and documents.

D.        Other Discovery-Related Issues

1.         Informal Discovery

The attorney for the employer is entitled to access to all of the documents and tangible items controlled by the long-term care facility without the necessity of discovery tools authorized by the court rules.

2.         Statements

An attorney may also speak directly to and take a statement from any witness, such as an employee, not otherwise represented by counsel without prior notice. Care should be taken in taking such statements, however, since they will not be privileged and will in all likelihood ultimately be requested by the plaintiff in a document request.

E.         Checklist of Information To Be Obtained in Written and Oral Discovery

The following information should normally be obtained by defense counsel through oral and written discovery:

I.          Resident's preadmission medical condition

A.        Was resident able to successfully manage the ADLs?

B.         Did resident have a driver's license?

C.        Did resident live independently?

D.        Did resident use assistive devices?

E.         What was resident's physical condition? (Obtain complete medical history.)

F.         Did family members provide assistance prior to admission? (If so, identify.)

G.        Did resident live with any family members prior to admission to the facility?

H.        Did resident suffer a fall prior to admission?

I.          Did resident have a skin breakdown?

II.         Decision to admit resident for long-term care

A.        How was the decision made to admit resident for long-term care? Was it on the advice of

            l.          family?

                        2.         Physician?

                        3.         Clergy?

            B.         Was resident involved in the decision?

C.        Did resident understand at the time of the admission that he or she would not return to independent living?

            D.        How was the facility chosen?

1.         Who recommended it (hospital, social service worker, friends, medical providers, or others)?

                        2.         What other facilities were considered?

3.         Were any visits made? If a visit was made to the facility prior to admission, obtain details:

a.         Were representations made?

b.         What inquires were made?

c.         Was a facility tour provided?

d.         What were the impressions?

4.         Were any written materials provided by the facility, e.g., a brochure, advertisements, etc.?

5.         What were the factors that were considered in choosing the facility?

6.         Were/are any relatives or friends of the resident also facility residents?

            E.         What was the admission process to the facility?

1.         Was a contract executed?

2.         Was the acknowledgment of receipt of the resident's bill of rights executed?

3.         Were any DNR provisions discovered and executed?

4.         Did resident choose the attending physician?

5.         What information about resident's prior medical condition was provided by resident to the facility at the time of admission?

III.       Resident's nursing home experience

A.        Did resident's family members visit the facility?

B.         Did family members attend the care plan meetings and/or resident council meetings?

C.        Did family members speak with the attending physician(s)?

1.         Why?

2.         What was the response?

            D.        How was the care funded?

1.         Private pay?

2.         Insurance?

3.         Medicare/Medicaid?

            E.         Did resident make any complaints while at the facility?

                        1.         To whom?

                        2.         When?

                        3.         About what?

                        4.         How were they handled?

            F.         Did any family members or friends make complaints?

                        1.         To whom?

                        2.         When?

                        3.         About what?

                        4.         Were they oral/written?

                        5.         What was the response?

G.        What written materials or documents relate to the care and services provided to resident at the facility? (Identify and obtain.)

H.        Did resident/family members make any attempts to remove resident from the facility? If not, why not?

I.          Did resident/family members make any complaints to police, state/federal agencies, or others regarding the care and services provided?

J.          Did resident know that the attending physician was responsible for the overall medical care?

K.        Did resident understand that he or she would not receive one-on-one care at the facility?

VI.       EXPERT TESTIMONY

As in medical malpractice cases, expert testimony is needed in long-term care cases to establish that the facility met the standard of care. Defense counsel should retain experts who have experience both in geriatric care and in long-term care and who have a good working knowledge of the applicable regulations. Defense counsel should consider using the facility's medical director and administrator to provide the defense theories.

There are benefits of retaining an expert at the outset of the case. These benefits include being able to utilize the expert to identify the strengths and weaknesses of the plaintiff's and defense cases, to assist in developing a defense strategy, to assist in formulating the strategy for the plaintiff's expert deposition, and in some cases to assist in assessing the settlement value of the case.

 

 

A.        Explaining the Difference Between Hospital Care and Long-Term Care

Most jurors have a misconception regarding the type of care that is provided at a long-term care facility. The jurors' expectations in large part are because most jurors have never been a resident in a long-term care facility and their only interaction with a long-term care setting is as a visitor. It is crucial for defense counsel to demonstrate and explain to the jury that the long-term care facility provides a different level of care than a hospital. The long-term care expert needs to explain the care and services that were provided to the resident and how the type of care was appropriate for that particular resident. Next, the expert should explain the type of care that was ordered by the resident's attending physician and establish that the facility staff followed the plan of care ordered by the physician. It is important to use the defense expert to explain that the facility staff must have an order from the attending physician who is in charge of the resident's care for any care that is provided.

