CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Notification of Changes
(Tag F0580)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review and staff interviews, the facility failed to notify the physician timely when there was a si...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review and staff interviews, the facility failed to notify the physician timely when there was a significant change in the resident'ss condition for one (#24) of two residents out of 26 sample residents.
Specifically, the facility failed to notify the Resident #24's physician when enteral nutrition orders were not being followed by the staff.
Findings include:
I. Facility policy and procedure
The Enteral Tube Feeding via Continuous Pump policy, revised November 2018, was provided by the quality improvement specialist (QIS) on 8/29/19 at 10:00 a.m. It read in pertinent part,
-Report complications (diarrhea, gastric distention, respiratory distress) promptly to the supervisor and the attending physician.
-Report negative consequences of tube use (agitation, depression, self-extubation, infections) to the supervisor and attending physician.
-Notify the supervisor if the resident refuses the procedure.
-Report other information in accordance with facility policy and professional standards of practice.
The Enteral Medication Administration policy, revised 8/28/19, was provided by the QIS on 8/29/19 at 10:00 a.m. It read in pertinent part,
-The facility ensures the safe and effective administration of enteral formulas and medications. Selection of enteral formulas, routes and methods of administration, and the decision to administer medications via enteral tubes are based on nursing assessment of the resident's condition, in consultation with the physician, dietitian and pharmacist.
-Enteral formulas, equipment, route of administration and rate of flow are selected based on an assessment of the resident's condition and need.
II. Resident #24
A. Resident status
Resident #24, age [AGE], admitted [DATE] and readmitted [DATE]. According to the August 2019 computerized physician orders (CPO), diagnoses included cerebrovascular disease (stroke) and hemiplegia and hemiparesis (weakness and paralysis) affecting the left side.
The 6/11/19 minimum data set (MDS) assessment revealed the resident had severe cognitive impairment with no assessment for brief interview for mental status (BIMS) score and severely impaoired decision making. The resident received 51 percent or more of his total calories by nourishment through artificial route in the form of tube feed and depended on staff for activities of daily living.
B. Observation
On 8/28/19 the resident's tube feeding pump was observed intermittently from 9:00 a.m. to 3:30 p.m in the day room adjacent to the nurses station. The resident was not connected via his percutaneous endoscopic gastrostomy (PEG) tube to the pump throughout that time.
C. Record review
The 4/25/19 physician order documented and re-ordered when resident readmitted from the hospital on 8/27/19, Glucerna 1.5 infused at 60ml (mililaters)/hour x 20 hours via PEG (percutaneous endoscopic gastrostomy) every shift for gastroparesis. The hours the resident was not to be connected to the continuous feed was from 1:30 p.m. to 5:30 p.m.
-Review of the August 2018 medication administration record (MAR) indicated the tube feeding was administered on 8/27/19 at 6:30 p.m. from 6:30 a.m. and 8/28/19 from 6:30 a.m. to 1:30 p.m. (This documentation was in accurate and contradicts the observation above)
Review of the nurse progress notes from 8/27/19 to 8/28/19 revealed the resident was sent to the hospital around 1:00 p.m. on 8/27/19 due to the resident having abdominal distention and vomiting. The resident returned to the facility at 7:00 p.m. the same day (8/27/19) The nurse notified the nurse practitioner, director of nursing and administration and documented the resident was at baseline.
-There was no other documentation regarding the nurse practitioner holding the order or progress note from the nurse on 8/28/19 that she communicated with the physician to hold the resident's enteral nutrition orders while the resident remained in the facility before going to the hospital and/or after the resident returned from the hospital his tube feeding was not turned back on (see observations above and interview below).
III. Staff interviews
The registered dietitian (RD) was interviewed on 8/28/19 at 12:07 p.m. She said she provided the recommendations for the residents on enteral nutrition. She said she reviewed the resident's tolerance to the tube feeding regimen, the rate, and make formulary recommendations based on medical conditions. She said she came to the facility week to complete nutrition charting for residents in the facility.
She said Resident #24 was on continuous tube feeding formula Glucerna 1.5 at 60 milliliters (ml) per hour for 20 hours. She said he had a four hour break from the continuous feeding from 1:30 p.m. to 5:30 p.m. She said the resident could not have food by mouth so the tube feeding regimen was his only source of calories and protein. She said the resident went to the hospital on 8/27/19 for a few hours due to him not tolerating his tube feeding regimen and she had not reassessed him since being back at the facility. She said she was not aware that the resident was not connected to his tube feeding since he returned from the hospital on 8/27/19 at 7:00 p.m. and the morning of 8/28/19.
She said the nurses did not communicate to her when they disconnected him from the continuous feeding. She said she would expect the nurses or nurse management to communicate with her if the resident was not tolerating the formula or when they disconnect him from it due to an acute clinical condition.
Registered nurse (RN) #1 was interviewed on 8/28/19 at 4:12 p.m. She said she had not connected Resident #24's enteral nutrition since she came on shift at 6:00 a.m. She said during shift report with the night nurse that he had returned from the hospital due to distension and vomiting and the hospital did an abdominal scan and it was negative. She said the night nurse said the hospital added miralax powder to be administered via his PEG tube but his previous medications orders had remained the same, including his enteral nutrition order.
She said it was her nursing judgement to hold the enteral nutrition orders for Resident #24 because she said he still had abdominal distention. She said she had not communicated to the physician that the resident's enteral nutrition was held or the acute complications the resident had during her shift.
The director of nursing (DON) was interviewed on 8/28/19 at 5:20 p.m. She said the nurses should follow all physician orders unless the resident was having acute complications then it would be communicated to the resident's physician immediately.
She said she talked to the night shift nurse via the telephone, that worked the night the resident returned from the hospital on 8/27/19. She said per her telephone conversation the nurse said when she called orders in to the nurse practitioner she said to hold the enteral nutrition order and failed to document the order.
The DON said all orders communicated by prescribers via the telephone should be entered into the resident physician's order. She said the hospital discharge orders were to continue with his feedings since his test obtained in the hospital were negative and to add Miralax.
