CRITICAL
(J)
Immediate Jeopardy (IJ) - the most serious Medicare violation
Pressure Ulcer Prevention
(Tag F0686)
Someone could have died · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review and interviews, the facility failed to take timely and sufficient steps to implement interve...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, record review and interviews, the facility failed to take timely and sufficient steps to implement interventions to prevent the development of pressure injuries, affecting one (#29) out of one resident reviewed for pressure injuries out of 29 sample residents.
Resident #29 admitted to the facility with a stage 2 pressure ulcer to her left buttock and was identified as being at risk for pressure ulcer development related to multiple comorbidities including post-polio syndrome, adult failure to thrive, spinal stenosis, and fibromyalgia. Record review revealed Resident #29's pressure ulcer to her left buttock healed over three times.
The facility failed to have a system in place to identify and review residents at risk for pressure ulcer development and pressure ulcer re-development. As a result, the facility failed to put appropriate interventions in place timely for Resident #29, which contributed to the development of a pressure ulcer. She developed a pressure ulcer to her coccyx which worsened to a stage 4 pressure ulcer.
Although the wound to the left buttock healed, Resident #29 developed a wound to her left coccyx, documented on 6/20/19 as a deep tissue pressure injury (DTPI), which never healed and worsened to a stage 4 pressure ulcer.
Record review and staff interviews revealed the facility failed to implement appropriate interventions timely. As Resident #29 continued to decline and spent more time in bed, staff did not recognize a need for increased nutritional support when Resident #29's meal intake decreased as well. The pressure reducing overlay mattress which was provided to Resident #29 was ineffective, and likely contributed to the pressure ulcer development. The staff did not implement an alternating air mattress until the wound had worsened on 8/22/19 (over a two month period since the development of the wound), which created an immediate jeopardy situation with the likelihood of causing serious harm to additional residents if not immediately corrected.
Findings include:
I. Immediate jeopardy
A. Findings of immediate jeopardy
Resident #29 admitted to the facility with a stage 2 pressure ulcer to her left buttock. She had multiple comorbidities including post-polio syndrome, failure to thrive, fibromyalgia, and spinal stenosis which placed her at a higher risk for pressure ulcer development and redevelopment.
Nursing staff did not consistently review residents at risk for pressure ulcers for effective interventions, such as residents who had changes in condition including poor intake and spending more time in bed, as evidenced by record review, staff interviews and the resident's skin assessments, which did not always accurately describe the condition of the resident's skin. The wound assessments completed by the wound nurse did not include all the information needed to comprehensively assess the overall status and health of the resident's wounds.
Finally, nursing staff did not review as an interdisciplinary team (IDT) systemic conditions affecting wound healing, such as nutritional and fluid support, or refusal of care including refusing to eat and to be repositioned in bed, implement preventative measures timely; and update care plans to reflect the current status of Resident #29's wound, which contributed to wound redevelopment which advanced to a stage 4 pressure ulcer.
Observation, record review, and interviews with staff and health professionals revealed the facility failed to have an effective system in place to implement and monitor preventative measures for residents who were assessed to be at risk for pressure ulcers, which created a situation of immediate jeopardy with the likelihood of causing serious harm to additional residents if not immediately corrected.
On 10/10/19 at 3:25 p.m., the nursing home administrator (NHA) was notified of the findings above, which created a situation of immediate jeopardy for serious harm.
B. Plan to correct the immediate jeopardy situation
On 10/10/19 at 7:50 p.m. the NHA submitted a final plan to remove immediate the jeopardy situation. It read as follows:
Resident specific: In regard to (Resident #29) the resident is receiving daily wound care. Peri care is provided every 2 hours. Weekly wound measurement and skin assessment done. This resident is on a low air loss alternating pressure mattress. Hospice as well as the facility wound consultants have evaluated this resident and provided their recommendation which the facility has followed. Repositioned every 1-2 hours. This resident is asked prior to each meal what her preference of food and drink are. On October 9, 2019 RD (registered dietitian) did a nutritional assessment. The Assistant DON (director of nursing) has spoken with this resident as well as her family regarding her wound treatment and poor nutritional intake. Hospice has also spoken and discussed her wound issues with the resident and daughter.
All residents will have a skin assessment, nutritional assessment and Braden (tool used to determine risk for pressure ulcer development) scale assessment completed by 2:00 p.m. on October 11, 2019. Any resident that is identified as a high risk for pressure ulcer development will have an individualized intervention established by 4:00 p.m. on October 11, 2019.
All staff will be in serviced on pressure ulcer prevention interventions and review interventions for all residents receiving wound care will be started 10/10/19 and all staff will be educated and in serviced prior to the start of their shift.
C. Removal of immediate jeopardy
On 10/10/19 at 8:30 p.m., the nursing home administrator (NHA) was notified the immediate jeopardy had been removed based on the plan to complete skin, Braden, and nutritional assessments on each resident, with appropriate interventions for those identified. However, based on observation, interviews, and record review, deficient practice remained at a G (harm) level.
Although the facility had interventions in place during the survey, the following did not occur until after the coccyx wound worsened and then developed to a stage 4 pressure ulcer:
-The care plan documented to turn the resident every 2 hours and provide peri-care every 1-2 hours. However, the facility did not implement any new interventions when Resident #29 declined to be turned and was spending more time in bed (see wound notes and progress notes).
-The hospice wound specialist did not assess Resident #29's wound until it worsened (see health status note 8/23/19).
-The registered dietitian or facility staff did not identify and assess Resident #29's decreased meal intake until she had severe weight loss of 13.4% (see meal intake record for April and May 2019 and nutrition/dietary note 6/13/19).
-Finally, the facility did not place Resident #29 on an alternating low air loss mattress until after the wound had worsened on 8/22/19 (see health status note 8/23/19).
II. Facility policy and procedure
The Wound Management policy, revised on 2/20/18, was provided by the director of nursing (DON) on 10/9/19 at 5:30 p.m. It read in pertinent part, the facility's wound management program identified staff participation and accountability to include:
-A qualified RN (registered nurse) is responsible for weekly wound measurements.
-All caregivers are involved in prevention and identification of skin integrity issues.
-All caregivers are to observe resident skin integrity during the daily provision of the residents' personal care.
-Comprehensive assessment of any wound will include:
-Location of Wound;
-Length, width, and depth measurements recorded in millimeters;
-Direction and Length of tunneling and undermining;
-Appearance of the wound base;
-Type and percentage of tissue in wound;
-Drainage amount and characteristics including color, consistency and odor;
-Appearance of wound edges; and
-Description of the peri-wound (area around the wound bed) condition or evaluation of the skin adjacent to the wound.
-Wound Management principles provide the basis of effective wound care and should be considered in development of the plan of care.
-Wound Management principles include, and are not limited to:
-Control or elimination of causative factors such as:
-Pressure;
-Shear;
-Friction;
-Moisture; and
-Circulatory impairment.
-Provision of systemic support to reduce existing and potential co-factors such as:
-Nutritional and fluid support per assessed need;
-Control of systemic conditions affecting wound healing per medical plan of care;
-Documentation and Care Planning;
-Goals of the wound care plan are collaboratively determined with the resident, family and interdisciplinary team; and
-Currently, it is the facilities protocol to have the MDS (minimum data set) coordinator created the initial care plan and subsequent updates.
-Risk factors and interventions are documented within the care plan including, but not limited to:
-Impaired mobility;
-Need for pressure relief such as support surfaces, repositioning, and pressure relieving devices; and
-Nutritional status.
-Preventative measures and interventions shall include, but not limited to: Use air mattress to relieve pressure, especially to those who are bed bound or spend extended periods of time in bed.
III. Professional References
The National Pressure Ulcer Advisory Panel (2017) NPUAP Pressure Injury Stages, retrieved from:
http://www.npuap.org/resources/educational-and-clinical-resources/npuap-pressure-injury-stages/ revealed the following pertinent information:
Pressure injuries can be numerically staged (i.e. Stage 1, 2, 3, or 4), if the type of tissue injured can be visualized or directly palpated (e.g., in case of Stage 4 when exposed bone is visible or directly palpated). The NPUAP also recognizes the very real clinical limitations of being able to visualize the types of tissue exposed by injury. Based on these limitations, the NPUAP staging system provides two additional options: (1) unstageable pressure injuries to address situations where the wound base is obscured by slough and/or eschar and (2) Deep Tissue Pressure Injury (DTPI) where the skin may still be intact, but is purple or maroon indicating deeper tissue damage has occurred. After DTPIs evolve, or unstageable pressure injuries are debrided, these injuries can be numerically staged. Due to the unique anatomy in mucosal membranes, pressure injuries in these tissues should be noted, but can never be staged.
-In many situations, the level of tissue injury can be accurately assessed with visual inspection. However, the tissue surrounding the visible injury should be assessed for changes in sensation (e.g., pain), temperature (e.g., warmer from inflammation, colder as tissues die), firmness (firmer or boggy with tissue destruction and edema), color (signs of inflammation consistent with skin tone) and drainage expressed from surrounding tissues as they are palpated. This more thorough assessment of surrounding tissue may alert the clinician to more extensive damage than is readily visible. These additional findings should be described and documented.
