SERIOUS
(G)
📢 Someone Reported This
A family member, employee, or ombudsman was alarmed enough to file a formal complaint
Actual Harm - a resident was hurt due to facility failures
Accident Prevention
(Tag F0689)
A resident was harmed · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Resident #56
A review of the Progress Notes section of the Electronic Medical Record (EMR) revealed the following:
10/31/2022 (...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Resident #56
A review of the Progress Notes section of the Electronic Medical Record (EMR) revealed the following:
10/31/2022 (8:15 a.m.) Incident Note . Heard yelling out- entered room and observed resident lying on the floor alongside her bed, head @ foot of bed and feet @ head of bed, on her right side . She was very incontinent of urine, in her PJ's, w/o (without) footwear on, alarm in place, not sounding .
During an interview on 11/29/22 at 3:24 p.m., Family Member (FM) X stated Resident #56 had falls a few days after her admission to the facility and ended up with two black eyes and bruised ribs with one out of place on August 19th, 2022. FM X stated she felt there were not enough staff to watch everybody. FM X stated she was ready to move Resident #56 out of the facility, but felt the staffing and care was much better now.
A review of the incidents for Resident #56 revealed the following:
A review of the incident report dated 6/10/22 at 6:30 p.m., revealed Resident #56 was heard yelling and was found lying on her back with blood coming from her right eyebrow. Non-skid shoes/socks were implemented after this fall.
A review of the incident report dated 8/21/22 at 8:50 p.m., revealed Resident #56 was observed on the floor in front of the clean linen room for the unit. Resident # 56 was unable to say what she was trying to do. There was no new intervention identified in this incident following the fall.
A review of the incident report dated 8/31/22 at 9:35 a.m., revealed Resident #56 was observed lying on her back, calling for help in the doorway of her room, and had fallen and hit her head. The incident report went on to discuss Resident #56 was persistently complaining of needing to go to the bathroom. Resident #56 was toileted after the fall and had a bowel movement.
A review of the incident report dated 10/31/22 at 7:13 a.m., revealed Resident #56 was heard yelling out and upon entering the room was found lying on the floor next to her bed on her right side.
On 11/29/22 at approximately 4:05 p.m., during an interview, the Director of Nursing (DON) was asked if non-skid shoes and socks would be a baseline care planning intervention for fall risk reduction. The DON stated yes, but Resident #56 would be one to take them off. The DON went on to stated Resident #56 was very ambulatory and often took herself to the bathroom. When asked if the other two interventions on her fall care plan should be baseline interventions, the DON agreed they would be considered baseline.
On 11/29/22 at 4:15 p.m., during a follow-up interview, the DON acknowledged the care plans were not where they needed to be and were in the process of being cleaned up. When asked if she felt a toileting program would be appropriate, the DON agreed a toileting program would be appropriate for Resident #56. The DON also acknowledged encouragement of a resident who lacks cognitive ability to use a call light should not be encouraged to use the call light as an intervention and would not be appropriate.
A review of the Minimum Data Set (MDS) assessment dated [DATE] for Resident #56, revealed short term and long term memory issues and Resident #56 was severely cognitively impaired.
A review of the care plan High risk for falls, with an initiation date of 6/17/22, had interventions which included the following:
Anticipate and meet (Resident #56)'s needs. Initiated on 6/17/22.
Be sure (Resident #56)'s call light is within reach and encourage (Resident #56) to use it for assistance as needed. Initiated on 6/17/22 and revised on 11/18/22.
Non-skid socks or shoes with non slip soles. Initiated on 6/10/22.
Provide activities that promote exercise and strength building where possible. Provide 1:1 activities if bedbound. Initiated on 6/10/22.
There were no other care planning interventions to address the falls sustained by Resident #56 on 8/21/22, 8/31/22 or 10/31/22.
