Citations in Ohio
Comprehensive analysis of citations, statistics, and compliance trends for long-term care facilities in Ohio.
Statistics for Ohio (Last 12 Months)
Financial Impact (Last 12 Months)
Latest Citations in Ohio
A resident with intact cognition receiving Medicare Part A skilled services for metabolic encephalopathy had services discontinued while benefit days remained, but the facility did not issue the required Skilled Nursing Facility Advance Beneficiary Notice (SNF ABN). The Social Services Director later confirmed that no SNF ABN was provided and reported she believed only a Notice of Medicare Non-Coverage (NOMNC) was needed when all skilled services were stopped. This practice conflicted with the facility’s written policy, which required SNF ABNs to be issued when extended care items or services were initiated, reduced, or terminated due to expected non-coverage by Medicare.
Surveyors identified that the facility exceeded the acceptable medication error rate when two residents with type 2 DM received insulin doses that were not administered according to orders or manufacturer instructions. In two separate observations, an LPN administered Novolog and another LPN administered insulin glargine and insulin lispro without priming the insulin pens, and the insulin lispro and Novolog were given after the residents had already consumed a significant portion of their breakfast meals, despite orders for administration before meals. Manufacturer information for both insulin products required priming before each injection to ensure accurate dosing, and facility policy required medications, including insulin, to be administered safely, timely, and in accordance with prescriber orders and specified time frames.
Surveyors found that the facility failed to document tray line food temperatures for multiple meals served from two dining room kitchenettes, despite having a “Trayline Taste & Temperature Log” and a policy requiring food to be stored, prepared, distributed, and served according to professional food safety standards. Review of logs showed repeated missing entries for breakfast, lunch, and dinner services in both the Harrison and McClellan dining areas, and the Senior Director of Culinary Services confirmed that temperatures had not been recorded for those meals, potentially affecting all residents receiving meals from those kitchenettes.
The facility failed to conduct and document required periodic care conferences for two residents, despite multiple comprehensive, quarterly, and significant change MDS assessments and a policy requiring periodic care conferences with resident and/or family participation. One resident with Parkinson’s disease, post-stroke hemiplegia, TIA, DMII, and depression had only two documented care conferences over a year, while another resident with aphasia, cerebrovascular disease, DMII, gait difficulty, coagulation defect, depression, and muscle weakness had no documented care conferences in the past year, aside from a declined invitation to the representative. The UCC confirmed that care conferences were expected to occur quarterly and that no additional documentation existed for either resident.
A resident with Alzheimer's disease and type II DM, who required extensive assistance with ADLs and was receiving scheduled Lantus and sliding-scale Humalog, experienced a severely elevated blood glucose level. The on-call provider was notified and ordered an additional dose of lispro insulin with a directive to recheck the blood glucose after administration. Nursing staff administered the extra insulin but did not document any follow-up blood glucose check, and the DON confirmed that this reevaluation was required by the facility's abnormal blood glucose policy and was not completed or documented.
A resident with Parkinson’s disease, dementia, and hypothyroidism was prescribed levothyroxine once daily along with other medications. A consultant pharmacist’s monthly drug regimen review recommended that levothyroxine be given in the morning on an empty stomach, 30–60 minutes before food, per manufacturer instructions. The medical record contained no documented physician response to this recommendation, and the MAR showed the drug scheduled for morning administration while the resident was observed eating breakfast and receiving the medication at the same time. An LPN confirmed administering levothyroxine during the meal, and the DON verified there was no documentation explaining whether or why the pharmacist’s recommendation was or was not followed, resulting in a failure to act on and document the identified irregularity.
A resident with severe cognitive impairment, multiple comorbidities, documented gait and balance abnormalities, and a high fall risk was care planned and assessed by therapy to require contact guard assistance and use of a gait belt for transfers and ambulation. While being assisted by a CNA from a recliner to the bathroom with a walker, the CNA did not apply a gait belt, even though the resident had a known tendency to lean backward when standing. As the CNA reached to open the bathroom door, the resident lost balance and fell backward, striking the back of the head, and was later found by an LPN without a gait belt in place, contrary to the facility’s gait belt policy and the resident’s assessed needs.
A resident with metabolic encephalopathy, muscle weakness, and a history of CVA experienced a fall in his room that was not documented in the medical record until the following morning as a late entry. Two RNs acknowledged that the fall was not recorded at the time it occurred and stated that fall incidents should be documented as soon as possible after the event, resulting in a deficiency for failure to maintain timely, professionally standard medical records.
A resident with Alzheimer’s disease, diabetes, anxiety, significant ADL dependence, and behavioral symptoms was observed seated in a chair positioned against the nursing station with a locked wheelchair placed directly in front, also against the nursing station, effectively restricting movement. An LPN confirmed both wheelchair wheels were locked and that it should not have been placed there, while a CNA stated she had positioned the wheelchair to prepare for lunch, was unable to complete the transfer, and left it in place, acknowledging this was wrong. This arrangement conflicted with the facility’s restraint policy, which prohibits physical restraints except when alternatives are ineffective for treating a medical symptom and defines restraints as devices adjacent to the body that cannot be easily removed and that restrict freedom of movement or access to the body.
A resident with cirrhosis, ascites, mood disorder, and alcohol-induced major neurocognitive disorder, and with moderately impaired cognition, was observed sitting on a shower chair in a gown with buttocks exposed and visible from the hallway through an open room door. A CNA left the room quickly after hearing another resident yell and forgot to close the door or pull the privacy curtain, and an RN confirmed the exposure, demonstrating a failure to maintain the resident’s dignity and privacy.
Failure to Issue Required SNF ABN When Discontinuing Medicare Part A Services
Penalty
Summary
The deficiency involves the facility’s failure to issue a Skilled Nursing Facility Advance Beneficiary Notice (SNF ABN) when Medicare Part A services were discontinued for a resident who still had available benefit days. The resident was admitted with a diagnosis of metabolic encephalopathy and had intact cognition per the Minimum Data Set assessment. The facility’s own SNF Beneficiary Notification Review documented that Medicare Part A skilled services began on 02/11/26 and the last covered day was 03/11/26, and that the facility initiated discharge from Medicare Part A services before the resident’s benefit days were exhausted. Despite this, no SNF ABN was provided to the resident or the resident’s representative. During interviews, the Social Services Director stated that the SNF ABN was issued hours prior to the last covered day but, upon reviewing her files, confirmed that no SNF ABN had actually been issued for this resident. She further explained that she believed an SNF ABN was only required if one skilled service remained and that if all skilled services were being discontinued, only the Notice of Medicare Non-Coverage (NOMNC) needed to be issued. The Administrator, however, stated that a resident should always receive both a SNF ABN and a NOMNC when Medicare Part A services are discontinued and benefit days remain. Review of the facility’s written policy dated 03/28/23 showed that the facility was required to issue SNF ABNs for initiation, reduction, or termination of extended care items or services when Medicare payment was not expected, which did not occur in this case.
