CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Pressure Ulcer Prevention
(Tag F0686)
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 resident care consistent with professional st...
Read full inspector narrative →
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observations, record review and interviews, the facility failed to ensure resident care consistent with professional standards of practice, to prevent avoidable pressure ulcers for one (#30) of three residents reviewed out of 20 sample residents.
Specifically, the facility failed to ensure the resident did not develop avoidable deep tissue injuries to his bilateral great toes by:
-Ensuring the removal of the resident's socks while in bed, to prevent irritation/pressure to the bilateral great toes;
-Ensuring the implementation of interventions to keep the resident's bed covers from touching the tips of the resident's bilateral great toes; and,
-Updating the resident's care plan to include interventions for the resident's right great toe deep tissue injury.
These failures contributed to the resident developing deep tissue injuries to both of his great toes, which increased in size. Additionally, these failures contributed to delayed wound healing.
Findings include:
I. Professional reference
According to the National Pressure Ulcer Advisory Panel, European Pressure Ulcer Advisory Panel and Pan Pacific Pressure Injury Alliance Prevention and Treatment of Pressure Ulcers: Clinical Practice Guideline, [NAME] Haesler (Ed.), Cambridge Media: [NAME] Park, Western Australia; 2014, retrieved from https://www.ehob.com/media/2018/04/prevention-and-treatment-of-pressure-ulcers-clinical-practice-guideline.pdf on 4/18/22. Pressure ulcer classification is as follows:
Category/Stage 1: Non- blanchable Erythema
Intact skin with non-blanchable redness of a localized area usually over a bony prominence. Darkly pigmented skin may not have visible blanching; its color may differ from the surrounding area. The area may be painful, firm, soft, warmer or cooler as compared to adjacent tissue. Category/Stage I may be difficult to detect in individuals with dark skin tones. May indicate at risk individuals (a heralding sign of risk).
Category/Stage 2: Partial Thickness Skin Loss
Partial thickness loss of dermis presenting as a shallow open ulcer with a red pink wound bed, without slough. May also present as an intact or open/ruptured serum-filled blister. Presents as a shiny or dry shallow ulcer without slough or bruising. This Category/Stage should not be used to describe skin tears, tape burns, perineal dermatitis, maceration or excoriation. Bruising indicates suspected deep tissue injury.
Category/Stage 3: Full Thickness Skin Loss
Full thickness tissue loss. Subcutaneous fat may be visible but bone, tendon or muscle are not exposed. Slough may be present but does not obscure the depth of tissue loss. May include undermining and tunneling. The depth of a Category/Stage 3 pressure ulcer varies by anatomical location. The bridge of the nose, ear, occiput and malleolus do not have subcutaneous tissue and Category/Stage 3 ulcers can be shallow. In contrast, areas of significant adiposity can develop extremely deep Category/Stage 3 pressure ulcers. Bone/tendon is not visible or directly palpable.
Category/Stage 4: Full Thickness Tissue Loss
Full thickness tissue loss with exposed bone, tendon or muscle. Slough or eschar may be present on some parts of the wound bed. Often include undermining and tunneling. The depth of a Category/Stage 4 pressure ulcer varies by anatomical location. The bridge of the nose, ear, occiput and malleolus do not have subcutaneous tissue and these ulcers can be shallow. Category/Stage 4 ulcers can extend into muscle and/or supporting structures (e.g., fascia, tendon or joint capsule) making osteomyelitis possible. Exposed bone/tendon is visible or directly palpable.
Unstageable: Depth Unknown
Full thickness tissue loss in which the base of the ulcer is covered by slough (yellow, tan, gray, green or brown) and/or eschar (tan, brown or black) in the wound bed. Until enough slough and/or eschar is removed to expose the base of the wound, the true depth, and therefore Category/Stage, cannot be determined. Stable (dry, adherent, intact without erythema or fluctuance) eschar on the heels serves as ' the body's natural (biological) cover ' and should not be removed.
Suspected Deep Tissue Injury: Depth Unknown
Purple or maroon localized area of discolored intact skin or blood-filled blister due to damage of underlying soft tissue from pressure and/or shear. The area may be preceded by tissue that is painful, firm, mushy, boggy, warmer or cooler as compared to adjacent tissue. Deep tissue injury may be difficult to detect in individuals with dark skin tones. Evolution may include a thin blister over a dark wound bed. The wound may further evolve and become covered by thin eschar. Evolution may be rapid, exposing additional layers of tissue even with optimal treatment.
II. Facility policies and procedures
The Wound Care policy, revised September 2015, was provided by the director of nursing (DON) on 4/11/22 at 9:36 a.m. The policy revealed a wound was a type of injury in which the skin was torn, cut or punctured and/or a surgical incision. Resident wounds would be assessed, classified, staged, planned, implemented, documented and evaluated.
A charge nurse would assess a wound at the time of the injury, before initiation of treatment, during treatment and after therapy. During the assessment, wounds were to be inspected for appearance, presence of exudates, condition of under-lying tissue in an open wound, also noting skin discoloration, i.e. bruising or signs or symptoms of infection.
The would be assessed for the character of the wound drainage by noting amount, color, odor, and consistency. Drainage classifications types included:
1. Serous: clear, watery plasma,
2. Sanguineous: fresh bleeding,
3. Serosanguineous: pale, waterier, a combination of plasma and red blood cells, and
4. Purulent: thick, yellow, green, or brown, indicating the presence of dead or living organisms and white blood cells.
The classification of a wound focused on the status of the skin integrity, the cause of the wound, the severity of the tissue injury, the cleanliness of the wound, and/or descriptive qualities of the wound.
