It's time to tighten up your restraint definitions and assessments. A new Centers for Medicare & Medicaid Services' survey and certification memo clarifies the meaning of phrases in the regulations governing use of restraints, including "remove easily" and "freedom of movement." CMS defines "physical restraints" as "any manual method or physical or mechanical device, material, or equipment attached or adjacent to the resident's body that the individual cannot remove easily, which restricts freedom of movement or normal access to one's body." The clarification indicates that "freedom of movement" means any change in place or position for the body or any part of the body that the person is physically able to control. "Remove easily" means that the resident can intentionally remove the manual method, device, material, or equipment in the same manner as staff applied it. For example, the resident puts the siderails down rather than climbing over them or intentionally unties knots. Consider the resident's physical condition and ability to accomplish an objective, such as transferring out of a chair to get to the bathroom in time. The memo cautions that "although the requirements describe narrow instances" where facilities may use physician restraints, "growing evidence" supports that they have a "limited role in medical care." No fallback: "Physical restraints certainly do not eliminate falls," states the memo. "In fact in some instances reducing the use of physical restraints may actually decrease the risk of falling." "The memo does capture the fact that there may be an emergency situation where the resident is at risk for self-injury or in danger of hurting others, and where the facility may have to use a restraint briefly or intermittently," says Evvie Munley, senior health policy analyst for the American Association of Homes & Services for the Aging. Facilities should, however, always do a careful assessment and care planning "regarding the use of any type of restraint," she advises.