She said she would call the physician to see what course of action would be required due to the resident's abdominal distention and she said after communicating with the physician, his feeding was not held and was continued.
IV. Facility follow-up
The 8/28/19 nurse progress note documented in part, At around 4:00 p.m. the tube feeding was set up and it runs at 60cc (cubic centimeters/60 mililtiers) per hour. The resident was assessed and no s/s (signs and symptoms) of discomfort or pain.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0625
(Tag F0625)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on resident interview, record review and staff interviews, the facility failed to inform a resident of the facility's bed ...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on resident interview, record review and staff interviews, the facility failed to inform a resident of the facility's bed hold policy for one (#71) of one resident reviewed for hospitalization out of 26 sample residents.
Specifically, the facility failed to ensure Resident #71 was informed, in writing, of the bed hold policy when he transferred to the hospital while on leave from the facility.
Findings include:
I. Facility policy and procedure
The Bedhold policy, dated 11/4/13, was provided by the quality improvement specialist (QIS) on 8/29/19 at 1:05 p.m. It read in pertinent part,
-The resident and/or responsible party shall be notified of behold policies of the facility. The notification will be provided in writing upon admission and upon transfer for medical leave.
-The admission Coordinator gives a notice of the facility's Behold policy to all new admissions during the admission process.
-In case of emergency medical transfer, the Notice Regarding Behold and readmission form will be included with other paperwork, which accompanies the resident to the hospital. The health information manager will mail a copy of the form to the resident's legal representative within 24 hours unless the resident has been readmitted to the facility.
II. Resident #71
A. Resident status
Resident #71, age [AGE], was admitted [DATE]. According to the August 2019 computerized physician orders (CPO) diagnoses included diabetes mellitus, chronic kidney disease and dependence on renal dialysis.
The 8/2/19 minimum data set (MDS) assessment indicated the resident was cognitively intact with a brief interview for mental status (BIMS) score of 15 out of 15. The resident had a reentry date of 5/27/19 and 7/25/19 from an acute care hospital.
B. Record review
The 5/22/19 nurse progress note documented the resident had critical renal labs and the resident was transported to the emergency room.
The 7/24/19 nurse progress note documented the resident had cellulitis (bacterial skin infection) on his toe and was sent to the emergency room.
A review of progress notes and the transfer/discharge paperwork failed to reveal the resident was notified by the facility of it's bed hold policy when he transferred to the hospital on 5/22/19 and 7/24/19.
III. Staff interviews
The director of nursing (DON) was interviewed on 8/28/19 at 5:00 p.m. She said when a resident is sent to the hospital, the involuntary transfer/discharge form was sent with the resident. She said it outlined in the form that when the resident was sent to the hospital that the facility followed the information provided in the bed hold policy the resident signed at admission. She said admission agreement with the bed hold policy and each involuntary transfer/discharge form was uploaded by medical records into the electronic medical record.
She said for Resident #71, she did not locate the admission agreement signed by the resident when he admitted or any of the involuntary transfer/discharge form. She said she was going to resign the bed hold agreement with Resident #71 since the facility could not locate any documentation.
IV. Facility follow-up
The DON provided an updated admission agreement form that outlined the bed hold policy signed by Resident #71 on 8/29/19 at 8:53 a.m.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Tube Feeding
(Tag F0693)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review, and staff interviews, the facility failed to ensure residents with a gastrostomy tube recei...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review, and staff interviews, the facility failed to ensure residents with a gastrostomy tube received appropriate treatment and services to prevent complications for one (#24) of two reviewed out of 26 sample residents.
Specifically, the facility failed to:
-Label the tube feeding bag with the date and time, initials of the nurse hanging the tube feeding, type of tube feeding and flow rate upon administration; and,
-Ensure the tube feeding equipment was stored in a clean and sanitary manner.
Findings include:
I. Facility policy and procedure
The Enteral Tube Feeding via Continuous Pump policy, revised November 2018, was provided by the quality improvement specialist (QIS) on 8/29/19 at 10:00 a.m. It read in pertinent part,
-Use aseptic technique when preparing or administering enteral feedings.
-Check the enteral nutrition label against the order before administration. Check the following information: resident name and room number, type of formula, date and time formula was prepared, route of delivery, access site, method and rate of administration.
II. Manufacturer recommendation for storage of formula
The manufacturer's recommendation for storage of enteral tube feeding formula was provided by the registered dietitian consultant on 8/29/19 at 9:30 a.m.
It read, in pertinent part, Feeding sets are for single-patient use only. Use clean technique to avoid set and/or product contamination. Hang product up to 48 hours after initial connection when clean technique and only one new feeding set are used. Otherwise, do not hang longer than 24 hours.
II. Resident status
Resident #24, age [AGE], admitted [DATE] and readmitted [DATE]. According to the August 2019 computerized physician orders (CPO), diagnoses included cerebrovascular disease (stroke) and hemiplegia and hemiparesis (weakness and paralysis) affecting the left side.
The 6/11/19 minimum data set (MDS) assessment revealed the resident had severe cognitive impairment with no assessment for brief interview for mental status (BIMS) score and severely impaoired decision making. The resident received 51 percent or more of his total calories by nourishment through artificial route in the form of tube feed and depended on staff for activities of daily living.
III. Observations
On 8/26/19 at 10:00 a.m. the resident's tube feeding pump was observed connected to him while he was in a recliner prompt up watching television in the day room adjacent to the nurses station. The tube feeding pump was connected to an intravenous pole (IV) pole with two bags hanging from both sides. The tube feeding formula bag had written on it 8/26/19 in black marker with no other identifiable information.
On 8/28/19 the resident's tube feeding pump was observed intermittently from 9:00 a.m. to 3:30 p.m in the day room adjacent to the nurses station. The resident was not connected via his percutaneous endoscopic gastrostomy (PEG) tube to the pump throughout that time.
The tube feeding formula bag that hung on the IV pole had documented on it in black marker, 8/27/19 at 0100. (8/27/19 at 1:00 a.m.) The connector from the tube feeding pump was hanging from the pole with crusted formula at the end of the connector.