The staging of pressure ulcers would be according to the Pressure Ulcers: Prevention and Management Program Policy and Procedure.
A nurse would establish a plan of care that reflected the resident's health care needs after the appropriate identification of the wound. The type of wound care administered depends on the type of wound, size, location and any complications. The nurse would establish the expected outcome based on the goals of the care. Nursing interventions were dependent and independent. Dependent interventions resulted from physician's specific wound care orders.
Implementation depended on the type, size, and location of the wound. Surgical wounds and pressure ulcers usually required dressing changes under specific orders from a physician. Wounds associated with secretions and/or excretions involved skin protectants and supplies aimed at keeping a resident dry.
All wound care should be documented daily after treatments were completed, with all the subjective and objective information obtained.
A nurse was to evaluate the progress of the wound care related to its ongoing progress, or lack of, which would initiate a new plan of care being implemented. The nurse will evaluate the wound weekly for progress, report and document accordingly.
The Pressure-Ulcer Prevention and Management Program, revised October 2017, was provided by the ward clerk (WC) on 4/19/22 at 11:13 a.m. The policy revealed the policy was to provide a framework for identifying system components essential to the program for the prevention and management of pressure ulcers. A comprehensive written pressure ulcer prevention and management program would provide guidance, structure, continuity and care within the parameters of accepted standards of practice.
The admitting registered nurse (RN) or licensed practical nurse (LPN) would be responsible for identifying risk factors upon admission with the nursing history and physical (NHP) and the initial skin assessment.
The charge nurse (CN) would perform weekly skin assessments, during one of the weekly scheduled baths. If the CN reported on a new pressure ulcer, they would fill out the pressure ulcer record sheet (PURS), record all information onto this sheet and start the new pressure ulcer checklist sheet (NPUCS). In addition to these sheets, the CN would send a doctor's communication on wounds (DCW) to the resident's physician. The CN would also report to the minimum data set coordinator (MDSC) of any new skin problems.
The MDSC would use a Braden Scale assessment to evaluate the resident's skin on a quarterly basis or more frequently with significant changes.
All residents would receive preventive care when indicated. Residents with a history of pressure ulcer(s) would receive preventive care regardless of the Braden Scale score calculation.
Identify and promptly institute risk reduction strategies in accordance with protocol and other preventive actions as indicated.
III. Resident observations
On 4/12/22 at 10:13 a.m., the resident was seated in his wheelchair in the common area television room. There was a seat cushion on his wheelchair. The resident wore socks and bedroom shoes on both feet. His feet rested/positioned on the foot pedals of his wheelchair.
On 4/12/22 at 12:02 p.m., the resident was in the main dining room seated in his wheelchair. The resident was able to self-propel his wheelchair with his hands and feet. The resident wore socks and fleece booties on both feet. The resident said he got the fleece booties this morning and previously he wore shoes.
On 4/12/22 at 3:23 p.m.,. The resident was assisted by a staff member to propel the resident's wheelchair down the hallway. The resident wore socks and fleece booties on both feet. The resident's booties were sliding on the floor as he was being propelled down the hallway.
-At 3:40 p.m., the resident propelled himself down the hallway in his wheelchair. He was using both of his feet to propel himself. The resident wore socks and fleece booties on both feet.
On 4/13/22 at approximately 1:53 p.m., the resident propelled himself down the hallway in his wheelchair, using his hands and feet. The resident wore socks and fleece booties on both feet.
On 4/14/22 at 9:33 a.m., the resident propelled himself down the hallway in his wheelchair, using his hands and feet. The resident wore socks and fleece booties on both feet. On 4/14/22 at 10:11 a.m., the resident was seated in his wheelchair in the common area television room. The resident wore socks and fleece booties on both feet.
IV. Wound observations
The resident's wounds were observed on 4/12/22 at 1:43 p.m., by registered nurse (RN #1) and the state surveyor RN. The resident was in his recliner. The resident did not have on any socks. The resident wore sheep fleece booties on both feet. RN #1 said the resident had his booties for a while, but she would have to check the exact date they put the intervention into place. RN #1 said the resident's left great toe and right great toe concerns started about the same time. She said both concerns started as deep tissue injuries and were still deep tissue injuries. RN #1 said the resident's physician assessed the resident's left great toe and decided the toenail needed to be removed. She said when the resident was in bed at night, the staff untuck the sheets and blankets and drape them over the footboard to keep the pressure off of his toes. She said the facility tried to limit the number of blankets he had on his feet.
The resident's right great toe had a dark purple area at the tip of the toe that measured 1.2 centimeters (cm) by 0.8 cm with no depth.
The left great toe had a small linear dark purple wound on the tip of his toe that measured 0.9 cm by 0.6 cm with no depth. There was one area that was open, with no drainage.
-No stage documented for the open area that was no longer a DTI.
V. Resident status
Resident #30, age [AGE], was admitted on [DATE]. According to the April 2022 computerized physician orders (CPO), diagnoses included diabetes mellitus without complications, chronic kidney disease stage III, anemia, and pressure induced deep tissue damage of the left great toe.