VI. Failure to prevent redevelopment and worsening of a pressure ulcer to a stage 4.
A. Resident #29
1. Resident status
Resident #29, age [AGE], was admitted on [DATE]. According to the October 2019 computerized physician orders (CPO), diagnoses included protein calorie malnutrition, post-polio syndrome, spinal stenosis, fibromyalgia, and adult failure to thrive.
The 9/6/19 minimum data set (MDS) assessment revealed the resident was moderately impaired with a brief interview for mental status (BIMS) score of 12 out of 15. She exhibited the behavior of poor appetite or overeating nearly every day. She exhibited delusions and hallucinations, but did not exhibit verbal or physical behavioral symptoms or resist care (contrary to record review and interview - see below). She was totally dependent on two staff for bed mobility, transfers, dressing, and toilet use. Her weight was 118 pounds (contrary to the health status note dated 8/23/19 - see below). She had one stage 1 or greater over a bony prominence. She had two stage 2 pressure ulcers and one unstageable pressure ulcer. She was always incontinent of bowel and bladder.
2. Observation and staff interview
Cross-reference F880, failed to perform proper hand hygiene prior to, during and after wound care to prevent possible contamination of the resident's wound.
On 10/9/19 at 10:08 a.m. licensed practical nurse (LPN) #4 was observed providing wound care to Resident #29's coccyx. She had cleansed the surface of an over bedside table, draped the table, and placed all supplies on the clean field. Upon entering the room, certified nurse aides (CNAs) #1 and #3 assisted the resident to her right side and assisted with pulling the resident's brief down, while LPN #4 performed hand hygiene. LPN #4 washed her hands for eight seconds, turned the sink off with her bare hands and grabbed paper towels and dried her hands. LPN #4 donned gloves and removed the dressing from Resident #29's sacrum (area between the lumbar and coccyx bone). There was a large gaping wound to Resident #29's sacrum with a large amount of serosanguineous (thin watery pink or red fluid that contains red blood cells) drainage.
LPN #4 said Resident #29's wound was measured weekly by the assistant director of nursing (ADON). LPN #4 doffed her gloves, and donned clean gloves. She did not perform hand hygiene. Then she cleansed Resident #29's wound with normal saline and a 4 x 4 gauze pad.
Resident #29's coccyx wound bed was pink and red. It had a small amount of adherent slough (dead tissue), yellow/black/brown slough located at 12 o'clock of the wound. LPN #4 doffed her gloves and donned new gloves. She did not perform hand hygiene. She used a 4x4 to apply and dab Flagyl (antibiotic powder) to the wound bed, then placed calcium alginate rope (highly absorbent dressing) to the undermining (a pocket beneath the skin at the wound edge) areas. There was undermining almost completely surrounding the wound.
LPN #4 said there was a small portion to the top of the wound which did not have undermining, but it was worse towards 5-6 o'clock of the wound. After applying calcium alginate to the wound she placed a Medihoney coated absorbent dressing (calcium alginate impregnated with 100% Leptospermum or Manuka honey) to the wound and then covered with Mepilex border (absorbent foam dressing).
After repositioning the resident, LPN #4 changed the dressing to the resident's left lower extremity, doffed her gloves, washed her hands for seven seconds, shut the water off with her bare hands and grabbed paper towels to dry her hands. LPN #4 said she needed to apply additional dressings to Resident #29's arms as they were weeping.
3. Record review
a. Care plans
The skin care plan, initiated 9/5/18 and last revised on 5/30/19, revealed the resident admitted with a stage 2 wound to her left buttock which healed 11/15/18. On 1/18/19 the left buttock wound reopened and resolved on 1/24/19. Then on 4/23/19 the resident had currently a suspected deep tissue injury to her left buttock. Interventions included:
-Administer treatment as ordered;
-Assess/record/monitor wound healing weekly;
-Avoid positioning the resident on her left buttock if possible;
-Educate family and resident as to causes of skin breakdown;
-Instruct/assist the resident to shift weight in wheelchair at least every 15 minutes;
-The resident needed assistance to turn/reposition at least every 2 hours;
-Monitor nutritional status;
-The resident required pressure relieving/reducing device on bed (air mattress); and
-If the resident refused treatment, confer with the physician IDT and family to determine why and try alternative methods to gain compliance.
There were no revisions made to this care plan to include the reopening of left buttock wound stage 2 which was documented in the wound-weekly observation tool on 4/5/19 and when it resolved, the current stage of the resident's pressure ulcer on the coccyx which was a stage 4 observed during survey; and there was no update to the care plan to include an alternating low air loss mattress which was not placed until after the residents wound to her coccyx worsened from a documented shearing (see weekly wound tool 6/20/19) to a stage 4 pressure ulcer.
The nutritional care plan, initiated 9/6/18 and revised on 9/4/19 revealed the resident had a potential nutritional problem related to unhealed pressure ulcers. Interventions included to weigh the resident weekly for the first month and then monthly per facility protocol, registered dietitian (RD) to evaluate and make diet change recommendations as needed (PRN), and provide and serve diet as ordered.
There were no revisions made to this care plan to include the resident's weight loss.
The activities of daily living (ADL) care plan, initiated on 9/5/18 and revised on 9/4/19 revealed the resident required total assistance by two staff to turn and reposition in bed every 2 hours, with dressing, personal hygiene, transfers, and toileting which included to be checked and changed every 2 hours.
The care plan also revealed the resident had an alternating low air loss mattress; however, it did not document when the mattress was initiated, and skin/wound notes revealed it was not added until the wound worsened (see below).
b. Meal intake record
April 2019
Review of the April meal intake record 4/1/19-4/30/19 revealed the resident accepted 64 meals, she refused her meal 11 times, ate 0 (zero) - (to) 25% (percent) 45 times, ate 26-50% 12 times, ate 50-75% one time, ate 76-100% six times, and it was documented as not applicable 11 times; which meant the resident nutritional intake was less than 50% more than half of the time.
May 2019
Review of the May meal intake record 5/1/19-5/31/19 revealed the resident accepted 50 meals, she refused her meal 27 times, ate 0-25% 39 times, ate 26-50% five times, ate 50-75% five times, ate 76-100% one times, and it was documented as not applicable 11 times; which meant the resident nutritional intake was less than 50% more than three (3) fourths (4) of the time.
c. Progress notes, skin/wound notes, and wound-weekly observation tool
The restorative program note, dated 3/11/19 at 1:14 p.m., documented program and equipment needs for the month of February 2019, the resident continued on a nursing level II program with the goal to prevent further loss of range of motion (ROM), exercises included active/passive ROM as the resident was unable to move extremities unassisted, she used a Hoyer lift for transfers, she was a total assist with meals, and she had a hi/low bed with an air mattress (air overlay mattress).
The Wound-Weekly Observation Tool, dated 4/5/19 at 4:12 p.m., revealed the resident had a pressure ulcer stage 2 to the left buttock which was measured as a cluster with two open areas. The wound measured 1.6 cm (centimeters) x (by) 0.7 cm, peri-wound was within normal limits (WNL) and wound edges were irregular. The treatment was to apply calmoseptine (medicated cream) until resolved.
-The resident had refused to be repositioned off her buttocks. When attempted to reposition the resident only tolerated for a few minutes and requested to be back on her back/buttocks due to comfort. The resident's family was notified; however, there was no documentation of the resident or the family being provided education of the risks of the pressure ulcer worsening on the Wound-Weekly Observation Tool or alternate intervention implemented.
The skin/wound note dated 4/9/19 at 12:00 p.m., revealed the resident's left buttock was resolved.
The progress note, dated 4/23/19 at 10:55 a.m., revealed the resident had a wound to her left buttock which measured 3.2 cm x 2.0 cm; it was a deep purple raised discoloration to left buttock which was the same area which had previous openings. The treatment provided was calmoseptine and border foam dressing.
The Wound-Weekly Observation Tool dated 4/23/19 at 11:49 a.m. documented the left buttock wound was suspected deep tissue injury (SDTI) with 100% necrotic (brown, black, leather, scab-like) tissue present. The wound was dry with no drainage. The peri-wound had old scar tissue from a previous wound.
-The resident had refused to be repositioned off her buttocks, when attempted to reposition the resident only tolerated for a few minutes and requested to be back on her back/buttocks due to comfort. The resident's family was notified; however, there was no documentation of the resident or family being provided education of risks of pressure ulcer worsening on the Wound-Weekly Observation Tool or the progress notes.
The physician note dated 4/26/19 revealed the resident continued to decline and at previous visit she was referred to hospice but was declined.
The skin/wound note dated 5/3/19 at 3:25 p.m., revealed the purple discoloration to the resident's left buttock was improving measured 0.5 cm x 0.5 cm.
The restorative program note, dated 5/9/19 at 4:22 p.m., revealed the purple discoloration to the resident's left buttock measured 2.5 cm x 1.5 cm.
The following two skin/wound notes dated 5/14/19 and 5/17/19 did not address the resident's left buttock.
The skin/wound note, dated 5/23/19 at 4:44 p.m., revealed the purple discoloration to the resident's left buttock now had a small opening just medial to the purple discoloration and it looked as though the dressing peeled a piece of dry flaky skin from the wound.
The Wound-Weekly Observation Tool, dated 5/23/19 at 4:47 p.m., revealed the resident's wound was improving and measured 1.5 cm x 0.6 cm. The wound continued to have 100% necrotic tissue.