III. Record review
The 4/25/19 physician order documented, Glucerna 1.5 infused at 60ml (mililaters)/hour x 20 hours via PEG (percutaneous endoscopic gastrostomy) every shift for gastroparesis. The hours the resident was not connected to the continuous feed was from 1:30 p.m. to 5:30 p.m.
IV. Staff interviews
The RDC was interviewed on 8/29/19 at 9:30 a.m. She said tube feeding formula was good for up to 48 hours if the tube feeding connector was directly spiked into the 1000 milliliter bottles because there would be no potential for contamination. She said due to the spikes not being available to be ordered for the facility nurses, the nurses had to pour formula into a 1000 milliliter bag that had a connector to fit the PEG tube. She said the formula, since it had been removed from the original package would be good for 24 hours.
Registered nurse (RN) #1 was interviewed on 8/28/19 at 4:12 p.m. She said she had not connected Resident #24's enteral nutrition since she came on shift at 6:00 a.m. She said when the tube feeding formula was hung a label should be placed on the bag with the nurse's initial, time it was initiated, the formula and rate. She said when she disconnected the tube feeding connector from the PEG tube she ensured the connector was cleaned and stored away covered with no residual left on it.
The director of nursing (DON) was interviewed on 8/28/19 at 5:20 p.m. She said the tube feeding formula should have been discarded on 8/28/19 at 1:00 a.m. since the formula bag had the date of 8/27/19 at 1:00 a.m. on it. She said the tube feeding formula when hung should have the formula, rate, when it was administered at a minimum. She said it should be on a label and not written in marker on the formula bag. She said the tube feeding bags with connector should be discarded after 24 hours. She said she was providing inservice education to the nurses on proper management of the tube feeding formula, storage and labeling.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0698
(Tag F0698)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and staff interviews, the facility failed to ensure one (#71) of two out of 26 sample residents received ...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and staff interviews, the facility failed to ensure one (#71) of two out of 26 sample residents received dialysis services consistent with professional standards of practice.
Specifically, the facility failed to:
-Ensure ongoing communication and collaboration with the dialysis center regarding dialysis care and services was completed for Resident #71; and,
-A written contract between the dialysis center and facility was implemented to outline the provision of care of services for Resident #71.
Findings include:
I. Facility policy and procedure
The Hemodialysis Residents policy and procedure, revised 2/4/16, was provided by the quality improvement specialist (QIS) on 8/27/19 at 3:33 p.m. It read in pertinent part,
-The facility provides residents with safe, accurate, and appropriate care, assessments and interventions to improve resident outcomes.
-A Dialysis Communication Record is initiated and sent to the dialysis center each appointment; ensure it is received upon return. Key medical record documentation elements: vitals signs and weight.
II. Resident #71
A. Resident #71 status
Resident #71, age [AGE], was admitted [DATE]. According to the August 2019 computerized physician orders (CPO) diagnoses included diabetes mellitus, chronic kidney disease and dependence on renal dialysis.
The 8/2/19 minimum data set (MDS) assessment revealed the resident was cognitively intact with a brief interview for mental status (BIMS) score of 15 out of 15 and received dialysis services.
B. Record review
The 12/5/18 renal insufficiency care plan documented the resident went to dialysis center with their contact information. Pertinent interventions were monitor clinical changes post dialysis and labs.
The 6/26/19 physician order documented to take vital signs post dialysis on Monday, Wednesday and Friday.
Review of the Dialysis Communication Record forms from 6/1/19 to 8/27/19 revealed the form was not completed by the facility staff. The top portion of the form to be completed by the facility nurses included vital signs prior to dialysis, assessment concerns such as significant weight changes, medication changes, refusal of diet or fluid restriction with the facility nurse signature and date.
The contract between the facility and dialysis provider was requested on 8/27/19 at 12:00 p.m. and the QIS said there was not a written contract available (see interview below).
III. Staff interviews
Licensed practical nurse (LPN) #2 was interviewed on 8/27/19 at 1:53 p.m. She said when a resident had dialysis care and services there would be a physician order with the date, location and time. She said the facility and the dialysis communicated after each session via the Dialysis Communication Record form. She said the nurse on shift filled out the top portion of the form with pertinent clinical information like weight, vital signs and changes with the resident. She said the form was placed into a dialysis binder and sent with the resident to the dialysis treatment. She said the dialysis center filled out the bottom portion of the form with weight, vitals, medications administered at the center and other pertinent information. She said the nurse on shift reviewed the form post dialysis and if there were changes, it was communicated with the physician.
The director of nursing (DON) and QIS were interviewed on 8/27/19 at 2:05 p.m. She said in order to have consistent care and collaboration among the facility and dialysis providers the Dialysis Communication Record forms were filled out every treatment. She said the nursing staff were responsible for filling out the top portion of the form that included the daily vitals including weights and any issues or concerns with the resident. She said the dialysis center then filled out the bottom portion of the form with the same information and the nursing staff were responsible to view the form and communicate any new information.
The DON said for Resident #9, his Dialysis Communication Record forms were not filled out by the nursing staff before he left for treatment. She said she would begin education with the nurses on the importance of the form and ensure that it was filled out before a resident left for dialysis treatment.
The QIS said the dialysis center and facility should have had a contract in place to ensure the care provided by each entity was clearly defined. He said he told the facility to get the contract in place but it had not been done before 8/26/19. He said he reached out to Resident #9 ' s dialysis center to get a written contract in place.
The dialysis clinic manager (DCM) was interviewed on 8/28/19 at 2:23 p.m. He said when a resident had a dialysis treatment the clinic filled out the information on the communication forms in order for the facility staff to have any pertinent clinical information. He said if the forms were filled out by both entities correctly then it provided communication to ensure the resident had consistent care.
He said for Resident #9, his staff often indicated on the form that there was no information from the facility before his dialysis treatment. He said the resident faithfully brought the Dialysis Communication Record forms and brought them back to the facility. He said his staff often had to call the social worker or nurse on staff to ensure changes were communicated since his staff could not always rely on the facility staff reviewing for form with the written information.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Medication Errors
(Tag F0758)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and staff interviews, the facility failed to ensure resident use of psychotropic medication was appropria...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and staff interviews, the facility failed to ensure resident use of psychotropic medication was appropriate for one (#9) of five residents reviewed for unnecessary medication use out of 26 sample residents.