The 3/4/22 minimum data set (MDS) assessment revealed the resident had severe impairment in cognition with a score of five out of 15 with no behaviors. The resident required limited staff assistance for bed mobility, transfers, dressing, toileting and personal hygiene. The resident was at risk for the development of pressure ulcers. The resident had one stage II pressure ulcer. The resident utilized a pressure reducing cushion for his chair and received pressure ulcer/injury care
VI. Record review
A Braden Scale dated 11/30/21 at 1:30 p.m., noted a score of 13: moderate risk. The resident was very limited in his sensory perception (ability to respond meaningfully to pressure-related discomfort). The resident was very moist (degrees the skin is exposed to moisture). The resident occasionally walked (degree of physical activity). The resident was slightly limited in mobility (ability to change and control body position). The resident had probably inadequate nutrition (usual food intake pattern). The resident had a problem with friction and shear (friction was the mechanical force exerted on skin that was dragged across any surface and shearing was the interaction of both gravity and friction against the surface of the skin).
A nursing admission note dated 11/30/21 at 1:55 p.m., revealed this was the resident's third stay at the facility and the family thought this might be his permanent residence. The resident had an air bladder cushion for his wheelchair.
-The note did not reveal the resident had any injuries to his bilateral great toes.
A physician's order dated 11/30/21 noted to utilize heel protectors to the resident's bilateral feet along with floating his heels off of his mattress, related to the potential for skin breakdown.
A care plan for potential impaired skin integrity/pressure ulcer related to renal failure, history of skin breakdown, diabetes mellitus, incontinence and the removal of the resident's left great toenail on 3/10/22 (no start date). Some of the interventions included to apply an air bladder cushion to the resident's wheelchair as a skin breakdown preventative. Staff were to assess the resident for redness, skin tears, swelling or pressure areas and report any signs of skin breakdown. Staff were not to massage the resident's skin over pressure areas. Staff were to apply heel protectors to the resident's bilateral feet along with floating the resident's feet off of his mattress related to the potential for skin breakdown. Staff were to use pillows, pads and/or wedges to reduce pressure on heels and pressure points. The staff were to turn and reposition the resident.
A nurse general note dated 12/6/21 at 4:45 p.m., by a LPN revealed to administer Prostat 30 cubic centimeters (cc) orally twice a day for wound care healing.
A wound note (ID:02973) dated 1/7/22 at 11:36 a.m., revealed to apply skin prep daily to the resident's left great toe and allow it to dry before putting on a sock.
A care plan for a deep tissue injury to the resident's left toe was started on 1/7/22. The interventions included for staff to assess and record the size (Length by Width by Depth) of skin discoloration, edema, and pain status. Staff were to perform a complete skin assessment and record. Staff were to perform nutritional screening and adjust the resident's diet/supplements as indicated to reduce the risk of skin breakdown. Staff were to apply skin prep to the resident's left great toe daily and allow it to dry, before placing a sock on the foot.
An administration note dated 1/11/22 at 5:00 a.m., by RN #2 revealed the resident had no redness, but a purple spot remained on the very tip of the (left) toe. The resident denied any pain in his toe.
A Braden Scale dated 3/7/22 at 11:02 a.m., noted a score of 15: at risk. The resident was very limited in his sensory perception (ability to respond meaningfully to pressure-related discomfort). The resident was occasionally moist (degrees the skin is exposed to moisture). The resident occasionally walked (degree of physical activity). The resident was slightly limited in mobility (ability to change and control body position). The resident had adequate nutrition (usual food intake pattern). The resident had a problem with friction and shear (friction was the mechanical force exerted on skin that was dragged across any surface and shearing was the interaction of both gravity and friction against the surface of the skin).
A nursing general follow-up note dated 3/10/22 at 6:17 p.m., revealed the resident had his left great toenail removed. The resident complaint of pain and as needed Tylenol was administered at 4:30 p.m.
A care plan for an infected toenail with removal of the left great toenail was initiated on 3/10/22. Some of the interventions were for staff to administer medications as ordered. Staff were to obtain any cultures as needed. Staff were to follow standard precautions. Staff were to cleanse the left toe with a wound cleanser, apply triple antibiotic, and cover with bandage once daily for a diagnosis of toenail removal.
A nursing general follow-up note dated 3/10/22 at 6:17 p.m., revealed this was a follow-up on the resident's left great toenail removal. The nail appearance was pink with no redness or swelling. The resident had less grimacing and verbal expressions of pain. The resident was administered as needed Tylenol twice this shift. The resident was ambulating in his wheelchair with fleece booties on his feet.
A nursing general follow-up note dated 3/12/22 at 1:31 p.m., revealed the dressing to the resident's toenail remained dry and intact at this time. No pain or discomfort was voiced by the resident at this time.
A nursing general follow-up note dated 3/12/22 at 5:38 p.m., revealed the dressing to his toenail was changed by the treatment nurse. The resident did not complain of severe pain related to the toenail removal. There were no observed signs or symptoms of infection.
A nursing general follow-up note dated 3/13/22 at 6:12 p.m., revealed there were no observed signs or symptoms of infection to the toe wound. The dressing was changed by the treatment nurse.
A nursing general/new order dated 3/14/22 at 2:40 p.m., by RN #1 revealed discontinue the previous wound care to the resident's left great toe and initiate new wound care to the left great toe. Staff were to cleanse with wound cleanser, apply triple antibiotic and cover with a bandage once per day for toenail removal.
A wound order (ID: 93812) dated 4/4/22 at 3:47 p.m., revealed the dressing to the resident's left toe, was to cleanse with a wound cleanser, apply skin prep and then cover with a bandage once daily and as needed.
A wound order (ID:93814) dated 4/4/22 at 00:00 p.m., revealed to provide wound care to the resident's right great toe, cleanse with a wound cleanser, apply skin prep and then cover with a bandage once a day and as needed for a deep tissue injury.