Deficient Practice #2
Based on observation, interview, and record review, the facility failed to prevent an elopement from the facility for One Resident (#67) of two residents reviewed for elopement. This deficient practice resulted in the potential for further elopements. Findings include:
Resident #67
During an observation and interview on 11/28/22 at 2:01 p.m., Resident #67 was perseverating on going out to look at a fallen tree across the street. Resident #67 was upset that he was told he could not go and look at this tree that fell down. Resident #67 did not present as cognitively intact and demonstrated word salad communication at times during the interview.
A review of an Elopement incident dated 10/14/22, revealed Front Desk Staff FF had let Resident #67 out of the facility. Staff FF thought Resident #67 was a visitor and let him out when Resident #67 identified himself as a visitor and stated he needed to go outside and get the keys out of his car. Five staff were on the unit at the time of the incident and the incident occurred while staff were getting residents ready for dinner per witness statements.
A review of a Behavior Note dated 10/14/22 at 8:58 p.m., revealed the following:
During dinner today, (Resident #67) was actively exit seeking. With redirection he sat down to eat his soup. This nurse was at the med cart prepping medication when I heard CNA ([Certified Nurse Aide] HH) yellout(sic) hey that's (Resident #67)! to which this nurse looked up and saw (Resident #67) walking outside in the parking lot with his walker .I talked to the front desk asking how hegot(sic) out without the alarm going off to which he stated (Resident #67) knocked on the door and told the front desk he was a visitor and needed to go out to his car and grab his keys, to which the front desk let him out and entered the code to the door, so the alarm did not go off .The front desk was unaware of who (Resident #67) was and did in fact believe he was a visitor .
Author Licensed Practical Nurse (LPN) GG
During an interview on 11/30/22 at 8:06 a.m., the DON was asked why there was nothing in the body of the policy to address elopement prevention, only what to do when an elopement occurs. The DON acknowledged the policy should include education to staff on how to prevent elopements from happening in the first place, and to make sure they are not letting out residents without supervision. During this interview, Receptionist II proceeded to show this surveyor a binder kept at the receptionist desk which contained pictures of all the residents at the facility. Receptionist II stated the facility has always had this binder at the desk as far as she knew. The DON stated she was not aware of this binder being located at the reception desk. Both the DON and Receptionist II agreed staff who sat at the desk should be aware of the binder and check it before letting anyone off the units and out of the building.
During an interview on 11/30/22 at 3:49 p.m., LPN GG confirmed Staff FF had let Resident #67 off the unit and out of the facility under the premise he was a visitor and not an employee. LPN GG also confirmed Resident #67 was .very skillful in his exit seeking . and that she had educated Staff FF to please make sure to ask the nurse for the unit before letting anyone off the unit.
A review of the care plan Elopement risk, for Resident #67, with an initiation date of 8/12/12 had the following interventions:
1:1 staff as necessary when agitated and exit seeking Initiated on 8/15/22.
A name tag will be made up for (Resident #67) to be clipped to the back of his shirt to alert people that he is a resident of (facility). Initiated on 10/18/22.
A picture of (Resident #67) is posted throughout the facility. He will also wear a picture/resident ID tag(to be provided). Initiated on 8/12/22.
Call administrators cell phone number when agitated and unable to redirect so he can speak with him. Initiated on 8/12/22.
Distract (Resident #67) from wandering by offering pleasant diversions, structured activities, food, conversation, television, book. (Resident #67) prefers: Pepsi, talking about his past, Bingo, old shows and movies (TV land and westerns). Initiated on 8/12/22.
Monitor location every 15 min. (minutes) Document wandering behavior and attempted diversional interventions in behavior log. Initiated on 8/12/22.
Provide structured activities: toileting, walking inside and outside, reorientation strategies including signs, pictures and memory boxes. Initiated on 8/12/22.
(Resident #67) triggers for wandering/elopement are looking for his car, getting [NAME](sic), getting to work, etc (Resident #67) behaviors is de-escalated by redirecting and listed interventions. Initiated on 8/12/22.
The care plan provided by the facility did not show any new interventions to address Resident #67's specific elopement concern with staff not recognizing him and letting him out of the building.
