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Accreditation surveys frequently reveal gaps in informed consent procedures and complaint/grievance processes. Such deficiencies can result in citations and threaten the facility’s accredited status. Therefore, proactive assessments, staff training, and ongoing compliance efforts are essential.

Informed Consent and Complaint Resolution for Community Behavioral Health and Human Services Surveys

The following table outlines common areas of deficiency and action steps to ensure compliance.

Common Deficiencies, Explanations, and Responses

Area JC Standard/EP Common Deficiencies Explanation Response
Informed Consent RI.01.03.01 The organization obtains informed consent.
  • Incomplete or missing consent forms
  • Use of white-out or alterations on consent forms
  • Lack of consent documentation for psychotropic medications
  • Inconsistent adherence to policies
  • Providers documenting consent in progress notes instead of the consent forms
  • Lack of consent for telehealth services
  • Lack of patient involvement in care planning
These issues demonstrate a failure to adequately inform patients of their treatment options and obtain proper consent, potentially violating patient rights and accreditation standards. This can stem from inadequate policies, lack of staff training, or insufficient monitoring of consent practices.
  • Conduct comprehensive documentation audits
  • Review and revise consent policies
  • Provide targeted training to prescribers and staff
  • Monitor medication records for consent documentation
  • Implement standardized consent process for telehealth
  • Ensure that patient is involved in treatment planning
Complaint and Grievance Process RI.01.07.01 The organization addresses complaints and grievances.
  • Misidentified complaints vs. grievances
  • Missing timeframes for resolution
  • Lack of clear tracking and documentation
  • Absence of aggregate analysis for improvement
These issues highlight a breakdown in the process of addressing patient concerns and using feedback to improve services. It can result from unclear policies, inadequate resources, or a culture that discourages open communication.
  • Redefine the definition of a complaint vs. a grievance
  • Establish and enforce resolution timeframes
  • Design or improve tracking logs
  • Analyze grievance trends and integrate into quality improvement efforts
  • Train staff on proper escalation protocols
  • Ensure that staff or the individual who reports a grievance is protected from retaliation

Informed Consent and Complaint Resolution Key Takeaways

  • Differentiate between a Complaint vs a Grievance and clarify the actions to take for each.  A complaint can be informal or a formal concern about specific services or interactions, needing prompt investigation and response. A grievance is a formal expression of dissatisfaction, often about policies or quality of care, requiring a documented resolution process.
  • Joint Commission expects fully implemented, standardized, and monitored processes for informed consent and complaint resolution.
  • Gaps in documentation, inconsistent provider practices, and weak policy alignment are red flags during deemed status surveys.
  • Behavioral Health organizations must not only correct individual findings but embed preventive strategies into operations, policy, and provider accountability systems.
  • The SAFER Matrix is your compass—use it to navigate risk and compliance prioritization.

Is Your Agency Ready?

Now is the time to assess your consent and grievance processes, train your teams, and safeguard your compliance. Let the Barrins & Associates team of accreditation and regulatory experts help your organization prepare, respond, and excel. Through expert-led mock surveys, policy reviews, and targeted education, our consultants specialize in behavioral health and deliver tailored solutions that align with accreditation standards, regulatory requirements, and leading practices. Contact us today to strengthen your compliance strategy and survey readiness.

Barrins & Associates: “Simplify, Deliver, and Thrive: Your Path to Compliance and Safe Care”