Plan Of Correction
This Plan of Correction is submitted as required under State and Federal law. This Plan of Correction does not constitute an admission on the part of the Facility that the findings cited are accurate, that the findings constitute a deficiency or that the scope and severity regarding the deficiency cited are correctly applied. Any changes to the Facility's policies and procedures should be inadmissible in any proceeding on that basis. Without admitting or denying the validity or the existence of the alleged noncompliance, the Facility submits this Plan of Correction with the intention that it be inadmissible by any third party in any civil or other action against the facility or any employee, agent, officer, director or shareholder of the Facility. The Facility is utilizing this Plan of Correction as its allegation of substantial compliance as of 05/29/2026 F-0582 Corrective action for resident/s: On 5/14/26 Resident #34 was informed of rights and responsibilities related to Advanced Beneficiary Notice and voiced understanding of information for future reference by administrator. Identification of other residents who may be affected: Any resident receiving skilled services from nursing or therapy services. The Administrator audited all residents who were discharged from skilled services in the past 30 days to ensure they were issued a Notice of Non-Coverage and Advanced Beneficiary Notice on 5/29/26. No non-compliance was noted. Measures for systemic change: On 5/14/2026 Business Office Manager, Director of Rehab, Minimum Data Set nurse, Director of Nursing and Social Services Director were educated on proper procedure of issuing of Notice Of Medicare Non Coverage and Advanced Beneficiary Notice by administrator. All upcoming discharges from skilled services will be reviewed weekly at Utilization Review meeting to ensure notices will be delivered timely. How Corrective Action will be monitored: Administrator or designee to complete audits of all residents being discharged from skilled services to ensure they were issued a Notice of Non-Coverage and Advanced Beneficiary. This audit will be completed weekly x 4 weeks, then monthly x 2 months. Corrective action will be initiated for any noted non-compliance. Audit findings will be reviewed as part of the monthly quality assurance process to determine the need for further monitoring. Date of Compliance 5/29/26
Insulin Administration Errors and Failure to Prime Insulin Pens
Penalty
Summary
The deficiency involves the facility’s failure to maintain a medication error rate below 5%, with surveyors identifying 3 errors out of 28 medication administration opportunities, resulting in a 10.71% error rate. For one resident with type 2 diabetes mellitus and moderate cognitive impairment, the physician’s order directed Novolog insulin 10 units via subcutaneous pen-injector to be given before meals. During an observed medication pass, the LPN administered 10 units of Novolog insulin without priming the pen and did so after the resident had already consumed approximately 50% of the breakfast meal. The LPN later confirmed she did not prime the pen and acknowledged that the insulin was ordered to be administered prior to meals. Manufacturer instructions for the Novolog FlexPen specified that an air shot (priming) must be performed before each injection to ensure proper dosing. Another resident, also diagnosed with type 2 diabetes mellitus and with intact cognition, had orders for insulin glargine 35 units subcutaneously twice daily and insulin lispro 20 units subcutaneously before meals, plus 12 units subcutaneously if blood glucose was between 251 mg/dL and 300 mg/dL. During an observed medication administration, an LPN administered 35 units of insulin glargine and 32 units of insulin lispro without priming the insulin pens and after the resident had consumed approximately 90% of the breakfast meal, despite orders for insulin lispro to be given before meals. The LPN later stated she could not remember if she had primed the pen and acknowledged that the insulin was ordered to be administered prior to meals. Manufacturer information for insulin lispro stated that the pen must be primed before each injection to confirm insulin delivery and remove air, and that failure to prime could result in too much or too little insulin. The DON confirmed the expectation that insulin be administered as ordered, including priming each pen with two units before dialing the prescribed dose, and facility policy required medications, including insulin, to be administered safely, timely, and in accordance with prescriber orders and required time frames.
Plan Of Correction
This Plan of Correction is submitted as required under State and Federal law. This Plan of Correction does not constitute an admission on the part of the Facility that the findings cited are accurate, that the findings constitute a deficiency or that the scope and severity regarding the deficiency cited are correctly applied. Any changes to the Facility's policies and procedures should be inadmissible in any proceeding on that basis. Without admitting or denying the validity or the existence of the alleged noncompliance, the Facility submits this Plan of Correction with the intention that it be inadmissible by any third party in any civil or other action against the facility or any employee, agent, officer, director or shareholder of the Facility. The Facility is utilizing this Plan of Correction as an allegation of substantial compliance as of 5/29/2026. F-0759 Corrective action for resident/s: Residents #21 and #22 were assessed and evaluated by nurse and Director of Nursing 5/14/26. Resident #21 and #22 both denied any adverse effects and none were noted upon assessment by the Director of Nursing on 5/14/2026. Notification made to physician on 5/14/2026. LPN # 2 competency Eval on insulin administration with the Director of Nursing completed 5/14/2026. Identification of other residents who may be affected: Diabetic residents on assignment of LPN #2/station 2 have the potential to be affected and were assessed by the DON/Designee on 5/14/26 and found to be within normal limits. Measures for systemic change: All Nurses were educated by the Director of Nursing on the steps for Insulin administration per competency, diabetes clinical protocol policy, Medication and treatment orders policy, administering medications policy, and Obtaining fingerstick Glucose Level policy On 5/14/2026. How Corrective Action will be monitored: Director of Nursing and Assistant Director of Nursing will complete insulin administration audits on 5 nurses. This audit will be completed weekly x 4 weeks, then monthly x 2 months. Corrective action will be initiated for any noted non-compliance. Audit findings will be reviewed as part of the monthly quality assurance process to determine the need for further monitoring. Date of Compliance: 5/29/2026
Failure to Document Tray Line Food Temperatures in Dining Room Kitchenettes
Penalty
Summary
The deficiency involves the facility’s failure to document tray line food temperatures for meals served from the Harrison and McClellan Dining Room kitchenettes, as required by professional standards for food service safety and the facility’s own policy. Review of the “Trayline Taste & Temperature Log” (revised September 2018) showed missing temperature documentation for multiple meals from the Harrison Dining Room kitchenette, including dinner on 03/30/26 and 03/31/26, lunch and dinner on 04/01/26 and 04/02/26, dinner on 04/07/26, and lunch and dinner on 04/08/26 and 04/10/26. The Senior Director of Culinary Services confirmed during interview that tray line food temperatures were not documented on the log for these meals. Similarly, review of the same log for the McClellan Dining Room kitchenette revealed that tray line food temperatures were not documented for dinner on 04/01/26, breakfast and lunch on 04/02/26, and lunch and dinner on 04/07/26. The Senior Director of Culinary Services also verified these omissions during interview. The facility census at the time was 27 residents, and the governing “Food and Nutrition” policy, approved on 09/07/21, stated that the facility must store, prepare, distribute, and serve food in accordance with professional standards for food service safety.