Specifically, the facility failed to:
-Provide non-pharmacological interventions prior to the administration of an as-needed (PRN) psychotropic medication: and,
-Provide documentation and rational to justify the continued use of a PRN psychotropic medication.
Findings include:
Facility policy and procedure
The Psychopharmacological Medication policy, revised 1/10/19, was provided by the quality improvement specialist (QIS) on 8/29/19 at 9:38 a.m. It read in pertinent part:
-The community supports the appropriate use of psychopharmacological drugs that are therapeutic and enabling for residents suffering from mental illness.
-The licensed nurse and/or social service director will make every effort to determine if there are any potential behavior symptoms that may require special monitoring and/or care planning.
-The plan of care must include behavior interventions and medication monitoring/dosage reduction if appropriate.
-The interdisciplinary team will review residents on psychopharmacological drugs at least quarterly.
-The Psychopharmacological /Behavior Review Committee will review the residents on admission, quarterly, and change of status. Committee members will ensure the resident is on the most appropriate psychopharmacological drug for the specific behavior symptoms and/or diagnosis and at the lowest possible dose to control the symptoms and they have an appropriate corresponding diagnosis and rationale for continued use (Risk vs Benefit statement.)
-The licensed pharmacist will review residents' psychopharmacological drug regimen on a monthly basis.
-The primary physician will monitor residents who are prescribed psychopharmacological drugs at least quarterly to assure these drugs are utilized according to State and Federal regulations and for the appropriate treatment of resident diagnosis.
Resident #9
Resident #9, age [AGE], was admitted on [DATE] and readmitted on [DATE]. According to the August 2019 computerized orders (CPO), the diagnosis included chronic obstructive pulmonary disease, personal history of traumatic brain injury and anxiety disorder.
The 5/30/19 minimum data set (MDS) assessment revealed, the resident was moderately impaired with a brief interview for mental status (BIMS) score of 10 out of 15. He received antianxiety, antidepressant and opioid medication. He needed limited to extensive assistance with most activities of daily living. He did not exhibit any behaviors but he did reject care one to three days of the week. He used supplemental oxygen and received hospice care.
Record review
The anti-anxiety medication care plan, revised 6/3/19, documented the resident had the following behaviors: anxiety when he remembers his daughters death and thinks it was recent, and anxiety when he became short of breath. Pertinent interventions listed were to monitor and record occurence of target behavior symptoms, anxiousness related to shortness of breath and memories that trigger anxiety and document per facility protocol, notify hospice for break through anxiety or unsuccessful interventions, provide one to one when he shows signs of anxiety and encourage him to talk about feelings and concerns and utilize non-pharmacological interventions as able.
The mood care plan, revised 5/2/18, documented the resident had the following behaviors: mania, hypermania, racing thoughts, euphoria, increased irritability, frequent mood changes, pressured speech, flight of ideas, marked change in need for sleep and hyperactivity. Pertinent interventions listed were assist resident, family and caregivers to identify strengths, positive coping skills and reinforce them. Monitor/record / report to MD signs and symptoms of anxiety.
The August 2019 CPO documented, Lorazepam (anti-anxiety medication) give 0.5 ml (millileters) by mouth every 2 (two) hours as needed for terminal agitation /shortness of breath. The medication was started on 6/15/18 with no end date documented.
Review of the medication administration record (MAR) from 4/1/19 to 8/28/19 revealed the resident was administered the Lorazepam (brand name Ativan) PRN on 4/15/19, 5/7/19, 7/2/19 and 8/4/19.
-There were not any non-pharmacological interventions documented in the resident ' s progress notes or any behavior documentation indicating why the PRN Lorazepam was administered.
The 8/15/19 nurse practitioner (NP) note documented in part that the resident was being seen for a routine visit. He had no complaints of shortness of breath or anxiety. It read that the patient had a history of anxiety, which was stable, and was receiving Ativan PRN for anxiety. It read to continue the Ativan.
The 5/20/19 psychotropic medication management review documented the resident was on Lorazepam 0.5ml every two hours as needed for terminal agitation and shortness of breath. No gradual dose reduction or non-pharmacological interventions were documented.
Staff interviews
The registered nurse (RN) #1 was interviewed on 8/28/19 at 2:48 p.m. She said when administering a PRN psychotropic medication the nurse needed to know first what the indication for use. She said she tried non-pharmacological interventions such as divert their attention or to engage them in an activity. If the non-pharmacological interventions failed, then she administered the PRN psychotropic, checked back with the resident in an hour and document if the symptoms were diminished and if the PRN medication was effective. She said the non-pharmacological interventions and behaviors would be documented in the resident ' s progress notes.
She said for Resident #9 if he was having shortness she would check his oxygen saturation level and make sure he was wearing his oxygen before administering the PRN Lorazepam. She would document any abnormal breath sound, oxygen use, agitation, restlessness and his comfort level before administering his PRN Lorazepam. She said it was standard for hospice to have Lorazepam PRN for a resident in case it was needed. She said he received the PRN Lorazepam on 4/15/19, 5/7/19, 7/2/19 and 8/4/19. She said if the resident was in distress or had an increase in his anxious behaviors then she would communicate with the physician, hospice nurse and family.
The director of nursing (DON) was interviewed on 8/28/19 at 5:28 p.m. She said the facility reviewed residents ordered psychotropics in their quarterly meeting. She said the mental health doctor, pharmacist, administrator, DON and social service director participated in the meeting.
She said Resident #9 was on hospice, losing weight and had a history of anxiety. She said he was declining and had significant anxiety. She said he had been receiving the PRN Lorazepam for anxiety since 6/15/18. She said Resident #9 uses the PRN Lorazepam occasionally, but if he was anxious due to his shortness of breath then a breathing treatment often worked to relieve his anxiety. She said the nurse practitioner note dated 8/15/19 documented the resident was stable, appeared calm and was appropriate for the situation. It documented to continue the PRN Lorazepam.