The plan of care note, dated 5/30/19 at 11:03 a.m., revealed the resident had only been staying up out of bed for a short time and staff reported the resident refused to turn and reposition in bed. She was on an air mattress and palliative care for pain. She was refusing to eat and drink and had a resolving suspected deep tissue injury.
-There was no mention of an IDT review of the resident's poor nutritional intake, refusal to be turned, the resident becoming bed bound, education provided to the resident or family of the potential wound worsening, and no notification to the physician or family documented in the care plan note.
The health status note, dated 6/1/19 at 5:43 a.m., revealed hospice was in on 5/31/19 to evaluate the resident (she was placed on hospice 6/5/19).
The skin/wound note, dated 6/20/19 at 3:38 p.m., revealed the resident's left outer buttock had purple discoloration and was almost resolved. However, there was a new area of purple/red discoloration to the resident's left coccyx area, measuring 2.7 cm x 1.4 cm. The treatment orders were to cleanse the area with normal saline, pat dry, skin prep peri-wound, apply calmoseptine, and cover with border foam daily. The resident continued on an air mattress, repositioned every 2 hours and continued on hospice services. There was no documentation of any IDT review for further interventions.
The skin/wound note, dated 7/1/19 at 10:53 a.m., revealed the resident had a new stage 2 wound to right inner buttock which measured 1.0 x 1.2 cm. She also had several cuts/abrasions to her inner groin from wearing Attends briefs, and the plan was to leave the briefs unfastened.
The skin/wound note, dated 7/4/19 at 12:46 p.m., revealed skin to the resident's left coccyx was sloughing (shedding) off.
The Wound-Weekly Observation Tool, dated 7/18/19 at 3:51 p.m., revealed the resident's left coccyx wound was pink and moist, surrounding tissue pink, and was documented as a shearing. Epithelial tissue present, with a scant amount of serous drainage, irregular with two open areas measured as a cluster with peeling skin between the two openings. The wound measured 2.0 cm x 4.0 cm.
The Wound-Weekly Observation Tool, dated 8/9/19 at 12:53 p.m., revealed the resident's left coccyx wound had two distinct open areas with 10% necrosis, documented as shearing. It measured 2.5 cm x 1.5 cm x 0.1 cm. It was documented as worsening, hospice nurse to report findings to the hospice physician in their next IDT meeting.
The skin/wound note, dated 8/18/19 at 15:10 p.m., revealed the resident's coccyx wound had eschar, and an area with tan/gray stringy tissue and what appeared to be an open cavity underneath. The resident was encouraged to lie on her side which she did not like to do because it caused pain in her neck.
-Education was provided to the resident as her wound was getting worse, but there was no immediate action taken to provide any other pressure relief interventions such as treatment changes until 8/20/19.
The Wound-Weekly Observation Tool, dated 8/20/19 at 11:31 a.m., revealed the resident's left coccyx wound was documented as SDTI and was worsening. The wound was documented as one wound it measured 2.0 cm x 2.5 cm x 1.0 cm. It had a tunnel measuring 1 cm at 7 o'clock. The wound bed had 75% slough. There was a small amount of serosanguineous and tan colored drainage. The peri-wound was pink and scarred. New treatment orders were obtained to cleanse the area with normal saline (NS), pat dry, apply Medihoney (paste or gel) to the wound bed, lightly pack tunneled area with gauze packing, and cover with bordered foam dressing daily.
The skin/wound note, dated 8/21/19 at 12:06 p.m., revealed the resident's coccyx wound was worsening and staff discussed with the hospice nurse options to help relieve pressure and assist with wound healing/prevention. The resident had been on air overlay mattress, and could benefit from an alternating low air loss mattress (pressure relieving mattress). The hospice nurse agreed and ordered the mattress.
-Although on 8/21/19 the alternating air mattress was discussed and then implemented on 8/22/19, it was not implemented until after the resident had acquired multiple pressure ulcers which healed over. One pressure ulcer (coccyx) developed into a stage 4 ulcer because the facility failed to implement the preventative mattress timely for Resident #29 as she had a known history to lie on her back (see above), had become bed bound (see above and hospice physician interview below), and had poor nutritional intake and multiple comorbidities, which placed her at greater risk for pressure development.
The health status note, dated 8/23/19 at 9:10 a.m., revealed the resident and family agreed to have a wound care specialist observe the wound and provide recommendations. New treatment orders were obtained. The coccyx wound measured 2.0 cm x 3.0 cm x 1.0 cm. There was undermining from 6 o'clock to 1 o'clock that measured 1.4 cm. The resident weight was down to 106 pounds. The resident's mattress was changed to an alternating low air loss mattress on 8/22/19.
-The coccyx wound was not staged in the 8/23/19 health status note.
The resident's wound continued to worsen over the next couple of months as documented in the skin/wound notes (see below).
The skin/wound note, dated 8/27/19 at 1:25 p.m., revealed the wound to Resident #29's coccyx had a strong foul odor and the wound bed was black and stringy.
The skin/wound note, dated 8/30/19 at 4:34 p.m., revealed the wound to Resident #29's coccyx was worsening, had 100% necrotic tissue present and the wound measurements were increasing in size. New wound treatment orders were obtained.
The skin/wound note, dated 9/12/19 at 12:24 p.m., revealed the wound to Resident #29's coccyx continued to worsen, and measurements of the wound continued to increase daily. The wound continued to have a large amount of brown drainage. Staff were changing the wound dressing more than daily. The wound had large pieces of tissue sloughing off, black/brown in color. The wound had odor even though they had started applying Flagyl (antibiotic powder) to the wound.
The skin/wound note, dated 9/17/19 at 3:23 p.m., revealed the wound to Resident #29's coccyx continued to worsen as evidenced by the wound measurements increasing.
The skin/wound note, dated 9/26/19 at 4:59 p.m., revealed the wound was showing improvements as it had less necrotic tissue 45% and 55% granular tissue; however, it continued to have a large area of undermining to most of the wound except at 6 o'clock.
The skin/wound note, dated 10/3/19 at 2:01 p.m., revealed the wound to Resident #29's coccyx had improved; however, at this point the wound was a stage 4 pressure ulcer (see Wound-Weekly Observation Tool below).
The Wound-Weekly Observation Tool (most current wound status during survey), dated 10/3/19 at 12:40 p.m., revealed Resident #29's coccyx wound was a stage 4 pressure ulcer. It measured 7.5 cm x 8.5 cm x 1.5 cm, it had undermining from 9-12 o'clock equal to 4.0 cm, 12-3 o'clock equal to 3.5 cm, 3-6 equal to 3.0 cm, 6-9 o'clock equal to 3.6 cm. The wound had granular tissue and slough present, the slough covered 35% of the wound, and it had a large amount of serosanguineous drainage. The peri-wound had induration (associated with inflammation, a hardened mass or formation) right border near right buttock, three purple discolorations with small opening measured 6.0 cm x 3.5 cm.
d. Air overlay mattress
According to Direct Supply (2018) Air Overlays vs. Mattresses, retrieved from https://www.directsupply.com/blog/air-overlays-vs-mattresses-which-is-best-for-my-resident:
Most air overlays only measure three inches thick, and are not nearly large enough to prevent a typical resident bottoming out. When this happens, all benefits of immersion are lost as the body's peak points of pressure will rest on the surface underneath, providing the ideal condition for pressure ulcers.
e. Nutrition/dietary note and weight loss
The nutrition/dietary note, dated 9/17/18 at 2:24 p.m., revealed the resident needed increased nutrient needs related to the demands of wound healing as evidenced by multiple wounds, plan to trial mighty shakes twice a day and offer current diet as tolerated. The resident's weight was 138 pounds and her body mass index (BMI) was 24.4.
The nutrition/dietary note, dated 3/8/19 at 4:12 p.m., revealed the resident was below the recommended amount for her fluids and the plan was to monitor for signs and symptoms of dehydration.
The nutrition/dietary note, dated 6/13/19 at 3:24 p.m., revealed the resident had a severe weight loss of 19 pounds in one month (13.4%), the resident was not eating or drinking and her intake was less than 50% of most meals. The resident did not have wounds, continue current diet and honor preferences, the resident was on hospice.
f. Braden scale
The Braden scale dated 9/4/18 revealed the resident was at risk for pressure ulcer development with a score of 15 (15-18 at risk, 13-14 moderate risk, 10-12 high risk, and nine or below very high risk).
The Braden scale dated 11/30/18 revealed the resident was a moderate risk for pressure ulcer development with a score of 13.
The resident's Braden scale score continued to decrease as the resident became more at risk for developing pressure ulcers. On 9/4/19 she was high risk for developing pressure ulcers with a score of 10.
g. Skin assessments
The skin assessment, dated 6/24/19 at 10:37 a.m., documented the resident's left buttock sore was resolved and applying calmoseptine as preventative; however, it did not address the new area to the left coccyx identified in progress notes and skin/wound documentation 6/20/19 (see above).
The skin assessment, dated 7/1/19 at 10:46 a.m., documented the resident had an open sore, stage 2 to right inner buttock; however, did not address the resident's coccyx wound.
The skin assessment, dated [TRUNCATED]
SERIOUS
(G)
Actual Harm - a resident was hurt due to facility failures
Deficiency F0865
(Tag F0865)
A resident was harmed · This affected 1 resident
Based on record review and interviews, the facility failed to ensure an effective quality assurance program to identify and address facility compliance concerns was implemented, in order to facilitate...
