DEPOSITION PREP PACKET (LTC)
Targeted, clinically grounded deposition questions for nursing home staff, administrators, and interdisciplinary team members involved in long‑term care.
This deposition prep packet provides structured question sets designed to uncover deviations from standards of care, expose facility‑level failures, and clarify the responsibilities of each staff member involved in a resident’s care.
Use these questions to prepare for depositions of CNAs, nurses, administrators, DONs, MDS coordinators, and other key personnel in long‑term care litigation.
CNA DEPOSITION QUESTIONS
Role & Responsibilities
• Describe your daily responsibilities for resident care.
• How many residents were assigned to you during the relevant shifts?
• What training did you receive regarding fall prevention, skin care, and change‑in‑condition recognition?
Monitoring & Documentation
• How often were you required to check on residents?
• How did you document care provided?
• Were there times when you were unable to complete required tasks due to staffing levels?
Incident‑Specific Questions
• What did you observe about the resident’s condition before the incident?
• Did you report any concerns to the nurse?
• Were any interventions missed or delayed?
NURSE DEPOSITION QUESTIONS
Assessment & Monitoring
• What assessments were performed on admission?
• How often was the resident monitored for changes in condition?
• What were the resident’s identified risks?
Interventions & Response
• Describe the interventions in place for fall prevention, skin integrity, hydration, or other risks.
• When did you first notice a change in condition?
• What actions did you take, and when?
Notifications
• When was the physician notified?
• When was the family notified?
• Were there any delays in communication?
DIRECTOR OF NURSING (DON) QUESTIONS
Staffing & Oversight
• What were the staffing levels during the relevant period?
• Were there any staffing shortages or call‑outs?
• How do you ensure staff compliance with care plans?
Policies & Procedures
• What facility policies applied to this resident’s care?
• Were those policies followed?
• How is staff trained on recognizing and responding to changes in condition?
Quality Assurance
• Were there any prior incidents involving this resident?
• Were any corrective actions implemented?
• How does the facility track and address systemic issues?
ADMINISTRATOR QUESTIONS
Facility Operations
• What is your role in overseeing clinical operations?
• How do you ensure regulatory compliance?
• What systems are in place to monitor quality of care?
Incident Review
• Were you aware of this incident?
• What steps were taken after the event?
• Were any staff disciplined or retrained
MDS COORDINATOR QUESTIONS
Assessment Accuracy
• How were the resident’s risks captured in the MDS?
• Were assessments updated after changes in condition?
• Were care plans revised accordingly?
Interdisciplinary Communication
• How do you communicate assessment findings to nursing staff?
• Were there discrepancies between MDS data and nursing documentation?
THEMES TO ESTABLISH BREACH
Use these question sets to uncover:
• Missed or delayed assessments
• Failure to monitor
• Failure to respond to changes in condition
• Inadequate staffing
• Poor communication
• Inaccurate or incomplete documentation
• Failure to follow facility policies
• Failure to follow federal/state regulations
These themes help build a clear breach narrative.