The social services director (SSD) was interviewed on 8/28/19 at 5:33 p.m. She said they reviewed psychotropic medications quarterly at the minimum and if there was a significant change. The psychotropic committee discussed behavior changes as well as medical concerns. They reviewed the psychotropic medications prescribed and past gradual dose reductions. She said the findings were documented on the interdisciplinary psychotropic evaluation. She said the pharmacist tracked the psychotropic medications and presented recommendations during the monthly psychotropic committee meeting.
The pharmacy consultant (PC) was interviewed on 8/29/19 at 10:31 a.m. She said a medication regimen review (MRR) was completed monthly for each resident. She said her recommendations were sent to the DON and the staff development coordinator (SDC) and were addressed within 90 days. She said if the recommendations were more urgent she would expect it to be addressed within 30 days or if it was critical a call was placed to the DON to follow up on the recommendation immediately.
The PC said she would review any psychotropic PRN monthly especially if it had been ordered since 6/15/18. She said that if a PRN psychotropic medication was ordered, the prescriber should reassess the resident after 14 days, document the need for continued use and duration if prescribed longer than the 14 days.
The PC said Resident #9 was discussed in the monthly psychotropic committee meeting but she did not have any MRR for his Lorazepam PRN ordered.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0761
(Tag F0761)
Could have caused harm · This affected 1 resident
Based on observations and interviews the facility failed to ensure safe medication and vaccine storage in two out of three medication rooms.
Specifically, the facility failed to:
-Store vaccines in a ...
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Based on observations and interviews the facility failed to ensure safe medication and vaccine storage in two out of three medication rooms.
Specifically, the facility failed to:
-Store vaccines in a non-dormitory style refrigerator: and,
-Monitor the temperatures of refrigerated medications, vaccines and biologicals.
Finding include:
I. Facility policy and procedure
The storage of medications policy, revised April 2007, was provided by the quality improvement specialist (QIS) on 8/29/19 at 4:30 p.m. It read, in pertinent part: the facility shall store all drugs and biologicals in a safe, secure, and orderly manner. It read that medications requiring refrigeration must be stored in a refrigerator located in the drug room at the nurses ' station or other secured location.
II. Professional reference
According to the Centers for Disease and Control and Prevention (CDC) Vaccine Storage and handling (2019) retrieved from: https.//www.cdc.gov/vaccines/hcp/admin/storage/toolkit/storage-handling-toolkit.pdf. Do not store any vaccine in a dormitory style or bar-style combined refrigerator/ freezer unit under any circumstances. These units have a single exterior door and an evaporator plate/cooling coil, usually located in an ice maker/freezer compartment. These units have been shown to pose a significant risk of freezing vaccines, even when used for temporary storage. All staff members who receive deliveries and/or handle or administer vaccines should be familiar with storage and handling policies and procedures at your facility. Failure to store and handle vaccines properly can reduce vaccine potency, resulting in inadequate immune responses in patients and poor protection against disease. Vaccines must be kept refrigerated at 36-46 degrees F.(9/3/19)
III. Observations and interviews
A. Medication storage rooms
1. Fourth floor
On 8/28/19 at 5:16 p.m. the fourth floor medication storage room refrigerator was inspected with licensed practical nurse (LPN) #3. The refrigerator was observed to be a dormitory style refrigerator with an internal freezer unit and four pneumococcal vaccine vials stored in the top shelf of the door. The temperature was 34 degrees F.
The July 2019 temperature log documented that all 31 days the refrigerator temp was below 36 degrees F.
The August 2019 temperature log documented that 25 out of 28 days the temperature was below 36 degrees F.
LPN #3 said she did not know vaccines should not be kept in the door of the refrigerator or that the refrigerator should not have a freezer in it. She said she was not sure what the temperature range should be and that the night nurse checks the refrigerator temperature and logs it. She said she was not sure who should be notified if there are out of range temperatures.
2. Second floor
On 8/28/19 at 5:35 p.m. the second floor medication storage room refrigerator was inspected with LPN #1. The refrigerator was observed to be a dormitory style refrigerator with an internal freezer unit. There were no vaccinations in the fridge and the refrigerator temperature was 46 degrees F.
The July 2019 temperature log documented that two out of the 31 days the temperature was below 36 degrees F.
The August 2019 temperature log revealed that five out of the 28 days the temperature was below 36 degrees F and one of the days it was 48 degrees F. The top of the log form read the refrigerator temperature should be between 36-38 degree F.
LPN #1 said she did not know what the refrigerator temperature should be. She said the night nurse checked the temperature and then would log it. She was not sure who should be contacted if refrigerator temperatures were out of range but said the director of nursing (DON) or maintenance should also be notified.
The DON and the quality improvement specialist (QIS) were interviewed on 8/29/19 at 11:38 a.m. They said they were aware that the medication room refrigerators were out of compliance and would be replacing all of them. The DON said if the medications were not stored properly it could affect the medications potency. She said the refrigerator temperature should be between 36-42 degrees F. The QIS said they had ordered a refrigerator just for the vaccines. The DON said the night nurse checked the refrigerator temperature nightly and should then document on the log.
The QIS said if the temperature was not within range, the nurse should notify the DON and maintenance, remove the medications from the refrigerator and place them in another refrigerator or destroy them if needed. They said they had not been notified of out of range temperatures until the day before. They said the staff development coordinator should have educated the nurses on when to notify the DON and maintenance of incorrect refrigerator temperatures. They had not provided the training but would start the following day.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0849
(Tag F0849)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on resident record review and staff interviews, the facility failed to collaborate with the hospice provider to attain or ...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on resident record review and staff interviews, the facility failed to collaborate with the hospice provider to attain or maintain the highest practicable physical, mental and psychosocial well-being for one (#9) of two out of 26 sample residents.
Specifically, the facility failed to:
-Coordinate hospice services and develop a current care plan delineating the care provided by the hospice agency and the nursing facility for this resident's overall care and ensure adequate and timely documentation for Resident #9; and,
-A written contract between the facility and hospice provider outlining provision of care and services.