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Based on record review and interviews, the facility failed to ensure an effective quality assurance program to identify and address facility compliance concerns was implemented, in order to facilitate improvement in the lives of nursing home residents, through continuous attention to quality of care, quality of life, and resident safety.
Specifically, the quality assurance performance improvement (QAPI) program committee failed to:
-Identify systemic issues in its management for residents at risk for pressure ulcers to ensure they were consistently reviewed and appropriate interventions implemented to prevent the redevelopment of pressure ulcers;
-Ensure residents were reviewed consistently as an interdisciplinary team (IDT) to prevent unintended weight loss and activities of daily living (ADL) decline;
-Perform proper hand hygiene prior to, during, and after wound care treatment;
-Ensure clinical signs and symptoms (s/s) of an infection were identified and culture and sensitivity (C&S) were obtained prior to the start of an antibiotic; and
-Ensure the dietary department followed safe practices to prevent the potential of cross- contamination of food.
Findings include:
Cross-referenced citations
Cross-reference F686 failure to prevent the redevelopment of pressure ulcers.
Cross-reference F692 failure to review residents with unintended weight loss and ADL decline.
Cross reference F812 failure to follow safe practices to prevent the contamination of food.
Cross-reference F880 failure to perform proper hand hygiene during wound care treatment.
Cross-reference F881 failure to identify s/s of an infection and obtain C&S prior to the start of antibiotics.
Record review
Review of received QAPI program for the last quarter with the nursing home administrator (NHA) revealed the facility had been trying to retain staff and reduce agency use by offering paid training and sign on bonus.
However, the QAPI review failed to identify concerns for potential wound development, weight loss and ADL decline, infection control practices with wound care, antibiotic stewardship monitoring, and following safe practices to prevent the contamination of food.
QAPI staff interviews
The medical director was interviewed on 10/11/19 at 2:35 p.m. He said he was at the facility at least once a month, and he attended psychotropic review and QAPI quarterly. He said if the facility had any troubles he would give recommendation. He said if there was a problem for example with physician care he would step in and provide education to the physicians. He said no concerns related to care were brought to his attention last QAPI meeting, but they did discuss trying to get the residents vaccinated with influenza by the end of October or beginning of November. He said he was unaware of the immediate jeopardy regarding the development of wounds until just then, but planned to work with the facility as he felt they typically did a good job.
The NHA was interviewed on 10/11/19 at 3:00 p.m. He said the facility had quarterly QAPI reviewed and all department heads (nursing, social services, dietary, housekeeping, maintenance and activities), pharmacist and medical director attended. He said they would set goals, and review them to see if anything needed to be changed. He said the QAPI they reviewed staffing and they had trouble obtaining a night nurse. He said they even went on social media and they recently had turnover of three department heads; so for the last six months and last QAPI a couple of months ago, they had been focusing on staffing and recruiting for Certified nurse aides (CNAs), with paying for training, and offering sign on bonus. He said they were trying to reduce and or eliminate agency by January 2020.
-He said he believed resident care suffered when staffing was a problem, and they had asked staff what they wanted to try to get people to stay. He said he planned to help get the facility together to review and identify issues, and plan to improve communication and sharing amongst the staff. He said he was not too involved with the day to day clinical concerns because he did not have much input, but planned to work with the staff as they did not identify the concerns that were found during survey.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Grievances
(Tag F0585)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and interviews, the facility failed to ensure prompt efforts to resolve all resident grievances.
Specific...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on record review and interviews, the facility failed to ensure prompt efforts to resolve all resident grievances.
Specifically, the facility failed to ensure:
-Call light wait times were resolved for Resident #35; and
-Call light wait times were resolved for a group of individual residents.
Findings include:
I. Facility policies
1. The Call Light policy, dated 9/8/19 was provided by the social services director (SSD) on 10/9/19. It read, in pertinent part, The director of nursing (DON) or designee will complete a monthly audit to include: regular call light is answered within 5-7 minutes, bathroom call light is answered with 5-7 minutes, resident confirms call light is answered timely. The purpose of this audit is to be able to provide continuing education to all facility staff on the importance of answering call lights in a timely manner to improve overall quality care.
2. A copy of the undated Grievance policy was provided by the SSD on 10/9/19. It read, in pertinent part, The facility has designated its full-time SSD as the Staff Assignee to receive all grievances. The SSD will investigate the incident within three days of the grievance being reported and provide written findings and proposed solutions, if needed, to the complainant.
II. Resident status
Resident #35, age [AGE], was admitted on [DATE]. According to the October 2019 computerized physician orders (CPO), diagnoses included multiple sclerosis (MS), quadriplegia, neuromuscular dysfunction of the bladder, and depression.
The 9/27/19 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. She required total one-person assist for eating and total two-person assist for all remaining activities of daily living (ADL) that included bed mobility, transfers, dressing, toileting, and personal hygiene.
A. Resident interviews
Resident #35 was interviewed on 10/7/19 at 2:44 p.m. She said she had to wait 30-45 minutes for the call light to be answered.
Resident #35 was interviewed again on 10/9/19 at 1:00 p.m. She said it took the staff up to 30 minutes to answer the call light. When it was answered, only one staff member came and she required the assistance of two staff. She was told by the staff member who answered the call light they needed to get another person and took up to another 30 minutes for them to return.
B. Group interview
A group of seven residents were interviewed on 10/8/19 at 1:30 p.m. The group of residents said they were concerned with the call light response. The call lights were not answered timely and at times could be as long as 30 minutes to one hour before the light was answered.
C. Record review
The resident council minutes documented the following:
-7/25/19, .One resident mentioned that during the night shift, call lights were not being answered in a timely manner, as staff seemed to be on break at the same time and wondered why they did not stagger their breaks. Another resident said call lights were not answered during the night shift .
-8/29/19, .One resident reported that she still had difficulties with the aides on the evening shift answering the call light timely .
-9/26/19, .One resident reported he could not wait a long time for staff to assist him. He did not want to have an accident and could not wait 15-20 minutes .
Random dates of the call light record detail report were reviewed. The call light report tracked the date and time, the room number and the response time. Although, the call light report had the majority of the call lights answered within five to seven minutes, there were several call lights which were in excess of 15 minutes. Such as:
-9/5/19: 17 minutes room #C06, 22 minutes room #C03, 47 minutes room #B05, 28 minutes room #B04, 30 minutes room #C06, 18 minutes room #C03, 26 minutes room #A04, 29 minutes room #C06, and 20 minutes room #D04.
-9/11/19: 27 minutes room #C09 and 24 minutes room #A05.
-9/26/19: 16 minutes room #D04 and 19 minutes room #A02.
-10/6/19: 20 minutes room# C06, 19 minutes room #A04, 40 minutes room #C06, 16 minutes room #A04, 18 minutes room #A02, 17 minutes room #C06, 23 minutes room #D03, 39 minutes room #B06, 17 minutes room #D04, and 30 minutes room #D04.
A copy of the concern/comment report dated 8/30/19 was provided by the SSD on 10/9/19 at 9:00 a.m. The SSD met with Resident #35 on 9/13/19, 14 days after the grievance had been filed and advised the resident that more certified nurse aides (CNAs) were being hired by the DON.
D. Staff Interviews
CNA #5 was interviewed on 10/10/19 at 10:03 a.m. The CNA said the call lights should be answered in about three to five minutes.
CNA #3 was interviewed on 10/10/19 at 10:08 a.m. The CNA said the call lights should be answered in four minutes. She said after dinner there were quite a few lights that went off, so they had to prioritize residents needs.
CNA #2 was interviewed on 10/10/19 at 10:30 a.m. The CNA said call lights should be answered in one to two minutes. She said there were residents who required two-person assist and it may take in excess of 30-40 minutes before the other call lights were answered.
The DON was interviewed on 10/10/19 at 12:35 p.m. The DON said she expected the call light to be answered in five to seven minutes. The call light system was set-up with a target goal for call lights to be answered in one to two minutes.
E. Follow-up
The SSD provided a copy of the complaint/concern/comment/grievance form dated 10/9/19. It revealed a plan of action for the CNAs to respond to the call light and if a second CNA was required, then the light was to remain on until the second CNA arrived. The plan was to be re-evaluated in a week as to its effectiveness in the extended wait time.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0692
(Tag F0692)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observations, record review and interviews the facility failed to ensure residents maintain acceptable parameters of nu...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observations, record review and interviews the facility failed to ensure residents maintain acceptable parameters of nutritional status, such as usual body weight or desirable body weight range, as evidenced by significant weight loss for one (#4) of two residents reviewed for nutrition of 29 sample residents.
Specifically, the facility failed to:
-Follow the dietary consultant's recommendation to increase a supplement if Resident #4 had continued weight loss;
-Notify the physician timely of Resident #4's continued weight loss;
-Consistently review Resident #4's significant weight loss as an interdisciplinary team; and
-Implement additional nutritional interventions which contributed to Resident #4's unintended weight loss and further activities of daily living (ADL) decline.
Findings include:
I. Facility policy
The Dietary Response to Weight Loss/Gain policy, undated was provided by the director of nursing (DON) on 10/9/19 at 5:30 p.m. It read, in pertinent part, the Dietary Manager will monitor the weekly and monthly weights provided by nursing staff.