Plan Of Correction
F812 The facility will continue to ensure food temperatures are completed before meals are served for all residents. To ensure compliance with this standard the following measures have been taken: 1. Immediately 4/15/26 culinary supervisor #224 was re-educated by Dietary Manager to this standard and policy "Food and Nutrition" which includes documentation of food temperatures. 2. All dietary staff have been re-educated to the standard and policy "Food and Nutrition" during the month of April 2026. 3. Audits of food temperature documentation to be completed by Dietary Manager 4 x per week for 4 weeks then weekly for 4 weeks. 4. Administrator to validate audits/compliance and provide additional training as needed. Administrator will present to QAPI committee for ongoing monitoring and further direction.
Failure to Conduct and Document Required Care Conferences
Penalty
Summary
The deficiency involves the facility’s failure to complete and document comprehensive care conferences at required intervals in accordance with care plan regulations and facility policy. For one resident with Parkinson’s disease with dyskinesia, cognitive communication deficit, hemiplegia and hemiparesis following cerebral infarction, transient cerebral ischemic attack, type II diabetes mellitus, and major depressive disorder, the record showed multiple MDS assessments over a one-year period, including annual, quarterly, and significant change assessments. However, only two care conferences were documented during the last 12 months, despite the expectation that care conferences be conducted quarterly with the resident and family when possible. The Unit Care Coordinator confirmed that no additional care conference documentation existed for this resident beyond the notes dated 04/21/25 and 01/02/26. A second resident, with diagnoses including aphasia following cerebrovascular disease, cerebral infarction, type II diabetes mellitus, unsteadiness on feet, difficulty in walking, coagulation defect, depression, and muscle weakness, also had multiple MDS assessments completed over the review period, including quarterly and annual assessments. The record contained a note that a care conference was offered to the resident’s representative, who declined to attend, but there was no documentation of any care conferences for the most recent 12 months. The Unit Care Coordinator confirmed that no other care conference documentation was available for this resident. Facility policy stated that periodic care conferences involving the resident, family, and the interdisciplinary team are part of the care planning process, but the required periodic care conferences and corresponding documentation were not completed for these two residents.
Plan Of Correction
THIS PLAN OF CORRECTION SERVES AS BERKELEY SQUARE'S CREDIBLE ALLEGATION OF SUBSTANTIAL COMPLIANCE AS OF June 1, 2026. Without admitting or denying the validity or existence of the alleged deficiencies, Berkeley Square provides the following Plan of Correction: F657 The facility will continue to document completion of care conferences at the required intervals for all residents, including residents #04 & #15. To ensure compliance with this standard the following measures have be taken: 1. The social service designee and the inter- disciplinary team were re-educated by the administrator to the facility policy "Care Conference" on 4/29/26 and verbalized understanding. 2. Care conferences for resident #04 and resident #15 were conducted on or before 4/29/2026 by the interdisciplinary team. 3. Review of all other residents was conducted by the social service designee to validate and ensure that care conference schedule is up to date with timely care conferences scheduled for them on 4/15/2026. Audits of care conferences to be completed weekly for four weeks and then monthly after that by the social service designee. Documentation of the care conference including any identified concerns in the medical record. Administrator to validate audits/compliance and provide additional training as needed. Administrator will present results of these audits to QAPI committee for ongoing monitoring and further direction.
Failure to Reevaluate Blood Glucose After Treatment for Hyperglycemia
Penalty
Summary
The facility failed to ensure that a resident with diabetes received treatment in accordance with professional standards of practice when nursing staff did not reevaluate the resident's blood glucose after treatment for severe hyperglycemia. The resident, admitted with diagnoses including Alzheimer's disease, type II diabetes mellitus, and depression, had physician orders for Humalog insulin on a sliding scale before meals, Lantus insulin 25 units daily, and lisinopril 5 mg daily. The resident required extensive assistance with activities of daily living, including transfers, toileting hygiene, eating, and bathing. On the evening in question, the resident's blood glucose was documented as 532 mg/dL, and the on-call provider was notified. The provider gave a new order to administer an additional 8 units of lispro (Humalog) and to recheck the blood glucose in 30 minutes. The electronic medication administration record showed that the blood glucose of 532 mg/dL was obtained at 9:00 p.m. and that the additional 8 units of lispro were administered at 9:21 p.m. However, there was no documentation in the resident's chart that the blood glucose was rechecked after the additional insulin was given. In an interview, the DON confirmed there was no evidence of reevaluation and verified that, according to the facility's "Abnormal Blood Glucose Procedure" policy, the resident should have been reevaluated and that the evaluation step should have been included in the progress note documentation.
Plan Of Correction
F684 The facility will continue to ensure all residents, including #03, receive treatment in accordance with professional standards of practice and reevaluated for hyperglycemia. To ensure compliance with this standard the following measures have been taken: 1. The director of nursing assessed resident #03, reviewed documentation and orders and found no ill effects immediately 4/16/26. 2. All licensed nurses were re-educated to facility policy "Blood Glucose Monitoring" by the Director of Nursing/designee in April 2026. 3. Audits of like-residents that require blood sugar checks to be completed by the director of nursing/designee two times a week for 4 weeks and then monthly after that to validate correct follow through when there is abnormally high blood glucose result. The Administrator will bring results of these audits to the QAPI committee for ongoing monitoring and further direction.
Failure to Act on Pharmacist Drug Regimen Recommendation for Thyroid Medication
Penalty
Summary
The deficiency involves the facility’s failure to ensure that pharmacy recommendations from the monthly drug regimen review were acted upon and documented for a resident. The resident was admitted with diagnoses including Parkinson’s disease, dementia, and hypothyroidism, and had current physician orders for levothyroxine 150 mcg once daily, buspirone 50 mg twice daily, and losartan 100 mg once daily. A medication regimen review dated 11/25/2025 included a consultant pharmacist recommendation that levothyroxine be administered consistently in the morning on an empty stomach, at least 30–60 minutes before food, per manufacturer instructions. There was no specific physician response in the medical record to this recommendation, and the facility’s policy stated that consulting pharmacist reviews are sent to nursing and addressed with the primary care provider or consulting specialist for review and follow-up. Review of the resident’s medication administration record for April 2026 showed levothyroxine scheduled for 9:00 a.m. On observation, the resident was seen eating breakfast in the dining area at 8:03 a.m., and an LPN reported administering the levothyroxine 150 mcg to the resident while the resident was in the dining area eating breakfast. The DON confirmed there was no evidence in the resident’s medical record explaining why the consultant pharmacist’s recommendation from 11/25/2025 was or was not acted upon. This lack of documented physician review and action on the pharmacist’s identified irregularity constituted noncompliance with the drug regimen review requirements.