A nursing general/new order dated 4/4/22 at 5:16 p.m., by RN #1 revealed to discontinue (the current) wound care to the resident's left great toe and to initiate (a new) wound care to the left great toe. Staff were to cleanse with wound cleanser, apply skin prep and then cover with a bandage once daily and as needed for a removed toenail. Staff were to initiate wound care to the resident's right great toe; cleanse with wound cleaner, apply skin prep, then cover with a bandage once daily and as needed for a deep tissue injury.
A physician order dated 4/8/22 revealed to apply heel protectors continuously bilaterally to prevent further and future skin breakdown to feet.
Wound Documentation Notebook revealed the following information for the months of January to April 2022:
A. Left great toe documentation (start date of 1/7/22)
-1/7/22 deep tissue injury with a black wound color. Treatment was to apply skin prep.
-1/18/22 deep tissue injury. Treatment was to apply skin prep.
-1/27/22 deep tissue injury with a red/black wound color. Treatment was to apply skin prep.
-2/28/22 stage II. The scab came off and the blackened area was removed. Treatment was to apply skin prep.
-3/7/22 stage II measuring 1.0 cm by 0.5 cm with a pink wound bed. Treatment was to apply skin prep.
3/11/22 stage II measuring 0.8 cm by 0.8 cm. The toenail was removed related to infection and dressing was applied by the provider at this time. Treatment was to apply skin prep.
-3/14/22 stage II measuring 0.8 cm by 0.8 cm. Treatment was to cleanse with a wound cleaner, apply triple antibiotic and cover with a bandage, once a day for toenail removal.
-3/21/22 stage II (no measurements) with a wound bed that was pink/yellow in color. Treatment was to cleanse with a wound cleaner, apply triple antibiotic and cover with a bandage, once a day for toenail removal.
-3/29/22 stage II measuring 1.4 cm by 0.9 cm with a wound bed that was pink/yellow in color. Treatment was to cleanse with a wound cleaner, apply triple antibiotic and cover with a bandage, once a day for toenail removal.
-4/4/22 stage II measuring 1.4 cm by 0.9 cm with a wound bed that was pink/white in color. The treatment was to cleanse with a wound cleaner, apply skin prep and then cover with a bandage.
-4/12/22 stage II measuring 1.2 cm by 0.8 cm with a wound bed that was dark pink in color. The wound appeared open and a communication would be sent to the resident's provider to start hydrogel on the wound bed. The treatment was to cleanse with a wound cleaner, apply skin prep and cover with a bandage.
B. Right great toe documentation (start date of 3/21/22)
-3/21/22 deep tissue injury measuring 0.2 cm by 0.2 cm. The wound started as a deep tissue injury due to pressure induction from socks getting too tight, related to the way the resident self-propelled in his wheelchair. Treatment was to apply skin prep.
-3/29/22 deep tissue injury measuring 1.2 cm by 1.7 cm with a wound bed that was brown in color. Treatment was to apply skin prep.
-4/4/22 deep tissue injury measuring 1.2 cm by 1.7 cm with a wound bed that was brown in color. Treatment was to cleanse with a wound cleaner, apply skin prep and cover with a bandage, once daily or as needed.
-4/12/22 deep tissue injury measuring 1.2 cm by 0.8 cm. Treatment was to cleanse with a wound cleaner, apply skin prep and cover with a bandage, once daily or as needed.
On 4/14/22 at approximately 11:00 a.m., a review of the resident's April 2022 treatment administration record (TAR) revealed, wound dressings for the resident's bilateral great toes were completed as ordered.
VII. Staff interviews
RN #1 and RN #2 were interviewed on 4/14/22 at 2:10 p.m. They both said that they did not have wound care certifications. They said the facility did not use a wound clinic, however a physician from the hospital came to the facility and wrote orders in the resident's clinical record.
They acknowledged that both of them had assessed the resident's wounds and initiated treatment. RN #1 said she did most of the daily treatments. RN #1 said most of the time the resident did not have any pain during the assessments and if he did complain of any pain, she would premedicate the resident before the treatment. RN #1 said wound rounds were done weekly with measurements and treatments were done daily or as needed. RN #2 said they kept in contact with the resident's physician and the physician would sign off on their recommendations. RN #2 said the resident's bilateral fleece booties were started as part of his admission orders. RN #2 said the resident wore the fleece booties all the time and he did not refuse to wear them. RN #2 said the resident's bilateral great toe pressure ulcers were facility acquired.
They both reviewed the left great toe pressure ulcer documentation that was provided by the facility. They both acknowledged the wound started on 1/7/22 as a deep tissue injury and was facility acquired. RN #2 said this wound started due to the resident wearing regular socks. They both said they told the certified nurse aides (CNAs) not to pull the resident's socks upward, so that the socks would not put pressure on his toes. RN #2 said the great left toe was now a stage II pressure ulcer. RN #2 said on 4/17/22 they sent pictures of his toes to his physician and the physician wanted to leave the left great toe open to air, to see if it would dry out. RN #2 said the resident did sleep with his socks on and now they might try to have him sleep without his socks.
They both acknowledged that staff untucked his bed sheets and blankets so they would be loose on his toes. They both acknowledged the resident did not have interventions, such as a bed cradle, to keep the resident's sheets and blankets off of his toes. They both acknowledged that a bed cradle might be tried as an intervention at this time.