-When a pattern of persistent weight loss/significant loss has been identified, a review of the resident's meal intakes will be done to determine how much a resident is eating; then, through observation of the meal times and interviews of the assisting CNAs (certified nurse aides), it may be possible to identify chewing difficulties or signs of disinterest in the meal offered.
-Consulting Dietician will review the resident's chart and intakes and interview the resident to determine if there is another underlying problem that is contributing to low intakes or difficulty in maintaining weight.
-House supplement (Mighty Shake Plus) will be offered to determine if a resident will accept that form of increased calories and, if so, a request will be made to nursing to getan order for whatever amount seems appropriate to address the needs of theresident. This amount can be increased or decreased as the situation develops or resolves.
-Problems of weight gain or loss are discussed by the interdisciplinary team and addressed
in the care plan and the MDS. Significant changes that trigger a new MDS are also reported to the attending physician.
II. Resident #4
A. Resident status
Resident #4, age [AGE], was admitted on [DATE]. According to the October 2019 computerized physician orders (CPO), diagnoses included dementia, protein calorie malnutrition, and cerebral infarction.
The 7/5/19 MDS assessment revealed the resident required extensive assistance of one person with bed mobility, dressing and hygiene and required extensive two-person assistance with toileting. The resident's weight was 105 pounds and it was documented the resident was not on a physician-prescribed weight-loss regimen. She ate independently and required set up help from staff.
The 10/4/19 minimum data set (MDS) assessment revealed the resident's brief interview for mental status (BIMS) score was not completed. She was severely impaired and had short-term and long-term memory problems. She had no memory/recall ability. She required extensive assistance of one staff for transfers, extensive two-person assistance with bed mobility, (she was totally dependent with hygiene, toileting and dressing) and needed staff assistance of one with hygiene and staff assistance of two with toileting and dressing. The resident's weight was 96 pounds and weight loss of 5% or more in the last month or weight loss of 10% or more in the last 6 months was checked no or unknown. She ate independently and required set up help from staff.
-The resident status declined and she required increased assistance from the previous MDS in areas of bed mobility, dressing, toileting and hygiene. Although Resident #29 had not reached a significant amount of weight loss, she continued to decline and lose weight without any review for causation such as underlying problems which placed her at greater risk for pressure ulcer development and possible pneumonia as the resident declined to go to the dining room for meals. The resident was not coded to be on a physician-prescribed weight-loss regimen (see above).
Observations and staff interviews
On 10/9/19 at 12:34 p.m., the resident was lying in bed. The head of the bed (HOB) was at a 30 degree angle. She was pushing her meal tray away from her. She had the main meal which was a biscuit with cream sauce with vegetables, and iced cake. She ate only bites of her meal, she said she was finished. There were no staff present to encourage her with her meal. There was no meal ticket observed on the tray. There was no supplement observed on her meal tray. There was a chocolate pudding at the bedside, no other snacks observed in the room.
-At 4:55 p.m., the resident was lying in bed awake watching television (TV). There was no meal tray served at this time.
-At 5:36 p.m., the resident's room tray was delivered by the dietary manager (DM). The DM requested help from a staff member to sit the resident up higher in the bed (see interview below) and shortly after they left the room.
-At 5:44 p.m., the resident was lying in bed with the HOB at a 45 degree angle. She had her meal tray in front of her. The meal was macaroni and cheese, bread, grapes, eight ounce (Oz) glass of water, and a four Oz glass of pink colored milk/shake. She had only taken bites of her meal.
-At 5:58 p.m., CNA #8 was interviewed. She said she worked at the facility full-time on evening shift. She said the resident refused to be sat up at a 90 degree angle for supper. She said she would only allow the staff to sit her up a little, because of her pain. She said at night for supper the resident would always receive a Mighty shake (nutritional supplement) and she usually drank it all. She said, if she did not eat they would ask the nurse for another shake. The resident was observed to only eat bites of her supper and pushed the tray away, she did however, drink the shake. CNA #8 asked the resident if she could take the meal tray away and the resident stated yes. CNA #8 said she would ask the nurse for a shake later for her, she did not offer to assist the resident with her meal.
On 10/10/19 lunch service was observed. Resident #4's meal card read: Regular mechanical soft, nectar thickened liquids. It had an orange colored dot for ground food (per their color coding system). The card did not indicate supplements. Resident #4's noon meal tray consisted of ground roast beef, green beans, mashed potatoes and gravy, apple pie, water and a 4 Oz glass of strawberry mighty shake thin consistency. Dietary aide (DA) #2 delivered the room tray.
-The DM was interviewed on 10/10/19 at 1:12 p.m. She said Resident #4's diet card was not updated and the resident was on thin liquids and dietary staff provided the supplement, she said she would update the diet card. A copy of the updated diet card was requested but not provided during the survey as the card had not been updated prior to exit.
III. Unintentional weight loss for Resident #4
The nutrition/dietary note dated 10/10/18 at 4:12 p.m., revealed the resident's weight was 107 pounds. She was receiving Mighty shakes three times daily though she did not like them.
The MAR revealed the resident had an order dated 12/7/18 for Ensure (nutritional supplement) one box by mouth twice a day. The MAR was not clarified to include staff to document if the resident accepted the supplement and it did not include a percentage of supplement taken by the resident.
The nutrition/dietary note dated 1/9/19 at 11:25 a.m., revealed the resident's weight was trending upward and was 113 pounds. The resident's meal intake was less than 25-50%. The plan was to continue to offer Ensure twice daily.
The nutrition/dietary note dated 2/13/19 at 1:03 p.m., revealed the resident was seen for weight loss and her weight was 109 pounds. She did not eat much; however, continued to accept Ensure twice daily. The plan would be to increase Ensure to three times daily if the resident continued to have poor intake.
-There were no further nutrition/dietary notes for 2019.
-The supplement had not been increased per the dietary consultant's recommendation.
The monthly weights were documented in the clinical record as follows:
-4/2/19 105 lbs(pounds);
-5/31/19 105 lbs;
-7/9/19 102 lbs;
-8/1/19 101 lbs;
-9/3/19 100 lbs; and
-10/1/19 96 lbs.
-This was an 8.57% weight loss in six months, a 5.88% in three months and a 4% weight loss in one month. The resident's height documented in the clinical record was 65 inches.
-The resident's body mass index (BMI) (a general indication of whether a person has a healthy body weight for their height ranges from 18.5 to 25):
-The resident's BMI was 17.5 in April 2019 which meant she had mild thinness;
-The resident's BMI was 17 in July 2019 which meant she had moderate thinness; and
-The resident's BMI was 16 in October 2019 which meant she had severe thinness.
The Braden (tool used to determine risk for pressure ulcer development) scale dated 4/3/19 revealed the resident was at high risk for pressure ulcer development with a score of 11 (15-18 at risk, 13-14 moderate risk, 10-12 high risk, and nine or below very high risk).
The physician progress note dated 6/9/19 documented diagnosis anorexia and weight loss, the resident's weight was down to 105 pounds and was previously 107 pounds. The resident was currently on Remeron 7.5 mg daily, if the resident continued to have weight loss on the next visit he/she would consider increasing the Remeron dose.
The ADL care plan, revised 7/3/19 revealed the resident ate poorly but she was able to feed herself after set-up assistance. Interventions included to provide milkshakes or liquid food supplements when she refused her meal and to provide nutritious foods that could be taken from a cup or mug where appropriate.
-The care plan did not document if the resident needed encouragement or if encouragement had been offered. The care plan also did not document the resident refused to go to the dining room for meals and preferred to have a room tray.
The care plan note dated 7/3/19 at 8:29 a.m., revealed the resident was reviewed for her quarterly MDS assessment. It documented the resident continued to refuse meals frequently, and ate most meals in her room; however, there was no mention of her weight trending downward.
The plan of care note dated 7/11/19 at 11:09 a.m., (IDT care plan team meeting) documented the staff reviewed care with the resident's family no changes and continue to monitor. The resident's weight was down to 102 pounds and she continued to have poor intake.
-There was no documentation of the physician being notified of the resident's weight trending downward during or after his/her visit.
The communication with family/NOK (next of kin)/POA (power of attorney) note dated 7/25/19 at 11:23 a.m., revealed the family felt Remeron was not effective in weight management for Resident #4 and requested it be discontinued.
The physician progress note dated 8/12/19 documented the resident's weight was stable at 105 pounds contrary to the documented weight in the clinical record which was 101 pounds on 8/1/19 (see above).
-There was no indication of the physician being notified by staff of the resident's current weight documented in the clinical record until brought to their attention during survey.The facility failed to notify the physician timely of Resident #4's continued weight loss.
The behavior noted dated 8/30/19 at 3:16 p.m., revealed Resident #4 had an increase in verbal and physical behaviors and the family agreed to have Remeron 7.5 mg daily restarted for Resident #4.
-There was no documentation of any further intervention implemented to help with unintended weight loss after the Remeron was discontinued and the Remeron was not re-implemented until Resident #4 had increased behaviors, not prescribed for weight loss (see above). The facility failed to consistently review Resident #4's significant weight loss as an interdisciplinary team (see interviews below)
Review of the September meal intake record 9/1/19-9/30/19 revealed the resident refused her meal once, ate 0 (zero) -25% (percent) 68 times and ate 26-50% 12 times, at 51-75% six times, and ate 76-100% three times.
The pharmacy recommendation for September 2019 revealed the pharmacist recommended lab work thyroid stimulating hormone (TSH), complete blood count (CBC), comprehensive metabolic panel (CMP) on 9/27/19.