Plan Of Correction
F756 The facility will continue to ensure the pharmacy recommendations from the monthly drug regimen review by a licensed pharmacist are acted upon for all residents, including #08. To ensure compliance with this standard the following measures have been taken: 1. Resident #08 was assessed by the registered nurse and med review completed by 4/28/26. After review of resident's drug regime's, it was discovered that resident #8 had 2 separate medication recommendations on the same form, to be reviewed by two separate practitioners, pharmacy has been instructed and agreed to separate meds on individual forms. 2. Licensed nurses re-educated to facility policy "Drug Regimen Review" by Director of nursing/designee in April 2026 and no later than 5/8/26. Licensed nurses are responsible for ensuring the reviews and recommendations are given to the physician for timely review. 3. Review of all other current residents Drug Regimen orders completed by Director of nursing/designee on 4/16/26 to ensure recommendations were followed up on/reviewed by the physician and address concerns if needed. 4. Audit of drug regime recommendations, pharmacy recommendations, and physician follow up to be completed weekly for four weeks by the Director of nursing/designee. Administrator will present results of these audits to the QAPI committee for ongoing monitoring and further direction.
Failure to Use Required Gait Belt During Ambulation Resulting in Resident Fall
Penalty
Summary
The deficiency involves the facility’s failure to ensure that a required gait belt was used while assisting a high fall‑risk resident with ambulation, resulting in a fall with head injury. The resident had multiple diagnoses including metabolic encephalopathy, hypertension, osteoarthritis, muscle weakness, gait and mobility abnormalities, major depressive disorder, anxiety, and visual hallucinations. Admission and subsequent MDS and fall risk assessments documented that the resident was severely cognitively impaired, required moderate to maximal assistance with transfers and ambulation, could not independently come to a standing position, exhibited loss of balance while standing, used an assistive device, and had decreased muscle coordination. The resident had a history of falls prior to admission and was assessed as being at high, later moderate, risk for falls. The resident’s fall care plan identified her as at risk for falls and included interventions such as providing maximum to moderate assistance with transfers and walking short distances, use of a walker and wheelchair, and following the facility’s fall protocol. Therapy notes and care conference documentation indicated that the resident leaned backwards when standing, required contact guard to minimal assistance for bed mobility and transfers, and needed constant verbal cueing for safe sequencing during toilet transfers. The physical therapist confirmed that the resident was to use a gait belt with staff when ambulating, and the DON verified that therapy had assessed the resident as requiring contact guard assistance and a gait belt for ambulation and transfers. On the day of the incident, a CNA was assisting the resident from her recliner to the bathroom using a walker. The CNA walked beside the resident, providing guidance and support, and reported having a hand on the resident while assisting her. As they approached the bathroom door, the CNA reached for the doorknob to open it, and at that moment the resident began to lose her balance and fell backwards to the floor, striking the back of her head. The nurse who responded found the resident on her back at the foot of the bed with her feet near the bathroom, noted a red raised area on the back of the head, and documented that the resident was not wearing a gait belt and that the gait belt was on the dresser. In the facility’s investigative summary and in interviews, the CNA acknowledged that she did not have a gait belt on the resident while ambulating her, despite the resident’s assessed need for hands‑on assistance and gait belt use per facility policy and the resident’s care and therapy plans.
Untimely Documentation of Resident Fall Incident in Medical Record
Penalty
Summary
The deficiency involves the facility’s failure to document a resident’s fall incident in the medical record in a timely manner, in accordance with accepted professional standards. The resident was admitted with diagnoses including metabolic encephalopathy, muscle weakness, and cerebrovascular accident. According to the medical record, a progress note was entered as a late entry on 02/20/26 at 8:21 A.M., stating that the resident had suffered a fall in his room on 02/19/26 at 8:00 P.M. There was no evidence of any documentation of the fall incident entered in the medical record at the time of, or shortly after, the fall on 02/19/26 at 8:00 P.M. During an interview on 03/30/26 at 12:05 P.M., two RNs confirmed that the fall incident was not documented until the following morning and stated that fall incidents should be entered in the medical record as soon as possible following the event. This lack of timely documentation of the fall incident constituted non-compliance with requirements to safeguard resident-identifiable information and maintain medical records in accordance with professional standards.
Improper Use of Wheelchair as a Physical Restraint
Penalty
Summary
Surveyors identified a deficiency related to the facility’s failure to ensure a resident was free from physical restraints. Resident #7, admitted with diagnoses including Alzheimer’s disease, diabetes mellitus, and anxiety disorder, was documented on a recent MDS as rarely understood and dependent for ADLs except eating. The resident ambulated independently on the unit without an assistive device and had documented verbal and other behaviors occurring one to three days during the look-back period. The care plan noted the resident had potential to be physically aggressive, chase staff, throw objects, and be combative with care, with interventions such as offering choices, administering medications as ordered, and intervening early when agitation occurred. During an observation and interview, Resident #7 was found sitting in a chair with the right arm of the chair positioned against the nursing station and a wheelchair placed directly in front of him. The left arm of the wheelchair was also against the nursing station, and both wheelchair wheels were locked, creating a barrier that appeared to restrain the resident, who was sleeping with his knees touching the locked wheelchair. An LPN confirmed both wheelchair wheels were locked and that the wheelchair should not have been placed in front of the resident. A CNA reported she had placed the wheelchair there in preparation to get the resident up for lunch, was unable to transfer him, and left the wheelchair in that position, acknowledging it was wrong to keep it there. The facility’s physical restraint policy stated that physical restraints are not used except when alternatives are not appropriate or effective for treating a medical symptom and defined physical restraints as any device attached or adjacent to the body that the individual cannot easily remove and that restricts freedom of movement or access to the body.
Resident Left Exposed and Visible From Hallway Due to Failure to Maintain Privacy
Penalty
Summary
The facility failed to ensure resident dignity and privacy when a cognitively impaired resident was left exposed and visible from the hallway. The resident, who had diagnoses including cirrhosis with ascites, mood disorder, and alcohol-induced major neurocognitive disorder, had a BIMS score of eight, indicating moderately impaired cognition. During an observation, the resident was seen sitting on a shower chair in a gown with buttocks exposed, and this exposure was visible from the open room door in the hallway. A Certified Resident Care Associate and a Registered Nurse confirmed that the resident’s buttocks were visible from the hallway. The Certified Resident Care Associate reported that she had left the resident’s room quickly after hearing a resident in an adjacent room yell and, in her haste, forgot to close the door or pull the privacy curtain, resulting in the resident’s exposed state being visible to others. This incident involved one resident out of three reviewed for dignity, in a facility with a census of 52 residents, and was identified through record review, observation, and staff interviews.