Findings include:
I. Facility policy and procedure
The Hospice Care policy, revised 10/26/18, was provided by the health information manager (HIM) on 8/27/19 at 3:00 p.m. It read in pertinent part,
-When a facility resident elects to have hospice care, the facility staff communications with the hospice agency to establish and agree upon a coordinated plan of care that is based upon an assessment of the resident's needs and living situation in the facility.
-Ensure that the hospice services meet professional standards and principles that apply to the individuals providing services in the facility and to the timeliness of services.
-Ensure that the plan of care identifies the care and services which the facility and hospice agency will provide in order to be responsive to the unique needs of the resident and expressed desire for hospice care. Appoint a clinical member of interdisciplinary team to act as hospice coordinator.
-Ensure that the facility staff is aware of their responsibilities in implementing the plan of care, as well as the responsibilities of the hospice staff.
II. Facility and hospice written agreement
The Hospice Services Agreement, dated 8/27/19 (during survey), was provided by nursing home administrator (NHA) on 8/27/19 at 2:50 p.m. It read in pertinent part,
-The hospice must provide the nursing facility the most recent hospice plan of care, nurse and contact information for hospice personnel involved in hospice plan of care of each patient, physician certification and recertification of the terminal illness and hospice medication information specific to each patient.
-Nursing facility and Hospice shall each prepare and maintain complete and detailed clinical records concerning each hospice patient receiving nursing facility services.
III. Resident #9
A. Resident status
Resident #9, age [AGE], was admitted on [DATE]. According to the August 2019 computerized physician orders (CPO), diagnoses included chronic obstructive pulmonary disease (COPD), anxiety disorder and recurrent depressive disorders.
The 5/30/19 minimum data set (MDS) assessment revealed the resident was moderately cognitively impaired according to the brief interview for mental status (BIMS) score of 10 out of 15 and received hospice care.
B. Record review
The 10/10/16 physician order documented the resident was admitted to hospice with end stage COPD.
The 12/6/17 facility hospice care plan documented pertinent interventions of hospice nurse and certified nurse aide (CNA) visited at least once a week, hospice chaplain and social worker visited monthly, refer to hospice care plan and collaborate with hospice staff regarding the resident's care.
Review of the Resident #9's electronic medical record revealed the last nurse visits, CNA visits and the hospice plan of care from June 2019.
-There was no other current documentation from the hospice provider regarding current visits from the nurse, CNA, social worker or spiritual notes and the current hospice plan of care since June 2019.
IV. Staff interviews
Licensed practical nurse (LPN) #2 was interviewed on 8/27/19 at 1:53 p.m. She said when the hospice staff visited a resident on their services they checked in with the nurse on shift to be notified of any changes with the resident. She said the hospice interdisciplinary visits and plan of care were provided via secure email to the health information manager and she uploaded them to the electronic medical record so that all care staff had access to their information.
She said for Resident #9 the last updated information from hospice she saw uploaded in his medical record was from June 2019. She said she was not sure why the hospice information was not up to date in his electronic medical record.
The quality improvement specialist (QIS) and HIM were interviewed on 8/27/19 at 2:33 p.m. The HIM said she had been in the position since February but had worked at the facility in another capacity previous. She said she was emailed from the hospice company any pertinent records such as visits and plan of care securely about one to two times a month. She said she then uploaded the information downloaded from her secured email into the resident's electronic medical record.
She said for Resident #9 she had not uploaded his hospice records sent to her via email by the hospice company in July and August 2019. She said she was behind on her work and had not reached out to her consultant or facility staff to assist her. She said it was important to ensure Resident 9's hospice information was current for the coordination of his care with the facility staff and physicians.
The QIS said the hospice and facility should have had a contract in place to ensure the care provided by each entity was clearly defined. He said he told the facility to get the contract in place but it had not been done before survey started on 8/26/19.
He said he implemented with the hospice providers and the facility staff for the resident's hospice information to be emailed securely to both the director of nursing and the HIM in order to ensure that it was uploaded and current.
V. Facility follow-up
The current hospice plan of care and missing visits from the hospice interdisciplinary team was provided to the by the hospice company to the facility and was uploaded to Resident #9's electronic medical record by the HIM on 8/28/19.
CONCERN
(E)
Potential for Harm - no one hurt, but risky conditions existed
Infection Control
(Tag F0880)
Could have caused harm · This affected multiple residents
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** II. Failed to implement appropriate hand hygiene during medication administration.
A. Professional standards
The Centers for Dis...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** II. Failed to implement appropriate hand hygiene during medication administration.
A. Professional standards
The Centers for Disease Control and prevention (CDC) Hand Hygiene in Healthcare Settings, last updated 4/29/19, retrieved from https://www.cdc.gov/handhygiene/providers/index.html, included the following recommendations : Multiple opportunities for hand hygiene may occur during a single care episode. Following are the clinical indications for hand hygiene: Use an alcohol-based hand sanitizer (ABHS) immediately before touching a patient, before performing an aseptic task or handling invasive medical devices, before moving from work on a soiled body site to a clean site on the same patient, after touching a patient or a patient's immediate environment, after contact with blood, body fluids or contaminated surfaces, and immediately after glove removal. Wash with soap and water when hands are visibly soiled, after caring for a person with known or suspected infectious diarrhea, or after known or suspected exposure to spores.
B. Facility policy and procedure
The Hand Hygiene policy and procedure, revised August 2015, provided by the quality improvement specialist (QIS) on 8/29/19 at 4:30 p.m. documented the following: All personnel shall be trained and regularly in-serviced on the importance of hand hygiene in preventing the transmission of healthcare-associated infections. Single use disposable gloves should be used before an aseptic procedure, when anticipating contact with blood or body fluids; and when in contact with a resident, or the equipment or environment of a resident who is on contact precautions. Wash hands before applying non-sterile gloves and after removing them.