-This was not completed and during survey when brought to the facilities attention they acted upon it (see follow-up below).
The nutritional care plan, revised 10/2/19 revealed the resident's BMI as of 10/1/19 was 16. Interventions included the resident was placed on Remeron 7.5 mg (milligram) for anorexia on 12/28/18 and it was discontinued on 7/26/19 (per family request see progress note above). Provide occasional supervision when the resident was drinking thin liquids and continue to offer mechanical soft texture with ground meats.
-The care plan did not document any intervention put into place after the Remeron was discontinued. The care plan also did not include supplements or implementation of any new interventions for the resident's unintended weight loss.
Review of the October meal intake record 10/1/19-10/11/19 revealed the resident refused her meal once, ate 0 (zero) -25% (percent) 20 times and ate 26-50% six times, at 51-75% one time, and ate 76-100% one time. The resident overwhelmingly ate only 0-25% of her meals.
-This was a further decline in food intake from the previous month of September 2019.
The care plan note dated 10/2/19 at 9:19 a.m., documented the resident's Remeron was discontinued 7/25/19 for ineffectiveness and then restarted on 8/29/19 because the resident had an increase in behaviors (verbal and physical aggression). The resident had lost another four pounds and her weight was 96 pounds, continue to monitor through the next quarter.
The plan of care note dated 10/2/19 at 1:54 p.m., (IDT care plan team meeting) documented the resident had lost another four pounds; however, was accepting shakes, care plans were reviewed with no changes, continue to monitor.
-There was no documentation of the physician being notified of the resident's continued weight loss. There was no documentation of any implementation of other interventions to promote weight gain, and/or recommendations for any further follow-up to assess for any other underlying problems contributing to weight loss and or progression of disease process.
VI. Staff interviews
Certified nurse aides (CNAs) #1 and #3 were interviewed on 10/9/19 at 9:05 a.m. They said they
worked the day shift on all units. They said the resident usually ate all meals in her room and occasionally would come to the dining room after her weekly shower. They said at times she would refuse to get dressed or eat. They said she usually at 5-25%. They said they had not seen any snacks in the resident's room. CNA #3 said Her daughter used to bring snacks, but we have not seen any snacks in her room lately. They said they had not seen her drink any milk shakes, but they offer her chocolate pudding off of their snack cart. There was a container of chocolate pudding on the bedside dresser, but no other snacks observed in the room.
The director of nursing (DON), assistant director of nursing (ADON) and the DM were interviewed on 10/10/19 at 10:23 a.m. The ADON said the nursing staff completed weekly weights for four weeks on admission and then residents would have a monthly weight. She said the staff would notify the physician if there were a five pound weight gain or weight loss. She said they kept track of what the residents were and were not eating. She said if residents had weight loss they would weigh them weekly, but Resident #4 was not on weekly weights because she usually refused almost all cares; however, they acknowledged daily weights were not initiated for Resident #4. They said Resident #4 preferred to stay in bed and did not like to be sat up at a 90 degree angle for meals due to pain. They said she would also refuse to sit in her recliner in her room.
-The DM said Resident #4 would eat the same amount whether she came out of her room or not.
She said Resident #4's daughter usually brought her in chocolate and the dietary staff would offer her Mighty shakes at every meal. She had no response to the lunch time observation 10/9/19 in which the resident did not have a Mighty shake on her tray. She said on 10/9/19 when she delivered Resident #4's room tray (for the evening meal) she asked staff to help position her higher in the bed to eat, but the resident would not let them sit her all the way up due to
discomfort.
-They had no response to the consulting registered dietitian's recommendation to have Resident #4's supplement increased to three times a day if she continued to have weight loss.
-The DON said they did not have regular IDT meeting to discuss any urgent issues. She said weekly they would have their care plan meetings with families, dining director, activities director, and the nurses. She said the last few months they had really been focusing on their payment driven payment model (PDPM), which would help them receive increased reimbursement. She acknowledged over the past few months individual residents specifically were not reviewed as an IDT for any change in condition such as unintended weight loss and increased risks for pneumonia or wound development. She had no response as to why lab work was not completed for Resident #4.
The pharmacy consultant was interviewed on 10/10/19 at 10:15 a.m. She confirmed after reviewing Resident #4's record she recommended lab work on 9/27/19.
Licensed practical nurse (LPN) #2 was interviewed on 10/10/19 at 10:20 a.m. She said the facility drew their own labs which could be completed daily and they would call the laboratory for same day pick up.
VII. Follow-up
The facility contacted the family/POA on 10/10/19 for Resident #4 regarding the pharmacist recommendation for lab work. Resident #4's family/POA stated they did not want to have the lab work completed and wanted the resident to receive comfort care. The facility notified the physician on 10/10/19 of Resident #4's continued weight loss, and there was a new order written for hospice to evaluate and treat.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Infection Control
(Tag F0880)
Could have caused harm · This affected 1 resident
Based on observations and interview, the facility failed to establish and maintain an infection prevention and control program designed to provide a safe, sanitary environment to help prevent the deve...
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Based on observations and interview, the facility failed to establish and maintain an infection prevention and control program designed to provide a safe, sanitary environment to help prevent the development and potential transmission of communicable diseases and infections.
Specifically, the facility failed to:
-Perform proper hand hygiene prior to, during, and after wound care for Resident #29.
Findings include:
I. Professional reference
According to Centers for Disease Control (CDC) Control and Prevention, Hand Hygiene Basics, retrieved from: http://www.cdc.gov/handhygiene/Basics.html (2019), It read in pertinent part, Healthcare providers should practice hand hygiene at key points in time to disrupt the transmission of microorganisms to patients including: before patient contact; after contact with blood, body fluids, or contaminated surfaces (even if gloves are worn); before invasive procedures; and after removing gloves (wearing gloves is not enough to prevent the transmission of pathogens in healthcare settings).
II. Facility policy
The Hand Washing Protocol for Nursing/CNA (certified nurse aide) Staff, was provided by the director of nursing (DON) on 10/9/19 at 5:30 p.m. It read in pertinent part, All staff shall clean their hands and exposed portions of their arms for at least 20 seconds and shall use the following cleaning procedure:
-Wet hands with warm water and apply antimicrobial soap product.
-Rub hands together with vigorous friction for at least 20 seconds on the surfaces of the lathered fingers, fingertips, areas between the fingers, backsides and palms of the hands and the wrists.
-Rinse thoroughly under warm, running water.
-Turn faucet off using paper towel and then discarding that paper towel.
-Completely and thoroughly dry hands with paper towel.
III. Improper hand hygiene
A. Resident #29's observation
On 10/9/19 at 10:08 a.m. Licensed practical nurse (LPN) #4 was observed providing wound care to Resident #29's coccyx. She had cleansed the surface of an over bedside table, draped the table placed all supplies on the clean field. Upon entering the room, two CNAs (#1 and #3) had assisted the resident to her right side and assisted with pulling the residents brief down, while the nurse performed hand hygiene. LPN #4 washed her hands for eight seconds, turned the sink off with her bare hands and grabbed paper towels and dried her hands. LPN #4 donned gloves and removed the dressing from Resident #29's sacrum (area between the lumbar and coccyx bone makes up the back wall of the pelvis). There was large gaping wound to Resident #29's sacrum with a large amount of serosanguineous (thin watery pink or red fluid that contains red blood cells) drainage. LPN #4 said Resident #29's wound was measured weekly by the assistant director of nursing (ADON). LPN #4 doffed her gloves, and donned clean gloves (she did not perform hand hygiene). Then she cleansed Resident #29's wound with normal saline and 4 x 4 (gauze pad). Resident #29's coccyx wound bed was pink and red, it had a small amount of adherent slough (dead tissue), yellow/black/brown slough located at 12 o'clock of the wound. LPN #4 doffed her gloves and donned new gloves (she did not perform hand hygiene). She used a 4x4 to apply and dab Flagyl (antibiotic powder) to wound bed, then she placed calcium alginate rope (highly absorbent dressing) to the undermining (a pocket beneath the skin at the wound edge) areas (there was undermining almost completely surrounding the wound). LPN #4 said there was a small portion to the top of the wound which did not have undermining but, it was worse towards 5-6 o'clock of the wound After applying calcium alginate to the wound she placed the Medihoney coated absorbent dressing (calcium alginate impregnated with 100% Leptospermum or Manuka honey) to the wound and then covered with Mepilex border (absorbent foam dressing). After repositioning the resident LPN #4 changed the dressing to the resident left lower extremity doffed her gloves and washed her hands for seven seconds shut the water off with her bare hands and grabbed paper towels to dry her hands. LPN #4 said she needed to apply additional dressings to Resident #29's arms as they were weeping.
B. Staff interview
LPN #4 was interviewed on 10/9/19 at 10:40 a.m. She said she did not sleep the night before and had been nervous since she was awake since 1:00 a.m. She acknowledged she did not wash her hands for 20 seconds and shut the sink off with her bare hands which was wrong. She said she should have performed hand hygiene after removing her gloves. She said she had alcohol based hand sanitizer (ABHS) in her pocket but she just forgot to use it.
