A 2013 study on the ESRD beneficiary grievance process, The ESRD Beneficiary Grievance Process (OEI-01-11-00550) conducted by the U.S. Health and Human Services, identified deficiencies at facilities across the country.  Because of this study, the following five  recommendations for improvement were made to CMS: 1) define “grievance” for facilities, 2) require that facilities report grievances regularly to their respective networks, 3) provide guidance to facilities on what constitutes a robust process for anonymous grievances, 4) work with the Agency for Healthcare Research and Quality to add a question to the standardized satisfaction survey to assess ESRD beneficiaries’ fear of reprisal, and 5) provide networks with better technical support for their grievance database. Of these recommendations CMS is working to address barriers related to the definition of a grievance, what constitutes a robust process for anonymous grievances, and proving better technical support for the grievance database. It is important for patients to be able to file a grievance without fear of reprisal.  In order to reduce the fear of reprisal, all facilities must develop an anonymous internal grievance process that allows patients, family members, or caregivers to voice their concerns. According to CMS guidelines, in an anonymous grievance, the identity of the person(s) will remain unknown to the facility. Patients should be educated that the facility is unable to contact an anonymous grievant to inform them of the steps taken to investigate the grievance or the outcome of the investigation. In these cases, the grievant should be advised of the following:

• The grievance will be investigated, but the facility will be unable to report back to them, unless a name and address is provided.
• Because of the small population in dialysis facilities, the provider involved may be able to identify the grievant, even when anonymity is maintained.
• The investigation may be limited due to minimal amount of information available to the facility.