B.        Explaining the Difference Between Physician Care and Nursing Care

Another major misconception that juries have regarding the long-term care setting regards the type of care that is provided by the nursing staff. Defense counsel should retain an expert to explain professional nursing and what it entails. The Nursing and Advanced Practice Nursing Act (Nursing Act), 225 ILCS 65/5-1, et seq., outlines the scope of professional and practical nursing care under two categories: registered nurse (RN) and licensed practical nurse (LPN). The Nursing Act provides that "registered professional nursing practice" includes

(1) the assessment of healthcare needs, nursing diagnosis, planning, implementation, and nursing evaluation; (2) the promotion, maintenance, and restoration of health; (3) counseling, patient education, health education, and patient advocacy; (4) the administration of medications and treatments as prescribed by a physician licensed to practice medicine in all its branches, a licensed dentist, a licensed podiatrist, or a licensed optometrist or as prescribed by a physician assistant...or by an advanced practice nurse...; (5) the coordination and management of the nursing plan of care; (6) the delegation to and supervision of individuals who assist the registered professional nurse implementing the plan of care; and (7) teaching and supervision of nursing students.

The Nursing Act does not license a nurse or provide the nurse with the authority to perform a medical diagnosis or prescribe medication. The defense expert should be able to explain the difference between a "nursing diagnosis" and a "medical diagnosis." The expert should establish the fact that diagnosis and prescription of medication are acts of the practice of medicine and are prohibited from being preformed by an LPN or RN pursuant to the Medical Practice Act of 1987, 225 ILCS 60/1, et seq.

C.        Explaining Long-Term Care Facility Charting Practices

Another common misconception regarding long-term care involves charting practices. The charting practices in a long-term care facility are much more relaxed than the charting practices in a hospital setting. The long-term care medical chart, particularly when compared to a hospital chart, is very sparse. In a long-term care setting, charting is required only when there is a change in condition or every 30 or 60 days depending on the type of care that the resident receives. At first glance, a nursing home chart will appear to have gaps in charting. The notes are usually sporadic.

The defense expert can be utilized to explain that intermittent charting is not below the standard of care. Defense counsel and the defense expert will want to focus on the charting during the time frame of the occurrence. A successful defense will depend in large part on appropriate charting during the time frame of the alleged occurrence, charting that shows any changes of condition, and charting of physicians' orders.

D.        Explaining the Life Care Plan

An expert should be retained to explain that the care identified by the plaintiff's expert is related to the natural sequence of the resident's preexisting condition and not due to the alleged negligence. Further, the defense expert should obtain the basis for plaintiff's expert's allegations as to the cost of future care and the need for medical devices.

VII.     CASE EVALUATION AND SETTLEMENT ISSUES

A.        Evaluation in General

Once a lawsuit has been filed and the initial investigation has begun, an evaluation should be made as to whether the case is appropriate for settlement or whether further investigation should be conducted. This evaluation involves a consideration of the strength of the case and the potential damages that may be awarded to the plaintiff. This preliminary evaluation should also include a decision whether to use some form of alternative dispute resolution short of trial, such as mediation. Mediation can be a valuable tool in cases in which there seems to be a high likelihood of an adverse verdict or a likelihood that the jury will award punitive damages. Although each case must be evaluated separately, there are certain types of recoverable damages common in each case, which include recovery pursuant to the survival statute, 755 ILCS 5/27-6, and the wrongful death act, 740 ILCS 180/0.01, et seq. Actions filed pursuant to the survival statute are permitted under the NHCA. However, wrongful death actions cannot be filed pursuant to the NHCA. Wills v. DeKalb Area Retirement Center, 175 Ill.App.3d 833, 530 N.E.2d 1066, 125 Ill.Dec. 657 (2d Dist. 1988).

B.        Jury Sympathy

Pursuant to the survival statute, the plaintiff can recover for pain and suffering and medical expenses. Pursuant to the Wrongful Death Act, the plaintiff may recover damages for money, goods, and services as well as loss of society and companionship. Even though the removal of the treble damages provision from 210 ILCS 45/3-603 on its face appears to remove the incentive for litigation, there is still the incentive to take a case due to potential recovery of attorneys' fees and costs. It should be noted that even without the potential to recover treble damages, juries across the country are increasingly awarding large six-figure verdicts and punitive damages. With the aging population increasing, juries are increasingly willing to recognize that there is value to an elderly person's life and are ignoring the elderly person's limited life expectancy and earning capacity. Therefore, it may be insignificant that treble damages are no longer available.