The Medication Administration policy and procedure, dated 9/30/13, provided by the QIS on 8/29/19 at 4:30 p.m. documented the following: Wash hands or use hand sanitizer prior to medication preparation for each medication pass. If direct resident contact is made, the nurse must wash hands. Do not touch oral medications, topical medications, ointments or creams.
C. Observation
Registered nurse (RN) #1 was observed on 8/28/19 at 7:18 a.m. during medication pass. RN #1 used alcohol-based hand sanitizer (ABHS) and then donned gloves. She said she wore gloves because she had a hard time popping the pills out of the cardboard bubble pack. She removed the medication cart keys from her scrub top pocket. She touched the computer, the mouse, the top of the cart, the medication cart handles and medication cards. She removed the residents medication cards from the cart and laid them on top. She then held the blister pack and popped the medication out in to her gloved hand, which was contaminated by previous touched items. She them placed the medication into a souffle cup. She followed the same technique for the next three medications. She then locked the medication cart and asked the resident if he would like milk to take his medications. With the same gloved hands, she removed the keys from her pocket and unlocked the nourishment room door. She opened the refrigerator and poured a cup of milk for the resident. She removed the gloves in the nourishment room, and did not perform hand hygiene. She grabbed the cup around the lip of the drinking surface and gave it to the resident.
RN #1 was observed again on 8/28/19 at 7:46 a.m. She used ABHS and then donned gloves. She used her gloved hand to remove the keys from her pocket. She touched the computer, the mouse, the top of the cart, the medication cart handles and medication cards. She removed the residents medication cards from the cart and laid them on top. She then held the blister pack and popped the medication out in to her gloved hand, which was contaminated by previous touched items. She them placed the medication into a souffle cup. She followed the same technique for the second medication. She then locked the cart and walked to the residents room. With the same gloved hands she knocked on the residents door. She entered the room and removed her gloves at the bedside before giving medications to the resident. She did not perform hand hygiene until after the medications were administered to the resident.
RN #1 was observed a third time on 8/28/19 at 5:01 pm. While she was preparing to check a resident's blood sugar. She donned gloves and removed an alcohol wipe and a 4x4 gauze from the cart. She walked to the common area where the resident was sitting. She used her gloved hand to push her glasses on to her nose and then scratched her arm with the same gloved hand. Without changing gloves or performing hand hygiene, she wiped the residents finger with the alcohol wipe and used the gauze to wipe away the first drop of blood. She then held the residents finger and collected the sample. She again used gauze to apply pressure to the bleeding finger. She failed to do hand hygiene and don new gloves after touching her glasses and scratching her arm.
D. Record review
The RN training log was provided by the QIS on 8/29/19 at 4:30 p.m. It documented RN #1 had received hand hygiene training on 8/14/19.
The skills check off form was provided by the QIS on 8/29/19 at 4:30 p.m. It documented that RN #1 was trained on handwashing, hand gel and glove use on 8/14/19 with satisfactory results. The document was signed and dated by RN #1.
E.Staff Interviews
The director of nursing (DON) and the QIS were interviewed on 8/29/19 at 12:00 p.m. The DON said when a nurse was preparing medications they should wash their hands and not touch the medication with their bare hands. The QIS said if a nurse chose to wear gloves, the only surface they should be touching was the medication card while the pill was being removed from. The QIS said if they touch any other surface they were to remove the gloves and perform hand hygiene before donning new gloves. The QIS said he would have to talk to the nurse in question and ask her why she was wearing gloves to pass medications. He said the nurse should not have worn gloves for the medication pass.
The staff development coordinator (SDC), who was also the infection control preventionist, was interviewed on 8/29/19 at 1:30 p.m. She said the facility did hand hygiene training with the annual competencies, during the skills fair every three months, and during spot checks. She said staff should be washing their hands before and after donning gloves. She said if a nurse chooses to wear gloves the nurse should only be touching the medication card and nothing else.
Based on observations, interviews and record review, the facility failed to maintain an infection control program designed to provide a safe, sanitary and comfortable environment to help prevent the development and transmission of disease and infection.
Specifically, the facility failed to:
-Follow appropriate surface contact times with a disinfectant and perform hand hygiene with routine cleaning; and
-Implement appopriate hand hygiene during medication pass.
Findings include:
I. Follow appropriate surface contact times with a disinfectant and perform hand hygiene with routine cleaning.
A. Professional reference
The Centers for Disease Control and Prevention (2019) Healthcare Environmental Infection Prevention and Control, retrieved from: https://www.cdc.gov/hai/prevent/environment/index.html. It read in pertinent part,
-Throughout healthcare, the physical environment represents an important source of pathogens that can cause infections or carry antibiotic resistance.Sometimes, the healthcare environment is a primary source of germs. Consider that molds can be present on wet or damp surfaces or materials, and bacteria can be present in plumbing fixtures including sink drains or ice machines. -The way that humans interact with the healthcare environment also plays a role. For example, when a healthcare worker fails to wash their hands, they might touch and contaminate a piece of equipment or environmental surface; in turn the equipment or surface could wind up exposing a patient to pathogens.
-These examples illustrate the importance of environmental infection prevention and control in the healthcare setting. Water and environmental surfaces are two intersecting parts of the healthcare environment that contribute to the spread of antibiotic resistance and healthcare associated infections.
B. Manufacturer recommendations for directions of use of the disinfectant spray
The manufacturer's recommendation for directions of use for the disinfectant spray, undated, was provided by the quality improvement specialist (QIS) on 8/29/19 at 4:22 p.m.
It read in pertinent part, To clean and disinfect hard, non-porous surfaces: For heavily soiled areas, clean before disinfecting. Thoroughly wet hard, non-porous for 10 minutes, then rinse and wipe clean.
C. Observations of housekeeping staff on 8/29/19
At 11:24 a.m. housekeeper (HK) #1 was observed cleaning room [ROOM NUMBER]. She donned gloves without performing hand hygiene previously and went into the bathroom with two clean rags. There was a brown substance on the base of the right side of the toilet. She sprayed the disinfectant directly onto the toilet seat, under the seat and base of the toilet. She immediately wiped the disinfectant with a rag starting on the toilet seat, the bowl rim and then cleaned the base of the toilet. The brown substance still remain at the base of the toilet even after she cleaned the toilet. She took the rag out of the bathroom and disposed of it on her cart.