There was no education provided to all staff when this occurred to prevent new and agency staff from making the same mistake as Staff FF. There were agency staff working in the building at the time of this survey. Staff also failed to provide 1:1 supervision per the care plan when he was identified as actively exit seeking just prior to the incident during the dinner meal.
This citation has 2 deficient practice statements (DPS) and pertains to intakes # MI00130986, #MI00132283 and #MI00125389.
Deficient Practice #1
Based on observation, interview, and record review, the facility failed to ensure thorough fall investigations were completed, interventions were in place, and new interventions were initiated to prevent falls for three Residents (#56,#62, and #66) out of six Residents reviewed for falls. This deficient practice resulted in repeated falls and a fall with fracture for Resident #62. Findings include:
Resident #62
On 11/28/22 at 11:33 p.m., Resident #62 (R62) was observed up in her wheelchair near the door of her room in the hallway. R62 was attempting to self propel herself into her room. She was noted with a wheelchair alarm and a seat belt in place. R62 was asked how she was doing but did not respond. At this time, RN K and CNA G were both at the nurses station, out of view of R62 going into her room alone. CNA G was noted to be using his cell phone under the desk.
On 11/29/22 at 12:27 p.m., R62 was observed self propelling in her wheelchair with her seat belt on back into her room.
On 11/30/22 at 12:45 p.m., R62 was observed up in her wheelchair with her seat belt on. Certified Nurse Aide (CNA L) was observed putting the footpedals on R62's wheelchair. R62 was wearing slip on slippers with no back to the slipper.
On 11/30/22 at approximately 4:21 p.m., R62 was observed in her wheelchair alone self propelling toward her bed and taking her slippers off leaving just her white socks on.
On 12/1/22 at 11:08 a.m., R62 was observed up in her wheelchair in the common area outside of her room self propelling. R62's seat belt as not in place and the right food pedal was still on the wheel chair.
A review of R62's medical record revealed she admitted to the facility on [DATE] with diagnoses including cerebrovascular disease, diabetes, and repeated falls. A review of her 9/6/22 Minimum Data Set (MDS) assessment revealed she scored 0/15 on the Brief Interview for Mental Status (BIMS) assessment, indicating severely impaired cognition. This review showed she did not walk during the review period, required the extensive assistance of two plus staff for transfers, and used a wheelchair. A review of her previous MDS dated [DATE] revealed she scored 10/15 on the BIMS assessment, indicating moderately impaired cognition, walked and transferred with the extensive assistance of one staff member, and used just a walker.
A review of a Physical Restraint/Alarm Evaluation/ Re-Evaluation for R62 dated 9/27/22 revealed the following: . Gets out of bed, stands from chair, recent hip fx (fracture) . Recommended three day trial of least restrictive physical restraint/alarm: Date : (blank) X Seat belt . There were no reminders checked off regarding the consent, order or care plan, and the final recommendation section was blank. There was no staff signature or signature date.
A review of R62's fall Investigation and Investigation forms revealed the following:
On 6/6/22 at 6:50 p.m., This nurse was in the nursing station getting report from (name of LPN R). We heard an alarm going off in the distance. I entered (R62's) room and observed (R62) sitting on the floor. (CNA J) was first in the room and saw the fall from the doorway. (R62) had stood up from her w/c and fell on her bottom . The Incident review form included the Intervention/Corrections implemented as Don't leave R62 unattended in her room (she does wheel herself in there so staff will need to be observant).
On 6/11/22 at 1:45 p.m. was a fall in the Residents bathroom. LPN R had a gait belt around R62 but was unable to stop the resident from falling.
