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The physical restraints quality measure: what P0100 counts

Only five P0100 items, coded as used daily, count toward N027.02. Which ones, how to judge a device by its effect, and the October 2026 locked-unit line.

September 29, 2026 · 4 min read · SuperLTC

The physical restraints measure counts long-stay residents who are restrained every day. It reads only five of the eight P0100 items, and only when they’re coded as used daily. Knowing which five, and what makes a device a restraint in the first place, is most of the work.

Where the measure is used

  • CMS ID N027.02, a long-stay MDS measure (101 or more cumulative days in the building).
  • Care Compare: yes. Five-Star: no.
  • Florida’s QIP scores it as one of its MDS measures. See Florida QIP, explained.

What puts a resident in the numerator

“This measure reports the percent of long-stay nursing facility residents who are physically restrained on a daily basis.”
MDS 3.0 QM User’s Manual v18.0, Chapter 2, Table 2-23, page 35

On the target assessment, any one of these coded 2 (used daily):

ItemRestraintCounted by N027?
P0100ABed rail, used in bedNo
P0100BTrunk restraint, used in bedYes
P0100CLimb restraint, used in bedYes
P0100DOther, used in bedNo
P0100ETrunk restraint, used in chair or out of bedYes
P0100FLimb restraint, used in chair or out of bedYes
P0100GChair that prevents risingYes
P0100HOther, used in chair or out of bedNo

Code 1 (used less than daily) doesn’t count toward the measure. Bed rails and the two “other” items don’t count either, even at code 2. They still have to be coded when they meet the definition of a restraint. The measure just doesn’t read them.

The only exclusion is a resident who isn’t in the numerator and has one of the five counted items dashed. There is no risk adjustment.

When it counts, and when it clears

P0100 has a 7-day look-back, and the measure reads only the target assessment: the resident’s latest qualifying assessment, dated no more than 120 days before the episode ends or the quarter closes. Once a restraint is gone, or used less than daily, for the whole 7-day look-back of the next target assessment, the resident is out.

A worked example. Resident E sits in a geriatric chair every afternoon. Resident E can’t get up from it, but transfers from other chairs without help. For Resident E, the geri chair is a chair that prevents rising, used daily: P0100G is 2, and Resident E is in the numerator. For a resident who can’t transfer on their own from any chair, the same geri chair isn’t a restraint.

Decide by the effect, not the reason

The RAI Manual’s test is whether the resident can remove the device easily and whether it restricts their freedom of movement or access to their own body. The reason it was put there doesn’t enter into it.

“In classifying any manual method or physical or mechanical device, material or equipment as a physical restraint, the assessor must consider the effect it has on the resident, not the purpose or intent of its use.”
RAI Manual v1.20.11, Chapter 3, Section P, page P-5

The geri chair rule shows how that plays out:

“For residents who have no ability to transfer independently, the geriatric chair does not meet the definition of a restraint and should not be coded at P0100G–Chair Prevents Rising.”
RAI Manual v1.20.11, Chapter 3, Section P, page P-7

New in the October 2026 RAI Manual

Version 1.20.11, effective October 1, 2026, adds a line on secured units to the P0100 coding tips:

“When coding this section, do not consider as a restraint a locked/secured unit or building in which the resident has the freedom to move about the locked/secured unit or building.”
RAI Manual v1.20.11, Chapter 3, Section P, page P-5

Common coding mistakes

  • Coding the device instead of the effect. A lap tray the resident can remove isn’t a restraint. One they can’t remove may be.
  • Misjudging enclosed-frame walkers. They aren’t automatically a restraint. They are one only when the resident can’t get out by opening the gate, bar, strap, latch or tray, and then they go in P0100G.
  • Coding medical equipment. Catheters, drainage tubes, casts, traction, braces, abdominal binders and bandages doing their usual job are excluded from Section P.
  • Treating the order as the justification. A restraint needs physician documentation of the medical symptom it treats, an order with parameters, and a care plan for gradual reduction. The RAI Manual is plain that the order alone isn’t enough, and that falls are not a medical symptom supporting a restraint.

See your building’s physical restraints rate against the nation, free.

SuperQM flags any resident with a counted P0100 item coded daily, so the team can review the device and the chart before the next assessment.

See where your building stands.

Your stars, your measures and your state program. Free, from public data.

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