Some of the Latest Corrective Actions taken by Facilities in Ohio
- Implemented an education binder to track and audit facility and agency staff respiratory/emergency education documents (J - F0695 - OH)
- Implemented Respiratory Therapist-led pre-shift training and competency checklists for agency nurses on ventilator-dependent resident care plans, tracheostomy care protocols, and emergency procedures before providing care (J - F0695 - OH)
- Implemented an agency acknowledgement process in the Clipboard staffing system to notify agency staff that the facility had vent/trach residents requiring care beyond routine care and required staff to read/sign the Agency Nurse Binder before picking up shifts (J - F0695 - OH)
- Implemented admission restrictions tied to Respiratory Therapist availability by not admitting tracheostomy/vent residents unless an RT was present and not admitting off-hours/weekends without RT availability (J - F0695 - OH)
- Implemented daily schedule monitoring by DON/RTM (or designees) to ensure compliance with RT and agency staffing requirements (J - F0695 - OH)
- Implemented daily monitoring of the agency education binder by RTM (or designee) to ensure education documents were completed (J - F0695 - OH)
- Implemented weekly audits of the education binder by DON (or designated nurse manager) to verify Respiratory Therapist training completion for facility and agency staff (J - F0695 - OH)
- Implemented ongoing QAPI review with the Medical Director to monitor the correction plan and continue review at QAPI meetings while the facility had vent/trach residents (J - F0695 - OH)
- Implemented ongoing Respiratory Therapist attendance at nurse and CNA meetings to provide continuing education, review competency checklists, and reinforce policies/procedures for residents on life-sustaining mechanical devices and/or requiring CPR (using verbal instruction, return demonstration, and printed procedures) (J - F0695 - OH)
Failure to Provide Life-Sustaining Respiratory Care and Effective CPR After Tracheostomy Decannulation
Penalty
Summary
The deficiency involves the facility’s failure to provide necessary life-sustaining respiratory services and effective CPR to a ventilator-dependent resident with a tracheostomy. The resident had diagnoses including acute and chronic respiratory failure, ventilator dependence, obstructive sleep apnea, pulmonary hypertension, and malnutrition, and was documented as a Full Code receiving invasive ventilation via a tracheostomy cannula. Her care plan included interventions to ensure trach ties were secured, to keep an extra trach cannula and obturator at the bedside, and a specific "cannula out" procedure directing staff to open the stoma with a hemostat, attempt reinsertion, monitor for respiratory distress, elevate the head of the bed, stay with the resident, and obtain medical help immediately if reinsertion was not possible. On the night of the incident, an agency LPN was assigned to the resident’s care. The LPN later reported she had not previously worked with the facility’s ventilator residents, had not been oriented to the unit or to the resident’s care plans, and had not received education on tracheostomy care, decannulation procedures, or the location of emergency equipment such as the crash cart and Ambu-bag. A CNA alerted the LPN that the resident’s trach had come out while care was being provided. When the LPN entered the room, she found the tracheostomy cannula lying on the resident’s chest and the resident unresponsive. The LPN attempted to reinsert the cannula but was unsuccessful, instructed the CNA to call the respiratory therapist and 911, and then began chest compressions when she could not obtain a pulse. During this period, the LPN did not provide supplemental oxygen and verified she did not know where the crash cart or Ambu-bag were located. The respiratory therapist, who had left the building at midnight after providing earlier trach and ventilator care and documenting that the resident was stable, was called back and arrived with EMS. Upon arrival, the respiratory therapist found the resident completely decannulated, very dusky, and with the LPN performing chest compressions but not providing oxygen via Ambu-bag or any other means. The respiratory therapist was able to reinsert the trach cannula, independently located the Ambu-bag in the gray basket on the ventilator, connected it to oxygen, and began ventilating the resident through the trach while EMS took over compressions. EMS documentation indicated that staff at the facility were unable to provide a history or information about the resident and that no information packet accompanied the resident to the hospital. Hospital records documented that the resident arrived in cardiac arrest secondary to hypoxic respiratory failure after the trach had been out for an undisclosed period of time, with initial blood gases showing respiratory acidosis and a clinical picture consistent with hypoxic respiratory failure leading to cardiac arrest. The death certificate listed anoxic brain injury secondary to cardiac arrest and hypoxic respiratory failure as the cause of death. Additional interviews and observations supported that staff were not adequately trained or prepared to manage tracheostomy emergencies. The agency LPN repeatedly told the respiratory therapist and EMS that she did not know where anything was for the resident or how to care for the trach when it became dislodged, despite having current CPR certification. The respiratory therapy manager confirmed there was no official training for agency nurses on caring for residents with tracheostomies on ventilators and stated that guidance was only contained in the care plans. A resident interview indicated awareness that a ventilator-dependent resident had died and that staff working that night were not trained to care for ventilator residents, and that there were no respiratory therapists in the building at night. Policy review showed that the facility’s CPR policy required provision of breaths via Ambu-bag after compressions, and the decannulation policy required calling 911, calling for a crash cart, attempting to reinsert the trach or establish an airway, and using an Ambu-bag with oxygen if there were no spontaneous breaths. Despite these written procedures and the presence of emergency supplies such as Ambu-bags and crash carts in the building, they were not effectively used during the resident’s decannulation and cardiac arrest, resulting in the identified deficiency.
Removal Plan
- Transferred Resident #54 to the hospital.
- Respiratory Therapist Manager (RTM) #242 in-serviced agency nurses LPN #288 and LPN #302; both completed return demonstration and reviewed printed policies/procedures in the agency binder (suctioning open/closed, suction catheter placement measurement, decannulation, Ambu-bag use, respiratory nursing competency checklist for vent/trach residents, and location of crash carts/AED).
- Chief Compliance Officer (CCO) #300 and former Human Resource Manager (HRM) #303 in-serviced RNs and LPNs on respiratory policies, CPR, supplemental oxygen, trach care, and decannulation; policies/procedures were sent to all nurses via text message for immediate review.
- CCO #300 and former HRM #303 in-serviced CNAs on personal care for residents with tracheostomies; policies/procedures were sent to all CNAs via text for immediate review.
- Administrator and CCO #300 educated RTM #242 on facility requirements for nurse training for ventilator-dependent residents, supplemental oxygen, tracheostomy care, and emergency procedures.
- RTM #242 implemented an education binder to track and audit all facility and agency staff education documents.
- RTM #242 (or designated Respiratory Therapist) will train agency nursing staff on ventilator-dependent resident care plans, tracheostomy care protocols, and emergency procedures prior to providing care; Respiratory Therapist to complete competency checklist.
- RTM #242 re-educated and completed competency check-offs for RNs and LPNs on respiratory care, decannulation, and emergency procedures using verbal instruction, return demonstration, and printed procedures.
- Held a QA meeting with interdisciplinary team to discuss the incident, needed education, and policies/procedures to implement.
- RTM #242 will complete respiratory assessments for all at-risk residents and ensure respiratory care is provided by trained staff.
- DON and RTM #242 uploaded an acknowledgement procedure to the Clipboard staffing agency to notify agency employees that the facility has vent/trach residents requiring care beyond routine care.
- Required agency staff to be trained by an RT on ventilator-dependent resident care plans, tracheostomy care protocols, and emergency procedures and to read/sign the Agency Nurse Binder before starting shift; acknowledgement must be signed before agency staff can pick up a shift at the facility.
- RTM #242 completed competency checklist and decannulation training for Liberty Dialysis nurses caring for tracheostomy residents (verbal instruction, return demonstration, printed procedures).