IV. Administrative interview
The director of nursing was interviewed on 10/10/19 at 11:02 a.m. She said the LPN #4 should have washed her hands after doffing her gloves. She said she planned to provide LPN #4 additional education on hand hygiene
V. Follow-up
The DON provided a copy of the hand hygiene training dated 10/10/19 which was completed with LPN #4 on the day shift.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Antibiotic Stewardship
(Tag F0881)
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 develop and implement an antibiotic stewardship program that...
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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 develop and implement an antibiotic stewardship program that included antibiotic use protocols and a system to monitor antibiotic use for one (#18) of one residents out of 29 sample residents.
Specifically, the facility failed to:
-Ensure clinical signs and symptoms of an infection were identified for Resident #18 prior to administering antibiotics; and
-Report culture and sensitivity (C&S) results timely to the physician.
Findings include:
I. Professional reference
According to the CDC, The Core Elements of Antibiotic Stewardship for Nursing Homes, Appendix A, https://www.cdc.gov/longtermcare/pdfs/core-elements-antibiotic-stewardship-appendix-a.pdf,
Communication tools used to facilitate information when a resident is suspected of having an infection should include key pieces of the clinical history including new symptoms and complaints, physical exam findings (e.g.,vital signs, pulse oximetry, localizing pain, etc.) and other relevant information (e.g., previous antibiotic exposure, previous culture and susceptibility results, current medications, and medication allergy history). Forms used for this information exchange could not only include information about the resident from nursing staff, but also options for how the offsite provider may want to manage the resident based on the information provided (e.g., hydrate and monitor, send further diagnostic tests, initiate treatment). In addition, any tools or forms utilized to improve communication should become part of the resident's medical record to improve documentation of decision making.
According to the CDC, The Core Elements of Antibiotic Stewardship for Nursing Homes, Appendix B, https://www.cdc.gov/longtermcare/pdfs/core-elements-antibiotic-stewardship-appendix-b.pdf,
Incomplete assessment and documentation of a resident's clinical status, physical exam or laboratory findings at the time a resident is evaluated for infection can lead to uncertainty about the rationale and/or appropriateness of an antibiotic. Ongoing audits of antibiotic prescriptions for completeness of documentation, regardless of whether the antibiotic was initiated in the nursing home or at a transferring facility, should verify that the antibiotic prescribing elements have been addressed and recorded.
II. Facility policy
The antibiotic stewardship policy, revised 3/2/18, was provided by the director of nursing (DON) on 10/9/19 at 5:30 p.m. It read, in pertinent part, Medical Record Referral Form. Use in all situations when a resident has a new problem and infection may be suspected, and is being referred to a medical care provider, including transfer to an emergency department or hospital.
-This form is used on an as needed basis any time an infection is suspected, regardless of the type of infection.
III. Resident #18
Resident status
Resident #18, age [AGE], was admitted on [DATE]. According to October 2019 computerized physician orders (CPO), diagnoses included dementia, restlessness and agitation, chronic kidney disease and anxiety.
The 8/14/19 minimum data set (MDS) assessment revealed the resident was severely impaired and short-term and long-term memory problems. She did not exhibit any behaviors. She required extensive one-person assistance with bed mobility, transfers and toileting. She was always incontinent of bowel and bladder.
IV. Record review revealed the following antibiotic failures
A. Report culture and sensitivity (C&S) results timely to the physician
Progress notes
The behavior note dated 6/23/19 at 10:32 a.m., revealed the previous day at 6:00 p.m. Resident #18 complained there were animals in her room, and that morning the night reported that morning Resident #18 stated there were snakes in her bed. The nurse to notify the physician.
The following behavior note dated 6/25/19 at 1:47 p.m., revealed Resident #18 had no further hallucinations observed or reported.
The health status note dated 6/27/19 at 6:08 p.m., revealed blood work was obtained and urinalysis (U/A) was sent out plan to wait for results.
The communication with family/NOK (next of kin)/POA (power of attorney) note dated 6/28/19 at 2:48 p.m., revealed the family was notified Resident #18 was started on antibiotics.
The order note dated 6/28/19 at 2:48 p.m., read New order received for Keflex 500 mg (milligrams) PO (by mouth) TID (three times a day) x (for) 10 days for UTI (urinary tract infection).
The infection note dated 6/29/19 at 2:27 p.m., revealed Resident #18 was verbally and physically aggressive and seeing snakes.
Labs
The UA results received on 6/28/19 revealed Resident 18's urine was positive for nitrates and had 2+ leukocytes (likely an infection); however, the culture and sensitivity results were pending.
The C&S results were reported on 6/29/19 positive for E. coli (Escherichia coli a bacterial infection) greater than 100,000 CFU/ML (significant for infection) the antibiotic Keflex was not indicated on the report for treatment.
A fax cover sheet dated 7/2/19 under comments read, The sensitivity report to follow, resident is on Keflex for a UTI. The staff did not see the antibiotic on the C&S report. Under physician order response it read, Change to Augmentin 500/125 mg by mouth twice a day for 10 days.
Which meant Keflex was not on the lab report as an antibiotic to treat the UTI infection and this was three days after the resident received Keflex unnecessarily.
Medication administration record (MAR)
The June 2019 MAR was reviewed and revealed Resident #18 received seven doses of Keflex from 6/28/19 through 6/30/19 and the July 2019 MAR revealed Resident #18 received two doses of Keflex on 7/2/19, the MAR was blank for 7/1/19.
There was no documentation of the staff providing extra hydration, non pharmacological interventions or any education to staff on proper peri-care for Resident #18 who tested positive for an E. coli infection as she was always incontinent of bowel and bladder and was dependent on staff to assist her to the bathroom. Also there was no documentation of any vital signs taken of the resident from 6/23/19-6/29/19 available in the clinical record and the resident received nine unnecessary doses of Keflex prior to C&S results being reported (see lab above).
The order note dated 7/2/19 at 5:17 p.m., revealed Resident #18 was switched from Keflex and was started on Augmentin for her UTI.
Resident #18 was treated with Augmentin 500 mg/125 mg by mouth twice a day for 10 days and she received this medication from 7/2/19 through 7/12/19.
B. Ensure clinical signs and symptoms of an infection were identified for Resident #18 prior to administering antibiotics
Progress notes
The progress notes reviewed from 7/25/19 through 7/30/19 revealed Resident #18 continued to have bouts of confusion, delusions, and verbal and physical aggression. She was noted to be flailing arms, and self-transferring unsafely.
A fax cover sheet dated 7/31/19 under comments read, the resident was behaving strongly and verbally agitated. It was difficult to obtain urine; however, UA dip was positive for leukocytes.
The infection note dated 7/31/19 at 8:32 p.m., revealed Resident #18 was started on Levaquin for UTI and she had not voided.
The health status note dated 8/1/19 at 11:15 a.m., documented late entry revealed Resident #18 was behaving different, yelling stating she needed her shoes because she wanted to go home, flailing arms in the air. The nurse obtained a straight catheter U/A was sent for culture and sensitivity and the resident was started on Levaquin (Fluoroquinolone antibiotic used to treat bacterial infections) 500 mg by mouth daily for five days along with Ativan 0.5 mg by mouth every 12 hours for seven days, and staff were instructed to push fluids.
The resident received all five doses of Levaquin from 7/31/19 through 8/4/19 (Fluoroquinolone).
The infection note dated 8/2/19 at 8:26 p.m., revealed Resident #18 had no current behaviors or complaints.
The infection note dated 8/3/19 at 3:08 p.m., revealed Resident #18 had no behaviors and no urinary burning or foul odor.
The infection note dated 8/4/19 at 1:09 a.m., revealed Resident #18 had no behaviors and was content.
The infection note dated 8/4/19 at 1:38 p.m., revealed Resident #18 was given the last dose of Levaquin for UTI and she did not have any behaviors and did not complain of urinary burning or foul odor.
The infection note dated 8/5/19 at 3:56 p.m., revealed Resident #18 had completed her antibiotics, she was more calm, relaxed Being herself again, she was up for meals, continued to drink poorly so staff encouraged fluids.
The infection note dated 8/6/19 at 3:32 a.m., revealed Resident #18 was to receive Cipro for five days based on C&S report even though the resident was not experiencing any symptoms of an infection over the past several days.
Lab
The 8/2/19 U/A report was negative nitrates and 3+ positive for leukocytes.
The C&S results were reported on 8/4/19 and revealed the organism E. coli greater than 100,000 CFU/ML. Sensitivity (S) for Levaquin S=1 and for Cipro S<=0.25 (indicates if the organism is sensitive or resistant to a particular antibiotic). Handwritten on the C&S report was Cipro (Fluoroquinolone antibiotic used to treat bacterial infections) 250 mg by mouth twice a day for five days for UTI.
Review of the August 2019 MAR revealed the resident received the full five day course of Levaquin and five day course of Cipro antibiotics.
-There was no evidence of a time out period (see interview below) or indication of a repeat U/A to check if the infection was clear prior to immediate start of Cipro.
-There was no education provided to staff on proper peri-care as the resident was always incontinent of bowel and bladder and dependent on staff to assist her to the bathroom documented in the resident's clinical record. Resident #18 vital signs remained WNL (within normal limits and she had no fever).
-There was no telephone order written for Cipro antibiotic and no fax communication cover sheet sent to the physician.