On 7/1/22 at 4:40 a.m., (R62) was found by (CNAV) during bed checks. Resident was face down on floor . A review of CNA V's statement for this event revealed, .She (R62) was laying on her stomach next to bed . her pad alarm was in bed under her and did not activate (it was on). We did not hear anything and 2 of the 3 CNA's on unit were sitting in that side of living room close to room . and noted she last checked on the resident two hours prior. The Incident Review form noted, Her alarm was on but not in the proper place- she had moved them . Ensure alarms are in place during rounds. Review of the care plan revealed that the intervention to ensure alarms were out of R62's reach was already initiated on the care plan as of 1/27/21, and was revised on 5/3/22, and therefore should have been in place.
On 7/5/22 at 2:00 a.m.(R62) observed on the floor on her right side . head under head of bed . red area at right hip, slight pain on palpation . shrinkage noted at the time of EMS exam . on call physician called, okay to send out for right hip evaluation . A review of the Incident Review form revealed, (CNA N) had just done a purposeful round and the alarm was on. When (R62) fell it was turned off. It was functional. The first thought was to place the alarm out of her reach but the cords are not log enough . the final decision was to put hip protectors on her. A review of CNA Ns statement revealed, Was in nurses station opening (name of EMR) to chart and check residents heart a loud crash noise ran to residents room and found her on the floor .
On 7/9/22 at 6:40 p.m., .(CNA P), she states '(R62) is on the floor' this nurse entered the room and (R62) was observed on the floor on her left side . the alarm pad was observed between (R62's) legs and a towel around it. The alarm was 'on' but was not sounding due to the towel . The Incident Review form intervention was, Do not put a towel around the safety alarm. This was already a care planned intervention initiated in May 2022, that was not implemented prior to this fall.
On 7/22/22 at 8:15 p.m., Nursing description: Walked by (R62's) room and witnessed her on floor of her room . (R62) has an indwelling foley catheter and the drainage bag was attached to the bed when she got up. She recently had an increased (sic) in her Sinemet d/t (due to) frequent falls . An email statement was attached to the report written by LPN U which revealed, This writer found (R62) on the floor she was sitting on her R (right) side with both hands on the floor . Her foley catheter bag was still attached to the bed . At the time of the fall she was lying in bed with slipper socks on but the alarm was not turned back on by the CNA when (R62) was last repositioned . There was no documentation of who the CNA was that failed to turn the alarm on and no indication if they were disciplined or educated. The intervention per the Incident Review form revealed, If (R62) is restless at night bring her out of her room for better observation and to lower her risk of falls.
On 8/21/22 at 9:25 p.m., Heard (CNA J) calling out, 'Fall' . (R62) lying beside her bed with her right hand hanging onto the side rail. Her upper body and head were elevated off the floor. Blood was dripping from her right elbow . checked over again once back in bed. (R62) started to c/o (complain of) pain in her right upper leg. Pain was 10/10 when leg was palpated or moved slightly . EMS called @ (at) 2240 (10:40 p.m.) and here by 2250 (10:50 p.m.) . EMT's examined and questioned (R62) . pain was now 1/10 . she denied significant pain . Decision made not to send her to (Name of Hospital) . Foley tubing pulled taut when she got up. Hip protectors checked and on @ all times. They were not on . A statement from CNA J revealed, I heard bed alarm and saw call light flashing. Ran to (R62's) room and she was on the floor . I pull(sic) the alarm and call light out of the way and yelled for the nurse . A summary of the incident revealed, .The following Monday morning .she was still having pain of 10 out of 10 and ordered a 3-view X-ray of her right hip and a 2-view x-ray of her right femur. The results came back as a displaced fracture of the right femoral neck. She was then transported to (name of Hospital) for repair . The interventions for this fall are to place the foley bag in a basin on the floor. This is so when she gets up it is not hooked to the bed . She does have hip protectors ordered. At the time of the fall they had been taken to laundry and were drying .