- Scheduler, DON, and RTM #242 will attempt to schedule at least one facility licensed nurse trained by an RT per shift; scheduler will notify DON/RTM #242 of shifts without a facility nurse trained by RT.
- If two agency nurses are working unexpectedly, the facility will provide RT coverage or another licensed facility nurse who has completed RT training for the duration of the shift.
- Will not admit any resident with a tracheostomy or ventilator needs until an RT is present in the facility.
- Will not admit ventilator or tracheostomy residents off-hours or on weekends if an RT is not available.
- DON (or designated nurse manager) and RTM #242 (or designated RT) will monitor the schedule daily to ensure compliance with RT and agency staffing requirements.
- RTM #242 (or designated RT) will monitor the agency education binder daily to ensure all education documents are completed.
- DON (or designated nurse manager) will audit the education binder weekly to ensure a Respiratory Therapist has trained all facility and agency staff.
- During QAPI meeting with Medical Director, review the correction plan to ensure training completion for all RNs, LPNs, and agency staff; continue review at QAPI meetings while the facility has vent/trach residents.
- RTM #242 (or designated RT) will attend nurse and CNA meetings to provide ongoing education, review competency checklists, and ensure staff knowledge of policies/procedures for residents on life-sustaining mechanical devices and/or requiring CPR (verbal instruction, return demonstration, printed procedures).
Significant Medication Error and Delayed Response After Wrong Medications Given
Penalty
Summary
The deficiency involves a failure to ensure that a resident was free from significant medication errors when an agency LPN did not follow proper medication administration procedures. The LPN prepared and administered evening/bedtime medications for two roommates at the same time, in a dark room, by popping both residents’ pills into separate cups labeled with their names. The LPN later admitted that she prepared both residents’ medications together and that the room was dark when she administered the medications. One resident, who was not ordered any benzodiazepines or opioid pain medications, was instead given medications that were ordered for his roommate, including Xanax 2 mg PO, Percocet (Oxycodone/Acetaminophen) 10–325 mg PO, and Gabapentin 800 mg PO. The resident who received the wrong medications had a history that included dementia with Lewy Bodies, neurocognitive disorder, mood disorder, major depressive disorder, anxiety disorder, CHF, hypertension, cirrhosis, muscle weakness, difficulty walking, and insomnia. His active orders included medications such as Abilify, Aspirin, Atorvastatin, Vitamin D, Plavix, Aricept, Fluoxetine, Lactulose, Magnesium Oxide, Melatonin, Remeron, Potassium Chloride, Sennosides, and Tamsulosin, with PRN orders for Acetaminophen, artificial tears, Mucinex, and Zofran. He had no orders for benzodiazepines or opioids. On the evening in question, the LPN documented administering his scheduled evening/bedtime medications around 8:44 P.M. and noted that he complained of being tired after a room change earlier that day. Shortly thereafter, his roommate complained to a CNA that his pain medications did not feel like they had worked, stating he could usually tell within 10 minutes when they took effect, suggesting concern that he had not received his usual medications. The facility also failed to timely identify and correlate the reported medication mix-up with the resident’s subsequent change in condition. Around 8:53 P.M., the LPN found the resident lethargic but responsive to touch and able to follow simple commands, with vital signs within acceptable ranges. The resident’s wife reported that he had not awakened during her visit. Despite the roommate’s report that he believed the medications had been mixed up and the LPN’s own acknowledgment that both residents’ medications had been prepared together, the LPN did not notify a physician of a possible medication error or seek medical guidance at that time. Throughout the night, the resident remained lethargic, and staff noted that something seemed “off,” but no provider was contacted until approximately 1:15 A.M., when the resident was found unresponsive, hypotensive, and bradycardic. EMS was then called, and the resident was transferred to the hospital with an altered mental status and unresponsiveness. Hospital evaluation, including a urine drug screen, showed the presence of benzodiazepines and oxycodone, which matched medications ordered for the roommate and not for the resident, confirming that a significant medication error had occurred and contributed to the resident’s serious deterioration in condition. Additional documentation from EMS and the hospital further described the resident’s condition following the error. EMS records indicated that the resident was unresponsive with pinpoint pupils, hypotension, bradycardia, and a Glasgow Coma Scale score of seven, and he received multiple doses of Narcan and Atropine en route. The ED provider note documented hypotension, bradycardia, poor responsiveness, and initial miotic pupils with partial response to Narcan, and the clinical impression included acute encephalopathy and unresponsiveness. The hospital history and physical described acute hypoxic respiratory failure and multifocal pneumonia, with progressive respiratory decline requiring endotracheal intubation and ICU admission. These findings, together with the positive urine drug screen for benzodiazepines and oxycodone in a resident without orders for those medications, were included in the facility’s investigation file as evidence of the significant medication error and its impact on the resident’s condition. The facility’s internal investigation gathered statements from the involved LPN, another LPN who assessed the resident, and a CNA. The agency LPN confirmed that she had prepared both roommates’ medications at the same time, in the dark, and that the roommate later complained that his medications did not feel effective. The second LPN reported that the resident’s condition appeared abnormal and that she eventually insisted he be sent out when he no longer responded as before. The CNA reported that the resident initially seemed at his baseline but later became more lethargic and took a “drastic turn” after his wife left. The DON acknowledged that the incident was possibly medication-related and that the resident’s transfer to the hospital for unresponsiveness was logged as an incident. Collectively, these actions and inactions—improper preparation and administration of medications, failure to promptly recognize and act on the reported medication mix-up, and delayed notification of a physician despite progressive lethargy—constituted the deficiency in ensuring the resident was free from significant medication errors.
Removal Plan
- The Vice President of Clinical Services created a performance improvement plan (PIP), presented it to the Director of Nursing (DON), and the DON assigned the Assistant Director of Nursing (ADON) to assist with medication audits designed to address medication pass performance criteria.
- The DON began an investigation for a possible medication error requiring a resident to be sent to the hospital.
- The DON interviewed the nurse involved and obtained the nurse’s statement of the incident.
- The DON interviewed the nurse working the night of the event and obtained the nurse’s statement.
- The DON interviewed the CNA who worked with the resident the night of the event.
- The DON interviewed the resident’s roommate to obtain a statement.
- The facility provided education on proper medication administration and the five rights of medication administration.
- The DON initiated an in-service on safe medication administration techniques and change of condition with nurses currently on shift regarding the possible medication error.
- The facility implemented a plan for the DON/designee to educate nurses on changes of condition and the five rights of medication administration followed by medication administration audits.
- The facility completed education for all current full-time licensed nurses and implemented a plan for new and agency nurses to be educated upon hire/scheduling by unit managers.
- The facility continued the process for an agency nurse resource guide binder to be available for agency staff to review.
- The DON/ADON began auditing changes in condition per the established schedule, with results reviewed through QAPI and issues addressed as needed.