She doffed her gloves and donned new gloves without performing hand hygiene to clean the rest of the room. She did not follow the manufacturer's instructions to spray disinfectant directly on the surface ensuring thorough saturation to remain wet for 10 minutes (see manufacturer recommendation above) before wiping up it up. After cleaning room [ROOM NUMBER], she doffed her gloves and placed them in the trash and proceed to clean another residents room without performing hand hygiene.
At 11:35 a.m. HK #1 was observed cleaning room [ROOM NUMBER]. She donned gloves without performing hand hygiene previously and went into the bathroom with two rags. She cleaned the sink area of the bathroom with one rag and left it on the counter after cleaning. She sprayed the disinfectant directly onto the toilet seat, under the seat and base of the toilet. She immediately wiped the disinfectant with a rag starting on the toilet seat, the bowl rim and then cleaned the base of the toilet.
She then placed the rag she cleaned the toilet with onto the sink area where she had just cleaned to take the trash out of the bathroom. She took the two rags out of the bathroom once she emptied the trash and placed them in a bag on her cart. She did not change her gloves and proceeded to clean room [ROOM NUMBER]. After cleaning the room, she doffed her gloves and placed them in the trash and proceeded to clean another resident room without performing hand hygiene.
D. Staff interviews
The maintenance service director (MSD) was interviewed on 8/29/19 at 12:31 p.m. He said he managed the housekeeping, laundry and maintenance departments. He said the housekeeping manager was on vacation and he was not available. He said the previous housekeeping manager worked in medical records currently so she would be able to answer procedural questions on how to clean the room.
He said the representative from the chemical company came in once a month to check the chemicals the facility was using to disinfect and clean the resident rooms. He said most of the housekeepers had been working at the facility for several years so they did not require additional training on how to clean and use the chemicals. He said when a housekeeper started, during initial training they were provided competency based training on how to clean the resident rooms.
The health information manager was interviewed on 8/29/19 at 12:41 p.m. She said previous to starting her position in medical records, she was the housekeeping manager for about five years. She said the correct procedure to clean the room was to start in the bathroom where two rags were used, one for sink area and one for the toilet. She said after the sink was cleaned the rag was discarded into a bag and then the toilet was cleaned with disinfectant sprayed directly on it and wiped immediately. She said the rag to clean the toilet was placed in the bag and removed from the room. She said after the bathroom was cleaned and disinfected, the housekeepers were to change their gloves with performing hand hygiene in between before proceeding to clean the rest of the room. She said once the room was cleaned then the housekeepers doffed their gloves and performed hand hygiene before cleaning the next room. She said when she managed the department she would provide on the spot training if she saw the rooms were not being cleaned correctly but did not document or provide competency based training after the initial training. She said she did not know what the surface contact time was the disinfectant chemical the housekeepers used and it was being used when she was supervising the department.
The staff development coordinator #1 was interviewed on 8/29/19 at 1:02 p.m. She said she was the infection control preventionist for the facility and oversaw the program. She said she had started a month previous in the position. She said she tracked the infections of the facility and had provided training to staff during monthly all staff meetings and skills fair training held every three months on hand hygiene, specifically when to use alcohol based hand rub or wash their hands.
She said she did not know the surface contact time for the chemical used by the housekeepers. She said based on the observations (see above) that there could be a potential for spread of a healthcare associated infection. She said moving forward she would be working with all the departments to provide education on infection control prevention.
CONCERN
(E)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0943
(Tag F0943)
Could have caused harm · This affected multiple residents
Based on record review and interview, the facility failed to ensure an effective training program for all staff included training on abuse, neglect, exploitation, and misappropriation of resident prop...
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Based on record review and interview, the facility failed to ensure an effective training program for all staff included training on abuse, neglect, exploitation, and misappropriation of resident property.
Specifically, the facility failed to ensure five employees received abuse training in the last 12 months after their initial training upon being hired.
Findings include:
I. Facility policy and procedure
The Abuse Training policy, undated, was provided by the nursing home administrator (NHA) on 8/29/19 at 3:00 p.m. It documented in pertinent part,
-Training programs are completed upon hire on abuse and neglect, The Elder Justice Act and resident rights.
-Abuse prevention and The Elder Justice Act training for all staff is to be completed semi-annually.
II. Record review
Review of the course training data from 8/28/18 to 8/28/19 revealed that five staff had not had abuse and neglect training in the past 12 months:
-Staff development coordinator (SDC) #2 hired on 9/4/12;
-Laundry worker (LW) #1 hired on 6/14/18;
-Certified nurse aide (CNA) #1 hired on 1/13/11;
-Housekeeper (HK) #1 hired on 3/6/12; and
-Licenced practical nurse (LPN) #5 hired on 1/20/14.
III. Staff interviews
The SDC #2 was interviewed on 8/28/19 at 9:19 a.m. She said she had started her position about a month previous but had worked in the facility in another capacity. She said since starting her role she ensured the nursing staff had their competency training which included an inservice about the types of abuse and reporting requirements. She said in addition to her training the nursing staff completed computer based training at a minimum annually but she did not have access to the system. She said she did not keep track of other staff ' s abuse and neglect training and she said the director of nursing (DON) would know who kept track of it.
The DON was interviewed on 8/28/19 at 9:30 a.m. She said she did not keep track of all staff training of abuse and neglect training but the social service director (SSD) kept track of it and provided the abuse and neglect trainings at their all staff meetings.
The SSD was interviewed on 8/28/19 at 9:35 a.m. She said she presented abuse and neglect training at all staff meetings. She said the staff who attended, signed in as being present, but she overall, did not keep track of who attended each meeting.
The NHA was interviewed on 8/28/19 at 9:38 a.m. She said she thought the SDC kept track of all employee abuse and neglect training. She said she was going to keep track of the abuse and neglect training moving forward to ensure all staff had received the training wither in their all staff meetings held monthly, on the computer based system or any other abuse and neglect training provided by department managers.