New London Sub-Acute: No Ethics Program Found - CT
No program. No policy. No training. The facility had operated without any of it.
The admission came quickly. The administrator, Regional Registered Nurse #4, and Regional Registered Nurse #8 confirmed during a 9:46 a.m. interview that the facility had no compliance and ethics program and no compliance and ethics policy. When inspectors asked for the policy in writing, nothing was produced.
What the facility did have was a Code of Conduct. RN #4 and RN #8 pointed to it. But inspectors found the Code of Conduct was not communicated to the entire staff, and when they examined it closely, they found it was missing the basic architecture that makes such a document functional. There was no identified compliance officer. No compliance committee. No mechanism for staff to report ethical concerns. No guarantee that concerns could be reported securely or confidentially. No process for internal monitoring or auditing. No defined response when a violation was detected. No risk assessment.
A Code of Conduct that doesn't tell anyone who to call, or what happens after they call, is not a compliance program. It is a piece of paper.
The Director of Nursing was unavailable for the interview.
Compliance and ethics programs exist for a specific reason: they create a structure inside a facility that allows problems to surface before they become serious harm. A nurse who witnesses medication being diverted needs to know who to tell and that they won't face retaliation for telling. An aide who sees a colleague mistreat a resident needs a clear path to report it. Without a designated compliance officer, without a confidential reporting channel, without any training that tells staff these systems exist, that path disappears.
At New London Sub-Acute, new employees were never introduced to compliance and ethics concepts during orientation. Staff who had worked there for years had never received annual training on the subject. RN #4 and RN #8 confirmed both facts directly.
The inspection rated the violation at the level of minimal harm or potential for actual harm, and noted that some residents were affected. That framing reflects where the deficiency sits on the regulatory scale, not a ceiling on what the absence of such a program can produce over time. Compliance failures tend not to announce themselves. They accumulate quietly, in the space between what staff witness and what gets reported, between what gets reported and what gets investigated, between what gets investigated and what gets fixed.
New London Sub-Acute is a 90 Clark Lane facility in a residential part of Waterford. The inspection was conducted by the Connecticut Department of Public Health on behalf of the Centers for Medicare and Medicaid Services.
What the March 27 visit documented was not a program that had broken down or a policy that had gone stale. It was the complete absence of a structure that should have been in place. Staff had no training on ethics. The facility had no officer to receive concerns. There was no auditing, no monitoring, no defined corrective process. The Code of Conduct that existed had not reached the full staff and lacked every element that would make it operational.
The administrator confirmed all of this. So did the two regional nurses. The Director of Nursing, the person most directly responsible for the clinical workforce at the center of any compliance concern, was not available to answer questions at all.
Inspectors left with no policy document in hand, because none existed to hand over.
Full Inspection Report
The details above represent a summary of key findings. View the complete inspection report for New London Sub-acute and Nursing from 2025-03-27 including all violations, facility responses, and corrective action plans.
Additional Resources
Data source: This article is based on inspection data downloaded directly from the Centers for Medicare & Medicaid Services (CMS) via Medicare.gov. CMS releases inspection reports in bulk; we publish the findings as documented by state surveyors in the official Form CMS-2567 Statement of Deficiencies.
Plan of correction: The CMS report we receive does not include the facility's plan of correction. Facilities submit plans of correction separately to state survey agencies and those responses may not be reflected in CMS data at the time of publication. The absence of a plan of correction in our data does not mean one was not filed. Readers who want information about corrective steps taken are encouraged to contact the facility directly or their state survey agency.
Corrections may have occurred: Inspection reports reflect conditions observed on the date of the survey. Facilities may have implemented corrections, staffing changes, additional training, or other remediation since the report was issued. We report what CMS provides and encourage readers to seek current information from the facility.
Editorial process: Inspection findings are extracted from CMS source documents and synthesized using AI, reviewed for factual accuracy against the original report by our editorial team.
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Last verified: November 3, 2026 · Our methodology
NEW LONDON SUB-ACUTE AND NURSING in WATERFORD, CT was cited for violations during a health inspection on March 27, 2025.
The facility had operated without any of it.
Health inspections identify deficiencies that facilities must correct. Violations range from minor documentation issues to serious safety concerns. Review the full report below for specific details and facility response.