On 9/22/22 at 4:35 p.m., (LPN R) called to (R62's) room by (CNA P), (R62's) electric recliner was in the standing position. (R62) was lying on her left side on the floor in front of her chair, eye glasses lying on the floor lens missing . noted 3 cm wide bump on her forehead left of center . redness to left patella (knee) . A review of a witness statement with no name or date of writing revealed, At nurses station: Last saw (R62) at 4:20 pm - place ice pack on R (right) hip for c/0 pain. A review of a written summary for this event revealed, . It was apparent that (R62) had taken the control and lifted the chair into an upright position and then slid out onto her left knee and forehead. The lift control was removed and will be kept out of her reach . A review of the care plan revealed no intervention was initiated to keep the recliner control out of reach.
On 9/26/22 at 5:15 p.m., (R62) was in the west living room. Sitting after an activity with a group of others. (LPN R) was in and out of the living room, passing medications. (R62's) alarm went off (LPN R) went to the alarm and saw (R62) holding herself off the floor by holding the wheel chair handle of the wheel chair in front of her . (R62's) feet and lower legs were caught in the foot pedals of her wheel chair . A review of the incident summary for this fall revealed, . Her feet were under her wheelchair foot pedals . There was (sic) 4 staff present on the floor at the time. The intervention was to have (R62) in line of sight anytime she is in the wheelchair . No new interventions regarding not leaving R62 with her foot pedals on the wheelchair unattended or when not being pushed. There was also no indication in the report if R62 had removed her own seat belt, or if it had not been placed back on by staff.
On 11/25/22 at 7:25 a.m., (Nurses summary left blank) . other info: (R62) was attempting to get out of bed by herself. Alarm was sound but staff was unable to get to her before her knees were on the mat beside her bed. She was barefoot . Review of a witness statement by CNA M revealed, I was in the nurses station talking about Tksgvng (Thanksgiving) w/ (RN K) . Her (R62's) light went off, our convo (conversation) came to a stop as we made our way to (R62's) room. Her bed was all the (sic - way) to the floor her mat was in place, but her knees touch the mat. That was her fall. Under the section of when the resident was last checked, CNA M wrote, Last rounds.
On 12/1/22 at 11:11 a.m., an interview was conducted with the Director of Nursing (DON) regarding R62's falls. When asked about the 7/1/22 fall where it indicated CNA's were sitting in the common area when it occurred, the DON made no comment. The DON was asked about the multiple falls (7/1/22 and 7/5/22 for example) where R62 was accused of turning her alarms off despite the care planned intervention from 2021 to keep the bed alarm out of reach. The DON stated, I don't remember if we got a longer cord? I don't remember to be honest. When asked about the 7/9/22 fall (alarm was wrapped in a towel), the DON stated, I don't know why they wrap it in a towel. Anyway's I talked to them and said don't do that . The DON was asked if since it was a previous fall intervention not to do that, if the CNA who had done it was disciplined or educated one on one for not following the care plan. The DON stated, It does (happen) if we can identify who it was (that did it), but I can't write everybody up if you don't know. When asked about the 7/22/22 fall (CNA did not turn alarm back on) the DON reported she didn't recall that fall and may not have been at the facility during that time. When asked about the 8/21/22 fall (hip protectors were not put on), the DON stated, That was (CNA J) . they (hip protectors) were both in the laundry room, one was drying and the other in a basket. After that we put two more pairs in the treatment room. When asked about there not being a discipline or education in CNA J's record for neglecting to follow the care plan and the fall resulting in a fracture, the DON just stated, She got educated. When asked if R62 was wearing appropriate footwear during the 9/22/22 fall, the DON reported, If you didn't see it (documentation) it probably wasn't there We generally make people take those (nonskid slippers) home. The ones you put your foot in and it just slides in, those are dangerous too. When asked if R62 had her alarming seat belt in place during the 9/26/22 fall as it was not noted in the report, the DON reported initially the belt was just a normal seat belt that didn't alarm. When asked about the foot pedals being left on if staff weren't around, the DON reported that she didn't know, but that staff have to have them on to push her. When asked about the 11/25/22 fall the DON indicated she was still investigating it. When asked about the concern of staff sitting at the nurses station and residents being found on the floor because the alarms are not answered in time, the DON reported the facility had already recognized that as an issue and were going to be fixing that. When asked about the intervention of R62 not having access to the recliner control, the DON provided no comment.