They both reviewed the right great toe pressure ulcer documentation that was provided by the facility. They both acknowledged the wound started on 3/21/22 as a deep tissue injury and was facility acquired. RN #2 said the deep tissue injury resembled a bruise with a purple color. RN #2 said the wound was on the tip of this toe and it started due to wearing regular socks.
The DON was interviewed on 4/14/22 at 2:46 p.m. She said she was a wound certified nurse and she reviewed the assessments and measurements provided by either RN #1 and RN #2. She said the resident wore regular socks and did sleep with his socks on. She said when the resident was in his wheelchair he wore regular socks and fleece booties. She said the resident did not utilize a bed cradle at this time.
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 observations, record review and interviews, the facility failed to ensure residents were as free from unnecessary psych...
Read full inspector narrative →
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observations, record review and interviews, the facility failed to ensure residents were as free from unnecessary psychotropic drugs as possible for two (#28, and #33) of five residents out of 20 total sample residents.
Specifically, the facility failed to:
-Ensure consent was obtained and residents and/or their responsible parties were informed of psychotropic medications with black box warnings (the Food and Drug Administration ' s strictest and most serious type of warning which describes a medication ' s serious or life-threatening side effects or risks) prior to the administration of the medication for Resident #28;
-Consistently track behaviors to justify the use of an antipsychotic medication for a resident with dementia for Resident #28 and Resident #33; and,
-Attempt a gradual dose reduction (GDR) of an antipsychotic medication for a resident with dementia for Resident #28.
Findings include:
I. Facility policy and procedures
The Unnecessary Drugs policy, last revised 9/2013, was provided by the assistant director of nursing (ADON) on 4/13/22 at 3:38 p.m. It read in pertinent part: Philosophy: This facility believes that all resident behavior has meaning. It is the philosophy of this facility to work to identify the cause and meaning of behaviors that are distressing, and impact negatively on the resident's quality of life. We will work diligently to minimize the use of psychoactive medications in our resident population. Policy: To prevent the use of psychopharmacological drugs when the ' behavioral symptom ' is caused by conditions such as (1) environmental stressors (e.g. excessive heat, noise, overcrowding, etc); (2) physiological stressors (e.g. abuse, taunting, not following a resident's customary daily routine); or (3) treatable medical conditions (e.g. heart disease, diabetes, chronic obstructive pulmonary disease, constipation, pain, etc). Behavioral symptoms resulting from these causes should not be ' covered up ' with sedating drugs. Procedure: The interdisciplinary team (IDT) will ensure the resident or their surrogate will be apprised of the risks and benefits of the medication being considered, and will provide informed consent before the medication is administered. This informed consent will be in writing and documented in the resident's medical record.Gradual Dose Reduction (GDR) is defined as ' the stepwise tapering of a dose to determine if symptoms, conditions, or risks can be managed by a lower dose or if the dose or medication can be discontinued. ' Goals of GDR are to achieve the lowest effective dose; to discontinue the medications that no longer benefit the resident; and to minimize exposure to increased risk of adverse consequences. GDR is indicated when the resident's clinical condition has improved or stabilized or the underlying causes of symptoms have resolved and the type of medication requires gradual reduction of the dosage in order to avoid adverse consequences that could occur if the medication is stopped abruptly. Guidelines for GDR: During the first year if receiving an antipsychotic or other psychopharmacologic medication, at least one attempt at GDR or dose tapering. A second attempt, in a subsequent quarter the same year (12 month period) unless the first attempt demonstrated that GDR or tapering was clinically contraindicated. The attempts should be at least a month apart. After the first year, GDR or tapering should be attempted once a year. GDR or tapering may be considered clinically contraindicated if the resident's targeted symptoms worsened or returned during the reduction. If this occurs, the physician must document the clinical rationale why further GDR attempts should not be done (further attempts may cause impairment of resident function, increase distressed behavior(s), cause psychiatric instability by exacerbating an underlying medical or psychiatric disorder.
II. Resident #28
A. Resident status
Resident #28, age younger than 70, was admitted on [DATE]. According to the April 2022 computerized physician orders (CPO), diagnoses included unspecified dementia with behavioral disturbance, wandering, restlessness and agitation, anxiety disorder, and post-traumatic stress disorder.
The 2/28/22 minimum data set (MDS) assessment revealed that the brief interview for mental status (BIMS) was not conducted. According to the staff assessment for mental status, the resident ' s cognitive skills for daily decision making were severely impaired. He required one-person limited assistance for bed mobility. He required one-person extensive assistance for dressing, toilet use, and personal hygiene. He required supervision for transfers.
The resident did not exhibit any potential indicators of psychosis such as delusions or hallucinations. He exhibited physical behavioral symptoms directed toward others (e.g., hitting,
kicking, pushing, scratching, grabbing, abusing others sexually) on one to three days during the seven day MDS assessment look-back period. He did not exhibit any other behaviors.
He received an antipsychotic medication daily.
B. Observations
On 4/11/22 at 11:11 a.m., Resident #28 stood by the dining room table and was falling asleep. Certified nurse aide (CNA) #2 noticed the resident and asked him if he wanted to go sit in a recliner. He said yes and allowed himself to be led by CNA #2, while CNA#2 held his hand as they walked to a recliner where he sat down. CNA #2 tried to get Resident #28 to scoot back in the recliner as he was sitting on the edge of it. He started to get angry and cursed a couple of times. CNA #2 remained calm and again encouraged him to scoot back in the recliner. Resident #28 stood up and CNA #2 let him walk away from the recliner. Resident #28 walked back over to the dining room table and did not exhibit any further verbal behaviors.