C. Physician progress notes
Review of the MD progress note on 7/25/19 revealed the resident was seen every 60 days for nursing home follow-up. She had recently been treated for a UTI. Under plan and instructions it was documented the resident had no new behavior abnormalities, had progressive dementia and was incontinent of urine and stool. The 9/26/19 physician note revealed the resident had a progression of end stage dementia, information obtained from the patient was that she did get easily confused family requested conservative management only, no blood draws, and end of life care.
D. The Medical Care Referral Form
The Medical Care Referral Form (a tool the facility used to ensure criteria was met prior to the start of administering an antibiotic see above) was not available in Resident #18's record. The form as indicated in the policy was to be filled out completely and sent to the provider. It read in pertinent part, Put an X in the box to indicate the suspected infection and circle related signs/symptoms: Y (present), No (not present), or? (not known). (Based on Y, No, Or ? documented on the form the physician would chose or not chose to treat with an antibiotic).
Suspected Urinary Tract Infection
-New or increased urgency or urination;
-New or increased frequency of urination;
-New or increased suprapubic pain;
-Costovertebral angle (CVA) tenderness;
-Painful or difficult urination;
-Obvious blood in urine;
-Change in urine appearance or odor;
-New or worse urinary incontinence; and
-Positive culture.
-The form also included to document vital signs including fever, and changes in cognition. Although the form included areas to document changes, the form was not completed or available in the record and it did not distinguish when criteria was met to treat for an infection for the dates the resident was treated for infection (see above).
V. Staff interviews
The DON was interviewed on 10/10/19 at 9:52 a.m. She said there were many tools the facility used to indicate if criteria was met to start an antibiotic. She said the facility utilized a medical referral form which was filled out and sent to the physician. She could not explain the form and how it was used to determine if criteria was met to start an antibiotic. She had no response as to what symptoms or how many symptoms were needed on the form to determine when to start an antibiotic. She said the physician would make a decision to start an antibiotic based on lab work and the staff would monitor the resident for 72 hours and they would monitor the resident for effectiveness of antibiotic use. She said the 72 hour period is the time staff would consider as a time out period. She said they did not notice any trends during their antibiotic surveillance and she did not notice a need to provide education to the staff regarding peri-care for residents who required assistance with toileting. She had no response as to Resident #18 receiving antibiotic prior to the C&S results being reported and Resident #18 receiving an additional course of antibiotics even though her behaviors had improved other than the staff knew how to use the tool to see if residents met criteria to start an antibiotic.
Licensed practical nurse (LPN) #3 was interviewed on 10/10/19 at 5:00 p.m. She said the criteria used for antibiotic stewardship was followed by the medical referral form. She said if a UTI was suspected the nurses would fill out the form and complete a UA dip in house and it was up to the physician to treat. She had no response as to what symptoms or how many symptoms were used on the form to meet criteria to start an antibiotic, but that it was the physician's decision to treat.
CONCERN
(F)
Potential for Harm - no one hurt, but risky conditions existed
Food Safety
(Tag F0812)
Could have caused harm · This affected most or all residents
Based on observations, record review, and staff interviews, the facility failed to ensure food was served under sanitary conditions during meal services.
Specifically, the facility failed to ensure:
-...
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Based on observations, record review, and staff interviews, the facility failed to ensure food was served under sanitary conditions during meal services.
Specifically, the facility failed to ensure:
-Prevention of potential cross-contamination of food contact surfaces; and
-Appropriate use of gloves when handling ready-to-eat foods.
Findings include:
I. Failure to prevent potential cross-contamination of food contact surfaces
A. Professional references
The Food and Drug Administration (FDA) Food Code (2017) pp. 49-50, detailed the following instances when foodservice staff should wash their hands:
-Immediately before engaging in food preparation including working with exposed food, clean equipment and utensils, and unwrapped single-service articles;
-After touching bare human body parts other than clean hands and clean, exposed portions of arms;
-After handling soiled equipment or utensils;
-During food preparation, as often as necessary to remove soil and contamination and to prevent cross contamination when changing tasks;
-When switching between working with raw food and working with ready-to-eat food;
-Before donning gloves to initiate a task that involves working with food; and
-After engaging in other activities that contaminate the hands.
-According to the FDA Food Code (2017) p. 24, A utensil was defined as a food contact implement or container used in the storage, preparation, transportation, dispensing, sale, or service of food, such as kitchenware or single-use gloves used in contact with food.
-The FDA Food Code (2017) p. 11, defines a highly susceptible population (HSP) as: Persons who are more likely than other people in the general population to experience foodborne disease because they are .immunocompromised or older adults .or persons who obtain food at a facility that provides services such as custodial care, health care, or assisted living .such as a nursing home.
B. Facility policy
The Bare Hand Contact with Food and Use of Plastic Gloves policy, dated 2018 was provided by the director of nursing (DON) on 10/10/19 at 10:01 a.m. It read, in pertinent part, Staff use clean barriers such as single-use gloves, tongs, deli paper, and spatulas to prevent food borne illness. Gloved hands are considered a food contact surface that can get contaminated or soiled. If used, single-use gloves shall be used for only one task, used for no other purpose, and discarded when damaged or soiled, or when interruptions occur in the operation. Gloves are just like hands. They get soiled. Anytime a contaminated surface is touched, the gloves must be changed.
C. Observations
The following observations were made during the noon meal service on 10/10/19 in the main kitchen:
-At 11:49 a.m., the cook used a blue handled scoop to serve mashed potatoes. Instead of resting the contact surface of the handle against the side of the pan above the mashed potatoes, the scoop fell into the mashed potatoes when she released it. The cook replaced the scoop that had fallen into the mashed potatoes with a clean scoop. However, she did not change her gloves that had come in contact with the food.
-At 11:51 a.m., once more, the new scoop fell into the mashed potatoes, but this time the cook did not replace the scoop and continued to use it throughout the meal service. The scoop fell into the mashed potatoes each time it was used. Mashed potatoes were visible on the scoop release button, which transferred onto the cooks gloved hand.
-At 11:53 a.m., the cook used tongs to serve the tossed salad. Instead of resting the contact surface of the tongs along the side of the bowl above the salad, the tongs fell in the large metal bowl on top of the salad when she released it. The fingers of her gloved hand came in contact with the salad every time she picked up the tongs and served it in the small white porcelain bowls.
II. Failure to appropriately use gloves when handling ready-to-eat foods
A. Professional reference
The Colorado Department of Public Health and Environment (2019) The Colorado Retail Food Establishment Rules and Regulations, retrieved from: https://www.colorado.gov/pacific/sites/default/files/DEHS_RetailFd_6CCR10102_RFFC_EffJan2019.pdf. It read, in pertinent part, Except when washing fruits and vegetables, food employees may not contact exposed, ready-to-eat food with their bare hands and shall use suitable utensils such as deli tissue, spatulas, tongs, single-use gloves, or dispensing equipment. If used, single-use gloves shall be used for only one task such as working with ready-to-eat food or with raw animal food, used for no other purpose, and discarded when damaged or soiled, or when interruptions occur in the operation.
B. Observations
The following observation was made during the preparation of the noon meal on 10/7/19 in the main kitchen:
-At 9:21 a.m., with a gloved hand, the cook pulled open a drawer located at the butcher block island in the middle of the kitchen, retrieved a small paring knife and closed the drawer. She walked to the opposite side of the island and with the same contaminated gloved hand, took a grape tomato from the container of tomatoes on the counter. She held the tomato with the gloved hand, cut it in half and tossed the cut tomato into the bowl of salad.
She repeated this process until all of the tomatoes had been cut in half. The cook did not change her gloves or wash her hands after the knife was retrieved from the drawer and before she worked with ready-to eat food.
The following observations were made during the noon meal service on 10/10/19 that started at 11:49 a.m., in the main kitchen:
-At 11:52 a.m., with a gloved hand, the cook opened a bag that contained hamburger buns, took a bun from the bag, opened the bun with both hands and placed it on the plate.
-At 11:53 a.m., with a gloved hand, the cook opened a cabinet door and retrieved a stack of small white bowls from the cupboard and then the cook opened a drawer located on the side of the kitchen island, retrieved tongs for the salad and closed the drawer.
-At 12:01 p.m., with a gloved hand, the cook opened a bag that contained hamburger buns, took a bun from the bag, opened it with both hands and placed it on the plate.
-At 12:06 p.m., with a gloved hand, the cook opened a bag that contained hamburger buns, took a bun from the bag, opened it with both hands and placed it on the plate.
Throughout the noon meal, the cook touched various non food surfaces such as cupboard door and drawer handles, bag containing hamburger buns, small white dishes, and meal cards. At no time during the observation did the cook change her gloves between tasks. It was not until after the residents in the dining room had been served that she removed the contaminated gloves and washed her hands.
III. Interviews
The DM was interviewed on 10/10/19 at 1:12 p.m. She said the kitchen staff performed hand washing when they came into the kitchen, before and after handling food (ready to eat and/or raw), after using the bathroom, after smoking, or when they touched other surfaces in between working with food. She said she has instructed the kitchen staff that if they touch the handles of the sink, other surfaces, or any part of their person (face, glasses, hair, etc) after washing their hands, they were to rewash their hands. She said there are no 'magic gloves' and she has tried to enforce this with the kitchen staff, explaining the risk of cross contamination.
The DM said verbal in-service training had been conducted with the kitchen staff including the cook on hand hygiene and food handling, but she did not have documentation to support the training. She said she would conduct further training on proper glove use and the increased risk for cross contamination in particularly with the cook observed above.