A review of R62's fall care plan initiated on 6/6/21 revealed the following: .a seat belt will be placed on (R62's) wheelchair (9/28/22) .be sure (R62's) call light is within reach and encourage the (sic) her to used it . (6/6/21) . Bed alarm while in bed in addition continue to activate chair alarm when up. Place bed alarm control box out of (R62's) reach @ (at) all times. (initiated 1/27/21, revised 5/3/22). Do not leave (R62) in her room unattended in her w/c (wheelchair). She tends to self transfer to her recliner or bed. (6/7/22). Do not wrap alarm pad in a towel or place anything around it, the pressure/weight will prevent the alarm from sounding (7/9/22) . If she is awake at that time she should be assisted with morning care and brought out to the dining room (11/25/22) . Ensure seatbelt alarm is turned on when in w/c (9/29/22). Ensure that (R62) is wearing appropriate footwear-tennis shoes, when ambulating with her walker (initiated 6/6/21, revised 11/21/22). Ensure the alarms are in place during rounds (7/7/22) . Frequent purposeful rounds when (R62) is in her room (Initiated 5/20/22, revised 11/21/22). Gripper socks when in bed (8/22/22) . Hip protectors at all times (7/6/22) . If (R62) is restless bring her out of her room at night to better observe her and lower her risk of falling (initiated 7/22/22, revised 8/1/22). (R62) has 2 pair of hip protectors - if both are in laundry there are 2 spare pair in the household and a new pair in storage (9/19/22) . (R62) has been placed on high risk fall list. Her light is a priority (initiated 5/7/22, revised on 11/21/22) .(R62) uses a bed alarm on the back of her recliner and a chair alarm on the seat of her recliner. Make sure both are on when (R62) is in her recliner (6/21/22). (R62) uses pancake alarm. Ensure the device is in place and working properly (6/6/21). Make sure chair alarm is on and in working order (12/21/21). Make sure that (R62) has two cough drops on her bedside table (initiated 10/5/21, revised 11/21/22). Mat to be placed beside (R62's) bed while in it (8/22/22) . Safety alarm is not to be placed under cushions. blankets, or other items, as the additional weight/pressure prolongs the alarming (initiated 3/23/22, revised 9/27/22) .
Between 7/1/22 and 12/1/22, R62 had eight falls. During three of the falls (7/22/22, 8/21/22, and 11/25/22), care planned interventions were not implemented and the 8/21/22 fall resulted in a fall with fracture and a decline in physical status. Two other falls documented R62 as turning her own fall alarm off, despite previous interventions to place the bed alarm box out of reach.
Resident #66
On 11/28/22 at 11:36 a.m., Resident #66 (R66) was observed in her wheelchair near the staff bathroom. R66 was wearing a seatbelt and there was an alarm on her wheelchair as well. R66 was asking about the staff bathroom and when asked if she needed to go to the bathroom she stated she did.
On 11/29/22 at 12:27 p.m., R66 was observed up in her wheelchair with the seatbelt on in the common area and hallway of her unit. Resident was being guided to the dining area for lunch.
On 11/30/22 at 12:45 p.m., R66 was observed seated at the dining room table. She started to push her wheelchair backward and undid her seatbelt which started to alarm, and exclaimed Its loud! CNA M went over to R66 and stated, You keep unplugging it that's why it's being loud. Put it back together. R66 buckled the seatbelt and pushed R66 back toward the table. R66 started, to say I don't which CNA M interrupted with Do you need to do something? R66 quietly stated, Well no. CNA M informed R66 that she had not finished her lunch.
On 11/30/22 at 4:20 p.m., R66 was in the common area of the unit and was observed unplugging her seat belt. Licensed Practical Nurse (LPN) R encouraged R66 to re-buckle her seat belt. LPN R stated to R66, Can you hook that up? Do you know why its on? to which R66 stated, Because they don't want me getting out. Approximately two minutes later R66 unplugged her seat belt again, and CNA O asked her to keep her seat belt on. R66 then asked this CNA O who was carrying a load of laundry to a room if she could help her and the CNA O responded No.