On 4/11/22 at 2:13 p.m., Resident #28 was standing next to the dining room table with a glass of juice in his hand. There was an iPad sitting in the middle of the room with music from the 1950's playing on it. The resident was smiling and dancing to the music while he drank his juice.
On 4/12/22 at 9:29 a.m., Resident #28 was seated in a recliner in the common area. He was sleeping, along with four other residents who were resting in chairs. There was soft music playing in the room.
On 4/13/22 at 8:30 a.m., Resident #28 was standing next to a recliner in the common area. CNA #2 was standing in front of him and he was holding her hands. He was smiling and dancing to the music that was playing on the television in the common area.
C. Record review
Review of the April 2022 CPO for Resident #28 revealed a physician ' s order for Olanzapine 2.5 milligrams (mg) by mouth two times daily for post-traumatic stress disorder. The order had a start date of 8/4/21.
Review of Resident #28 ' s comprehensive care plan, initiated 1/7/19 and last revised 3/2/22, revealed the resident received Olanzapine, an antipsychotic medication, on a regular basis for post-traumatic stress disorder. The medication was started on 8/4/21. Pertinent interventions included providing distraction and redirection, evaluating the resident for pain/discomfort, monitoring behaviors of becoming agitated with verbal aggression, monitoring for potential physical aggression, monitoring for environmental stressors (loud noises, becoming stressed with children visiting, shooting), IDT team to review medication use quarterly and with significant changes, monitoring the resident ' s whereabouts due to he did not always like other residents in his personal space, did not like unwanted touch and may cause harm to self and/or others, administering medication as prescribed, connecting with the resident one on one, listening to music, offering food, redirecting others away from his personal space, talking about hunting or the mountains, and monitoring for side effects of the medication.
Further review of the resident ' s antipsychotic medication care plan revealed the behaviors warranting the use of Olanzapine included aggression, the resident was unaware of others safety needs, and the resident was unable to recognize others.
-Review of Resident #28 ' s electronic medical record (EMR) failed to show documentation that the resident's responsible party was provided education of the risks and benefits (including the black box warning) of the prescribed antipsychotic medication for the specific identified symptoms the medication was prescribed to treat, or that consent was given for the medication, prior to the resident starting on the medication.
Resident #28 ' s behavior tracking sheets, which were documented by the CNAs, were reviewed for 1/1/22 through 4/12/22. The behavior tracking sheets revealed the following:
-The resident exhibited physical behaviors (e.g., hitting, kicking, pushing, scratching, grabbing, abusing others sexually) on 1/15, 2/1, 2/2, and 2/23/22;
-The resident exhibited verbal behaviors (e.g., threatening others, screaming at others, cursing at others) on 2/1 and 2/2/22;
-The resident exhibited wandering behaviors on 1/15, 2/1, and 2/2/22, and,
-All other dates from 1/1/22 through 4/13/22 were documented as no behaviors were shown.
Review of Resident #28 ' s progress notes from 1/1/22 through 4/12/22 revealed there were no behaviors documented for the resident.
-Despite the CNA behavior tracking sheets documenting the resident exhibited behaviors on 1/15/22, 2/1/22, 2/2/22, and 2/23/22, nurses failed to document in the progress notes what behaviors Resident #28 exhibited on those dates and what interventions were taken.
Review of the psychoactive medication quarterly evaluation conducted on 2/28/22 revealed Resident #28 had behavior episodes less than weekly.
Review of Resident #28 ' s EMR revealed the following physician ' s notes, documented in pertinent part:
8/3/21: Resident #28 was seen for a routine visit. Nursing staff reports that he seems to be increasingly more aggressive. Yesterday, he punched a CNA while he was in the bathroom and punched a bath aide earlier this morning. He was noted to have increased aggression when he was started on fentanyl (pain) patch some years ago. On my visit, the resident did not answer most of my questions. He did reply ' yes ' when asked whether he has a lot of pain in his knees, but did not elaborate otherwise.
Dementia with behavioral disturbance: Resident has had an increasing incidence of aggression with staff and other residents. He is currently on risperidone (a different antipsychotic medication), which initially helped but seems to be less effective more recently. It is possible that he has been dealing with an increase in his chronic pain, or else other medications have been causing him some stomach upset. There is also a challenge in administering medications, as he dislikes taking pills and has trouble even with changing patches. Medications have to be crushed to be administered to him. Addendum 8/4/21: Medication list has been reviewed, with discussion with the pharmacist. Will make the following changes: Risperidone will be discontinued and changed to Olanzapine 2.5 mg two times daily, which can be crushed.
11/30/21: Resident was seen for a routine visit. Nursing staff reports that he continues to be intermittently aggressive. The layout of the common room continues to be rearranged to minimize aggression from the resident. His pain seems to be under fairly good control. On my visit, the resident was sleeping in a chair; he stirred during my exam but did not wake up fully.
Dementia with behavioral disturbance: Appears to be at baseline mentation. Continue on Risperidone to alleviate some of his aggression.
-The note documented Resident #28 was on Risperidone which had been discontinued on 8/4/21. The note did not mention the Olanzapine which had been started on 8/4/21.
1/25/22: Resident was seen for a routine visit. He was noted to be sleeping on my visit but easily awakened. He only responded to one question ( ' yes ' when asked if he was okay; he did not answer when asked about pain or any other symptoms). Nursing staff deny any recent concerns. Dementia with behavioral disturbance: Appears to be at baseline mentation. Off Risperidone.