- The DON/ADON began medication audits per the established schedule, including audits of resident identification/picture identification availability, with results reviewed through QAPI and issues addressed as needed.
- The DON conducted interviews with nurses who had worked prior to the incident/event.
- The ADON completed skin checks and health assessments on residents with low BIMS scores to identify changes in condition or possible medication adverse effects.
- The Vice President of Clinical Services and DON reviewed current policies and procedures for medication administration and change in condition.
- The physician assessed the roommate resident for possible medication adverse effects and reviewed medications for the affected resident.
- The DON reviewed the agency staff process and provided report forms to nursing staff at the beginning of shift to inform nurses how residents take their medication, and identified additions needed to the process including five rights and change in condition policy/education.
- Social Services conducted resident interviews regarding life satisfaction, abuse/neglect, and comfort reporting concerns.
- The DON completed a one-on-one in-service with the nurse involved on safe medication administration and change in resident conditions.
- The DON initiated an in-service for nursing staff on when to notify the DON regarding accidents/incidents, significant changes, medication errors, and emergencies, and implemented education upon hire for new nurses.
- The facility placed the nurse involved on the Do Not Return list.
- The facility implemented a requirement for all residents to have a picture in their chart and completed an immediate audit to verify compliance.
- The physician reviewed medications for the affected resident upon return from the hospital.
- The provider reviewed and approved all medications and documents for the affected resident.
- Social Services interviewed residents to identify concerns about receiving other residents’ medications.
- The facility implemented a plan to discuss the incident at the next QAPI meeting and to review audit results through QAPI with issues addressed as needed.
Improper Diet Texture and Lack of Meal Supervision Lead to Fatal Choking Event
Penalty
Summary
The deficiency involves the facility’s failure to ensure a resident received food in the correct mechanically altered texture as ordered and to accurately assess and implement needed supervision during eating. The resident had a physician’s order for a low concentrated sweet, no added salt, mechanical soft diet with thin liquids and a divided plate. The care plan and Nutrition and Hydration Status Assessment documented that the resident had chewing problems and required supervision or assistance at mealtimes, including that the resident fed self with supervision. Speech therapy records showed a history of dysphagia, aspiration pneumonia due to food inhalation, cerebrovascular disease, hemiplegia, and muscle weakness, with recommendations for mechanical soft/chopped textures, upright positioning, alternating food and liquids, and small bites. The resident’s DOSS score indicated restricted diet consistencies and a need for distant supervision during meals. On the day of the incident, a CNA who knew the resident was on a mechanical soft diet provided a regular-texture ham sandwich as an evening snack after the resident requested a sandwich. The CNA later admitted she was aware of the altered diet order but believed the thinly sliced ham was acceptable, even though it was not chopped or otherwise modified to a mechanical soft consistency. The DON confirmed that the ham sandwich given was not of the appropriate texture for a mechanical soft diet. The resident was not being supervised while consuming this snack, despite documentation in the Nutrition and Hydration Status Assessment that the resident required supervision during meals. The DON stated she interpreted “supervision” on the assessment as only meaning set-up assistance, and the dietetic technician later stated that the documentation of supervision needs on the assessment was a human error and that the resident only required set-up assistance. Later that evening, during medication pass, an RN observed the resident in the doorway of his room in a wheelchair, clutching his throat with both hands and attempting to gag himself with his finger. The RN asked if he was choking, and the resident nodded yes but was unable to cough or speak. The RN inspected the resident’s mouth and did not see an obstruction, then called for help and initiated the Heimlich maneuver and back blows. Multiple staff, including CNAs and a respiratory therapist, responded and each attempted the Heimlich maneuver without success. The resident became unresponsive and pulseless, and staff initiated CPR with use of a backboard, crash cart, oxygen, and bag-valve-mask ventilation until EMS arrived. EMS found the resident pulseless and apneic with a reported full airway obstruction, used video laryngoscopy and forceps to remove a large piece of meat completely obstructing the trachea, and then intubated and resuscitated the resident before transferring him to the hospital. Hospital records and the death certificate documented that the resident experienced acute hypoxic respiratory failure, aspiration pneumonia, cardiac arrest, and ultimately anoxic brain death due to choking on food.
Removal Plan
- RN responded to Resident #77, EMS was called, and the resident was transferred to the hospital.
- RN notified Resident #77's physician of the incident.
- The DON reviewed Resident #77's diet order for accuracy.
- The DON initiated an investigation of events surrounding Resident #77's choking incident.
- The DON conducted a root cause analysis and determined Resident #77 choked when CNA #151 provided Resident #77 with the incorrect diet texture during the evening snack.
- The DON reviewed all facility residents' care plans to ensure they accurately reflected current diet orders.
- The DON conducted a full house audit to ensure no additional residents received incorrect diet consistency or improper feeding assistance.
- The DON educated CNA #151 on ensuring each resident received their diet as ordered.
- The DON educated all nursing staff and the Dietetic Technician on ensuring resident care plans accurately reflected current diet needs.
- The DON educated all nursing staff on the facility policy to ensure each resident received their diet as ordered and where to verify a resident's diet order.
- The Administrator, the DON, the LPN/UM, the RDO, and the RCD reviewed facility policies on assisting residents with in-room meals, snack serving, and therapeutic diets.
- An ad hoc QAPI meeting was held to review the choking incident and the facility's corrective action plan.
- The Dietary Manager posted a list of mechanical soft approved foods in the nutrition rooms on each floor of the facility.
- The Dietary Manager posted a list of residents with mechanically altered diets in the nutrition rooms on each floor of the facility.
- The Dietary Manager and/or designee will monitor and update the lists as diet orders change, with new admissions, and as needed.
- The Dietary Manager placed separate bins identifying regular snacks and mechanically altered snacks in the nutrition rooms.
- The Dietary Manager and/or designee will ensure appropriate food items are placed in each bin based on safe foods for each diet texture.
- The DON will audit nursing staff to ensure understanding of mechanically altered diets, with results reported to the QAPI committee.
- The DON will audit residents to ensure meals and snacks being served are appropriate based on the ordered diet, with results reported to the QAPI committee.
- The DON audited all Nutrition and Hydration Status Assessments to ensure accuracy regarding residents' feeding capabilities, including supervision and assistance.
- Any inaccuracies in Nutrition and Hydration Status Assessments were corrected immediately by the Dietetic Technician.
- The DON reviewed all residents' care plans to ensure they accurately reflected the residents' feeding and eating capabilities, including supervision and assistance.
- The DON educated all nursing staff on following the care plan and Kardex to identify a resident's level of assistance required when eating.
- The Registered Dietitian educated the Dietetic Technician on completing Nutrition and Hydration Status Assessments to accurately reflect a resident's level of assistance required when eating.
- The DON will audit residents to ensure they are receiving feeding assistance and supervision as needed, with results reported to the QAPI committee.
- The DON will complete random audits of resident charts for the most recent admission, quarterly, and change of condition Nutrition and Hydration Status Assessments for accuracy of the resident's level of assistance required when eating, with results reported to the QAPI committee.