On 11/30/22 at approximately 4:24 p.m., R66 was asked was observed aimlessly self propelling in the common area. When asked if there were any activities or things for her to do, R66 stated, Not really.
A review of R66's medical record revealed she admitted to the facility on [DATE] with diagnoses including dementia, adjustment disorder, adult failure to thrive, and history of falling. A review of the most recent 11/1/22 Significant Change MDS Assessment revealed she scored 3/15 on the BIMS assessment, indicating severely impaired cognition and had no falls since readmission or the previous assessment. R66 was assessed as needing extensive assistance of two staff for toileting and bed mobility, and extensive assistance of one staff for ambulation. A review of her MDS assessment dated [DATE] revealed she required only supervision of one staff for toileting and bed mobility, no supervision or assistance for transfers, and just supervision of one staff for ambulation requiring no mobility devices.
A review of a Facility Reported Incident (FRI) investigation for R66 for a Fracture of Unknown Source on 10/25/22 revealed the following: .At around 2130 (9:30 p.m.) (RN W) heard (CNA J) call out for help. (RN W) and (CNA P) responded to her call and observed (CNA J) supporting (R66) in the doorway to her room. (CNA J) stated that (R66) had cried out and said she could not walk. When (CNA J) heard her she was standing in the doorway. (R66) had been able to walk from her bed to the doorway without calling out. (R66) was very unsteady and complained of right knee pain. (R66) denied that anything happened and said she did not fall . once in bed (RN W) stated that (R66) again pointed to her kneed but then ran her hand up her thigh indicating that area hurt as well . The following morning (CNA M) called for (LPN R) to come to (R66's) room as she was having pain and she could not sit up or move her right leg without crying out . She (R66) had facial grimacing and was reluctant to move . There was no bruising or redness or any visible indication that she may have fallen . EMS transported (R66) to (name of Hospital) . an x-ray was done which revealed a mildly displaced fracture of the femoral neck without dislocation . (R66) had surgical repair of her hip at (Name of Hospital) on 10/25/22 and tolerated it well . This investigation did not have a conclusion section to discuss the investigation of the possible cause of the injury.
A review of the witness statement written by RN S on the morning R66 was found unable to walk revealed, .(LPN R) stated (R66) has not been able to get out of bed this morning - and she (is) screaming in pain when R (right) thigh/hip is palpated . This RN attempted to palpate area - (R66) screamed in pain . no markings to show of any type of fall. Staff state no fall - (R66) stated 'I Fell' but unable to say how or when. (R66) is confused at baseline .
A witness statement written by CNA J written 10/25/22 revealed, In living room with another resident when I heard (R66) yelling she needed help because she can't walk. Ran to her she at doorway was standing and tipping side ways. I put my arms around her and steady her and yelled for help. Waited for other staff to help assist/walk her to her bed . when asked what happened or if she fell she said No I don't know what happen (sic). This statement revealed R66 was last checked at 8:30 p.m. (an hour prior) and was noted to be sleeping at the time.
A review of R66's incident and accident reports revealed the following:
11/6/22 4:50 p.m. (R66) had been sleeping in the recliner in the west lounge. This nurse (LPN R) and (CNA H) heard (R66's) chair alarm sounding, (LPN R) and (CNA H) were in the nurse's station and went running to the west lounge, before reaching the lounge there was a loud noise, found (R66) on her knees f[TRUNCATED]
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0578
(Tag F0578)
Could have caused harm · This affected 1 resident
Based on interview and record review, the facility failed to ensure competency evaluation was completed per state law for two Residents (#56 & #67) of four residents reviewed for advance directives. T...