-Despite the physician documenting nursing staff had no recent concerns, the note did not mention the resident was taking Olanzapine for behaviors and there were no attempts made to lower the resident ' s dosage of the medication.
3/15/22: Resident was seen for a routine visit. Resident was sleeping and only stirred when I addressed him. Nursing staff did not report recent concerns.
-Despite the physician documenting nursing staff had no recent concerns, the note did not mention the resident was taking Olanzapine for behaviors and there were no attempts made to lower the resident ' s dosage of the medication.
Review of Resident #28 ' s physician order history revealed the resident had previously been receiving Risperidone, a different antipsychotic medication. The Risperidone was discontinued on 8/4/21 when the Olanzapine was started.
Review of Resident #28 ' s EMR revealed the following requests for a gradual dose reduction (GDR) of the antipsychotic medication (as is required two times within the first year of the medication being started unless clinically contraindicated):
11/24/21: Physician declined a GDR and documented the resident ' s symptoms were stable on the current medication regimen.
-The physician did not document a clinical rationale for why any attempted dose reduction at that time would be likely to impair the resident ' s function or exacerbate an underlying medical or psychiatric disorder.
-The resident ' s EMR did not reveal a Risk versus Benefits form signed by the family and the physician for the continued use of the medication.
2/23/22: Physician declined a GDR and documented the resident ' s symptoms were stable on the current medication regimen.
-The physician did not document a clinical rationale for why any attempted dose reduction at that time would be likely to impair the resident ' s function or exacerbate an underlying medical or psychiatric disorder.
-The resident ' s EMR did not reveal a Risk versus Benefits form signed by the family and the physician for the continued use of the medication.
-Despite the lack of documentation that Resident #28 exhibited behaviors which justifed the continued administration of the antipsychotic medication (see above behavior and progress note documentation), there were no attempts made since the medication was started (eight months prior) to lower the dose of the medication the resident was receiving.
D. Interviews
CNA #2 was interviewed on 4/13/22 at 8:35 a.m. CNA #2 said Resident #28 usually did not have any behaviors unless staff was trying to take him to the bathroom. She said he could get agitated during the toileting routine. She said he would make fists, but had never hit staff or residents that she was aware of. She said he would usually just cuss when he was agitated. CNA #2 said the resident would usually calm down if the staff talked softly to him and explained everything they were doing. She said if the resident did not calm down, which was rare, she would make sure he was safe and re-approach him in a few minutes.
Licensed practical nurse (LPN) #2 was interviewed on 4/13/22 at 8:43 a.m. LPN #2 said staff had to be patient with Resident #28. She said if the resident was holding something like an empty cup and the staff tried to replace the empty cup with a full cup, the resident could get upset and acted like he might hit the staff. LPN #2 said if he was spoken to calmly and things were explained to him, he would usually calm down. She said he calmed down and could be easily redirected if staff was patient with him. She said playing music for the resident was usually a good way to redirect any behaviors he might have.
The ADON was interviewed on 4/14/22 at 12:12 p.m. The ADON said Resident #28 was started on Olanzapine on 8/4/21. She said he received his first dose of the medication on 8/4/21. She said she was unable to find a consent for the medication in the resident ' s EMR. She said she did not see any documentation indicating the resident ' s representative had been notified of the order for the medication or the risks/benefits of the medication prior to the medication being administered to the resident. The ADON said whenever a nurse received an order for a new medication, they were to notify the family. She said if the medication was a psychotropic medication, the nurse would review the risks/benefits of the medication with the resident ' s representative and obtain consent from the representative for the medication to be administered. She said the conversation with the representative should be documented in the resident ' s progress notes.
The ADON said Resident #28 had a diagnosis of post-traumatic stress disorder and could become defensive. She said if he perceived someone as a threat he might strike out at that person. She said he was territorial and protective of his things, so the staff monitored him closely. She said the behavior tracking sheets were documented daily by the CNAs. The ADON said if a resident had a behavior, the CNA would document which type of behavior it was and notify the nurse of the behavior. She said the nurse would then document a more specific description of the behavior in the resident ' s progress notes. The ADON confirmed there were only a few behaviors documented on the CNA tracking sheets from 1/1/22 through 4/12/22. She confirmed that there were no behaviors documented in Resident #28 ' s progress notes on the dates that the CNAs documented the resident had a behavior. She confirmed there were no other behaviors documented in the resident ' s progress notes from 1/1/22 through 4/12/22.
The ADON said Resident #28 did not exhibit as many behaviors as he used to. She said the facility had requested a GDR on 11/24/21 and 2/23/22, however the physician felt that the resident was stable on his medications and did not want to reduce them. She agreed that, since the facility had not tried to reduce Resident #28 ' s antipsychotic medication in the eight months the resident had been receiving the medication, there was no way to know if the resident would continue to exhibit fewer behaviors on a lower dose of the medication.
II. Resident #33
A. Resident status
Resident #33, age [AGE], was admitted on [DATE]. According to the April 2022 CPO, diagnoses included Alzheimer ' s disease, anxiety disorder, delusional disorders, and narcissistic personality disorder.
The 3/21/22 MDS assessment revealed that the resident had severe cognitive impairment with a BIMS of six out of 15. She required two-person total assistance for bed mobility, transfers, and toilet use. She required two-person extensive assistance for dressing and personal hygiene.
The resident did not exhibit any potential indicators of psychosis such as delusions or hallucinations. There were no behaviors coded on the MDS assessment.
She received an antipsychotic medication daily.