Failure to Implement Ordered Pressure Ulcer Treatments and Prevention Measures
Penalty
Summary
The deficiency involves the facility’s failure to provide ordered pressure ulcer treatments and to implement effective pressure injury prevention and management for multiple residents, most notably a resident with paraplegia, a suprapubic catheter, an ostomy, and a known stage IV left ischial pressure ulcer with osteomyelitis on admission. Hospital records at admission documented orthopedic surgery’s recommendation for follow-up at a tertiary center for possible debridement and plastic surgery consultation for wound coverage/closure, but there was no evidence this recommendation was carried out. On admission, the resident’s skin impairment was documented only as “pressure” without location, assessment, or measurements, and the initial wound evaluation described a left buttock stage IV ulcer with minimal detail. A wound vac treatment was ordered but not documented as completed on multiple days, and the care plan initially lacked key interventions such as turning and repositioning, heel elevation, and a low air loss mattress, despite the resident’s dependence on staff for bed mobility and transfers. Subsequent wound consultant nurse practitioner (WCNP) visits documented progressive worsening of the resident’s left ischial ulcer and the development and deterioration of additional pressure-related wounds, including a left heel unstageable ulcer, bilateral buttocks (gluteal dermatosis progressing to unstageable and then stage IV sacral involvement), and a right ischial unstageable ulcer. The WCNP repeatedly specified detailed treatment regimens (e.g., hydrogel, medical-grade honey, calcium alginate with silver, Santyl, Dakin’s solution-moistened gauze, zinc oxide, collagen, low air loss mattress, turning/repositioning, and heel floating), but the facility frequently failed to enter these orders correctly into the electronic record, omitted treatments entirely, or implemented incorrect treatments and frequencies. For example, there was no treatment order entered for the bilateral buttocks gluteal dermatosis after the 07/16/25 WCNP visit, no updated order for the left ischial ulcer at that time, and no treatment documented on the TAR for the buttocks on several days. Later, when Dakin’s solution and Santyl were ordered in the WCNP plan, the facility did not clarify the Dakin’s concentration, did not obtain Dakin’s or Santyl from the pharmacy for extended periods, and continued to provide incorrect or incomplete wound care. There was no documentation that the resident refused wound care or repositioning. As the weeks progressed, wound measurements and descriptions documented by the WCNP showed increasing size, depth, undermining, slough, eschar, exposed deeper tissues (including muscle/fascia and subcutaneous tissue), malodor, and increased exudate in the left ischial, right ischial, and bilateral buttocks/sacral areas. Despite these changes and the resident’s total dependence for bed mobility, the MDS showed the resident was not on a turning/repositioning program, and the plan of care and interventions remained nonspecific or incomplete. Laboratory monitoring revealed elevated white blood cell (WBC) counts, with a WBC of 14.9 reported and acknowledged by the facility practitioner, and a subsequent WBC of 18.6 reported to the facility without documented notification to the practitioner or triage service. The resident ultimately requested transfer to the emergency room after being informed of the lab results and was hospitalized with osteomyelitis of the sacral stage IV pressure ulcer, requiring IV antibiotics and ongoing treatment for the left and right ischial ulcers. After a later hospital stay, the resident returned with documented wound care orders for sacral and bilateral ischial ulcers, but on readmission there were no corresponding treatment orders or documented treatments for these wounds on the first days back in the facility. Additional deficiencies were identified for other residents. One resident, admitted at risk for pressure ulcer development and altered skin integrity, developed an in-house unstageable pressure ulcer when the facility failed to implement pressure ulcer prevention strategies. Another resident had failures in ensuring pressure ulcer prevention measures and care were in place, though this did not rise to the level of actual harm. Across these residents, the survey findings showed repeated failures to implement ordered wound treatments, to obtain and correctly use prescribed wound care products, to clarify incomplete orders (such as missing Dakin’s solution concentration), to consistently document and carry out preventive interventions like turning, repositioning, and heel protection, and to timely communicate abnormal laboratory findings related to wound status to medical providers.
Removal Plan
- LPN #1077 initiated skin inspection on all current residents with verifying interventions; all residents were assessed with treatments initiated for newly identified areas (Resident #11 protective dressing for loose toenail; Resident #24 non-stick pad for abdominal blister; Resident #55 bordered foam for knee abrasion).
- The residents with pressure injury treatment orders were audited by RDCS #1050 to verify EMAR orders match WCNP orders; RDCS also audited Resident #72’s wound clinic visit note and verified orders.
- The facility held an ad hoc QAPI meeting with the Medical Director #1028 (by phone) and interdisciplinary team to discuss/address the Immediate Jeopardy; nursing education was initiated following the meeting.
- DON #1057 began education for nurses and CNAs on skin prevention, daily skin care, skin inspection, documentation of refusal of nutrition/hydration, reporting and documentation; nurses were educated on implementing treatments when skin alteration identified, ensuring interventions are in place, documenting refusals, following physician/NP orders, and reporting abnormal labs same day with documentation.
- DON #1057 provided verbal education to LPNs, CNAs, and RNs; staff not reached were instructed to receive verbal education prior to next scheduled shift and a communication message was sent to staff who had not yet received education.
- Additional education was completed by DON #1057; remaining staff who were left messages will be educated prior to next scheduled shift.
- RDCS #1050 educated the clinical management team (DON #1057, LPN #1077, LPN #1078) on auditing skin prevention, interventions, order implementation, and documentation; DON #1057 will complete pressure wound measurements/assessments with MDS RN #1071 as backup.
- VPCS #1029 and RDCS #1050 reviewed the Skin and Wound Policy for accuracy and to ensure it meets regulatory guidelines.
- The clinical management team (DON #1057, LPN #1077, LPN #1078) initiated education for all licensed nurses on changes in resident skin integrity related to decline, interventions, and notification of labs to medical professionals.
- RDCS #1050 completed an audit of wound evaluations initiated since wound rounds to identify new skin areas and verify new treatments were in place (Resident #14 skin tear treated with xeroform and kerlix; Resident #6 skin tear to left shin treated with xeroform and kerlix; Resident #22 two new diabetic ulcers treated with xeroform and kerlix; Resident #94 new sacral pressure area treated with chamosyn and leave open to air).
- DON #1057/designee will audit all new admission orders for 30 days to ensure skin treatments were implemented as ordered; if DON unavailable, RDCS #1050 will audit; audit verifies each identified area has a treatment in the EMAR and is completed by DON #1057 or LPN #1077 or LPN #1078 in DON’s absence.
- DON #1057/designee will audit weekly for 4 weeks all residents seen by wound consultants/outside wound clinics to verify treatment orders match consultant orders and were implemented timely by facility nurses.
- DON #1057 educated MDS RN #1071 on auditing skin prevention, interventions, order implementation, and documentation.
- All audit results will be reported to QAPI weekly for 4 weeks.
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