Due to advanced age and poor physical condition, residents usually have large medical bills. This is significant and should be considered by defense counsel because juries will return verdicts that represent the full value of the medical expenses and bills.

C.        Settlement and Release

If the decision is made to settle a case, defense counsel should obtain a release memorializing the settlement agreement. The release should contain the entire agreement between the parties and should include a number of recitals setting forth the parties' intentions and perhaps a brief statement of the dispute. The release should also include (1) the amount paid in settlement; (2) a waiver or release in the convent not to sue, which the facility should strive to have made as broad as possible; (3) a confidentiality agreement, if appropriate; (4) a clause that states that neither party admits any wrongdoing or liability and that no laws have been violated; and (5) a statement that the settlement agreement is the entire agreement between the parties

D.        Liens

1.         IDPA Liens

An award of actual damages is protected and cannot be recovered by the IDPA. See In re Estate of Castro, 289 Ill.App.3d 1071, 683 N.E.2d 1255, 225 Ill.Dec. 592 (2d Dist. 1997). See also 210 ILCS 45/3-605 (“The amount of damages recovered by a resident in an action brought under Sections 3-601 through 3-607 shall be exempt for purposes of determining initial or continuing eligibility for medical assistance under ‘The Illinois Public Aid Code’ . . . and shall neither be taken into consideration, nor be required to be applied toward the payment or partial payment of the-cost of medical care or services available under the ‘The Illinois Public Aid Code’.”).

This exemption also applies to the recovery received by the decedent's estate. The Illinois courts have held that a settlement for injuries suffered by a decedent while a nursing home resident, which could have been brought as a suit against the nursing home under the NHCA, was exempt from a claim by the IDPA for medical benefits paid. In re Estate of Castro, supra. It should be noted that this section of the NHCA that exempts any recovery for injuries suffered by a nursing home resident from an IDPA claim for cost of care does not preclude the Department from asserting a claim against the nursing home resident's estate when there are other assets in the estate aside from the settlement proceeds from which a claim could be satisfied. Id. See also 305 ILCS 5/5-13.

In order to protect the entire settlement amount from recovery by the IDPA, the parties may want to settle the case pursuant to the NHCA and dismiss all other counts.

2.         Medicare Super Liens

Pursuant to federal law, Medicare has a lien over any personal injury settlements and judgments for medical payments made to a Medicare recipient. The Medicare lien is often referred to as the "super lien" because it does not require any type of lien notification or written documentation to any party in the suit, the insurance company, or their attorneys. The significant provisions are found in 42 C.F.R. §411.24(1), which states:

In the case of liability insurance settlements and disputed claims under employer group health plans and no-fault insurance, the following rule applies: If Medicare is not reimbursed as required by paragraph (h) of this section, the third party payer must reimburse Medicare even though it has already reimbursed the beneficiary or other party.

A lengthy discussion of this topic is beyond the scope of this chapter. Defense counsel should see the regulation for an overview. It should also be noted that many residents receive Medicare benefits pursuant to their social security number. In order to make sure all liens have been satisfied, both spouses' social security numbers should be evaluated for liens.

E.         Attorneys' Fees and Costs

According to the courts, the requirement that the nursing home licensee pay a prevailing plaintiff's attorneys' fees is mandatory in a suit for violations of the NHCA. Berlak v. Villa Scalabrini Home for the Aged, Inc., 284 Ill.App.3d 231, 671 N.E.2d 768, 219 Ill.Dec. 601 (lst Dist. 1996).

The Berlak court acknowledged that one of the purposes of the NHCA was to encourage lawyers to represent residents who may have been abused or neglected but do not present the potential for significant damages. Therefore, the fees do not need to be proportional to the verdict. The court's rationale for this position is that awarding attorneys' fees in direct proportion to the damages would discourage private enforcement of the NHCA and defeat that purpose. Id.

The Berlak court provides a detailed discussion of how an award of attorneys' fees will be determined pursuant to the NHCA. The Berlak court holds that the attorney's contract is relevant but not dispositive on how attorneys' fees will be awarded. Id. The court held that in determining what fees to assess it will look at and evaluate the following factors:

1.         the skill and training of the attorney;

2.         the nature of the case and the issues alleged;

3          the degree of responsibility required;

4.         the usual and customary fee for comparable services;

5.         the result or the benefit to the client; and

6.         the connection between the fees and the amount of money involved in the litigation. Id.

 

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