B. Observations
On 4/11/22 at 10:07 a.m., Resident #33 was lying in bed on her back with the head of the bed elevated. She was pleasant but said she did not like to be bothered.
On 4/12/22 at 9:44 a.m., Resident #33 was seated in her recliner by the door of her room. She said she had been sitting in the chair for a long time. She said the staff just left her there because they do not care.
On 4/13/22 at 9:08 a.m., Resident #33 was tearful while staff was performing a wound care treatment. She was lying in bed while registered nurse (RN) #1 changed her wound dressing and CNA #3 helped position the resident during the dressing change. She told RN #1 and CNA #3 that they did not care about her and did not care what they did to her. RN #1 reassured the resident that they did care for her and would be finished with the dressing change shortly. Resident #33 calmed down and then became tearful again. RN #1 and CNA #3 reassured the resident several times. After the dressing change was completed, RN #1 and CNA #3 transferred the resident to her recliner using a mechanical lift. Resident #33 voiced that she was not comfortable and that the staff did not care about her. RN #1 again reassured the resident and worked with CNA #3 to ensure the resident was comfortable. Once the resident was positioned in a comfortable position, she calmed down. RN #1 and CNA #3 then exited the room.
C. Record review
Review of the April 2022 CPO for Resident #33 revealed the following physician ' s orders:
-Quetiapine 50 mg by mouth two times daily for delusional disorders. The order had a start date of 3/17/22; and,
-Quetiapine 25 mg by mouth one time daily for delusional disorders. The order had a start date of 3/17/22.
Review of the physician order history of Quetiapine for Resident #33 revealed the following:
-4/1/21: Resident was admitted on Quetiapine 25 mg by mouth two times daily for paranoia and delusions;
-4/30/21: Quetiapine was increased to 50 mg by mouth two times daily for delusional disorder, paranoia, and delusions; and,
-3/17/22: Quetiapine was increased to 50 mg by mouth every morning and 75 mg at bedtime for delusional disorders.
Review of Resident #33 ' s comprehensive care plan, initiated 4/1/21 and last revised 3/23/22, revealed the resident received Quetiapine, an antipsychotic medication, on a regular basis. The resident was admitted on [DATE] with a physician ' s order for the medication for paranoia and delusions. Pertinent interventions included administering medication as prescribed, recording behaviors on behavior tracking form, monitoring patterns of behavior (time of day, precipitating factors, specific staff or situations), reminding the resident that behavior is not appropriate, removing the resident from the situation and allowing her time to calm down,staff to monitor and report aggressive behaviors or agitation, listening to resident ' s concerns, providing distraction and redirection, evaluating the resident for pain/discomfort, IDT team to review medication use quarterly and with significant changes, monitoring for side effects of the medication, visiting with family and upper management/staff, writing conversations down, and visiting with the restorative CNAs.
Further review of the resident ' s antipsychotic medication care plan revealed the behaviors warranting the use of Quetiapine included believing that staff was not taking care of her, that she had not seen her provider, and the resident was very resistant with care/medications.
Resident #33 ' s behavior tracking sheets, which were documented by the CNAs, were reviewed for 1/1/22 through 4/12/22. The behavior tracking sheets revealed the following:
-The resident exhibited mood behaviors (tearfulness, self-isolation, comments of wanting to die) on 1/6, 1/9 (tearful), 2/25 (tearful), and 3/8/22 (tearful);
-The resident exhibited rejection of care behaviors on 1/6 and 3/8/22;
-The resident exhibited verbal behaviors (e.g., threatening others, screaming at others, cursing at others) on 1/6 and 1/7/22 and,
-All other dates from 1/1/22 through 4/12/22 were documented as no behaviors were shown.
Review of Resident #33 ' s progress notes from 1/1/22 through 4/12/22 revealed there were no behaviors related to delusions or paranoia documented for the resident.
-Despite the CNA behavior tracking sheets documenting the resident exhibited behaviors on 1/6, 1/7, 1/9, and 2/25/22, nurses failed to document in the progress notes what behaviors Resident #33 exhibited on those dates.
-Despite the CNA behavior tracking sheets documenting the resident exhibited two behaviors on 3/8/22, the nurse documented only one behavior exhibited by the resident on that date.
D. Interviews
RN #1 was interviewed on 4/13/22 at 9:29 a.m. RN #1 said Resident #33 was often tearful during wound dressing changes but would calm down once she had finished performing the treatment. She said the resident did not have a lot of behaviors, but the resident would accuse the staff of not caring about her and not doing anything for her RN #1 said she usually just remained calm with the resident and tried to reassure her whenever they were providing care for her.
The ADON was interviewed on 4/14/22 at 12:12 p.m. The ADON said Resident #33 was admitted on [DATE] with an order for Quetiapine. She said the medication had been increased a couple of times since her admission because of her increased behaviors. The ADON said Resident #33 would often refuse care from the staff, make notes about her interactions with the staff and then not believe she was the one who wrote the notes, and the resident believed she knew what was best for her regarding all her cares such as repositioning and wound care. The ADON confirmed there were only a few behaviors documented on the CNA tracking sheets from 1/1/22 through 4/12/22 for Resident #33. She confirmed that there was a progress note on 3/8/22 regarding the resident ' s rejection of care, however the note did not document the resident ' s tearfulness. The ADON confirmed there were no behaviors documented in Resident #33 ' s progress notes on the other dates that the CNAs documented the resident had a behavior.
The ADON confirmed there were no behaviors related to Resident #33 exhibiting paranoia or delusional behaviors documented in the resident ' s progress notes.