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Based on interview and record review, the facility failed to ensure competency evaluation was completed per state law for two Residents (#56 & #67) of four residents reviewed for advance directives. This deficient practice resulted in the potential for a Durable Power of Attorney (DPOA) acting on behalf of residents unnecessarily, and potentially making life ending decisions against resident's wishes. Findings include:
Resident #56
A record review on 11/28/22 at 3:25 p.m., revealed a Physician Orders for Scope of Treatment (POST), signed and dated on 6/6/22 by Family Member (FM) X. There was no evidence in the Electronic Medical Record (EMR) to suggest a competency evaluation had been completed by two physicians as required by state law. There was also no DPOA paperwork available to view in the EMR.
On 11/28/22 at approximately 4:45 p.m., a request was made for the facility to provide evidence of DPOA paperwork and competency evaluations to show FM X was legally able to make medical decisions for Resident #56.
During an interview on 11/29/22 at 3:00 p.m., Social Services (SS) BB presented this surveyor with DPOA paperwork from another state for Resident #56. SS BB stated she thought the paperwork stated the medical DPOA was assigned to the daughter (FM X). The paperwork reviewed designated FM X as Resident #56's health care representative, but she was not granted medical DPOA for Resident #56. SS BB stated the following line meant the DPOA was active: I have executed this Financial and Medical Power of Attorney on this 7 day of July, 2020. SS BB was informed this line in the document simply acknowledged the DPOA paper work was signed as being legally enforceable if the DPOA was ever needing to be activated, not that the DPOA was already activated. SS BB was informed the state required signatures from two separate physicians to establish competency or lack thereof. SS BB stated there was no documentation of Resident #56 being evaluated by two physicians for capacity to consent.
Resident #67
On 11/28/22 at 4:34 p.m., a review of the EMR revealed only one physician signature had been obtained to establish Resident #67 lacked capacity to consent.
On 11/28/22 at approximately 4:45 p.m., the facility was asked to provide a second signature from a physician determining Resident #67 lacked capacity to consent.
During an interview on 11/29/22 at 3:00 p.m., SS BB stated the DPOA paperwork language indicated activation required only the primary physician was needed to evaluate for competency to activate the medical DPOA. A review of the document revealed the DPOA required only the signature of the primary physician was required for activation. SS BB was informed state law still required two physicians must sign to determine a resident lacks the capacity to consent. A request for the policy on Advance Directives was requested.
No policy was received from the facility by the time of exit on 12/1/22 at 12:30 p.m.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0604
(Tag F0604)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview, and record review, the facility failed to ensure that restraint evaluations with appropriate in...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview, and record review, the facility failed to ensure that restraint evaluations with appropriate indications for use and physicians orders were in place for two Residents (#62 and #66) out of two residents reviewed for restraints. This deficient practice resulted in the potential for injury or feelings of loss of freedom. Findings include:
Resident #62
On 11/28/22 at 11:33 p.m., Resident #62 (R62) was observed up in her wheelchair near the door of her room in the hallway. R62 was attempting to self propel herself into her room. She was noted with a wheelchair alarm and a seat belt in place. R62 was asked how she was doing but did not respond.
On 11/29/22 at 12:27 p.m., R62 was observed self propelling in her wheelchair with her seat belt on back into her room.
On 11/30/22 at 12:45 p.m., R62 was observed up in her wheelchair with her seat belt on. Certified Nurse Aide (CNA L) was observed putting the footpedals on R62's wheelchair. R62 was wearing slip on slippers with no back to the slipper.
A review of R62's medical record revealed she admitted to the facility on [DATE] with diagnoses including cardiovascular disease, diabetes, and repeated falls. A review of her 9/6/22 Minimum Data Set (MDS) assessment revealed she scored 0/15 on the Brief Interview for Mental Status (BIMS) assessment, indicating severely impaired cognition. This review showed she did not walk during the review period, required the extensive assistance of two plus staff for transfers, and used a wheelchair. A review of her previous MDS dated [DATE] revealed she scored 10/15 on the BIMS assessment, indicating moderately impaired cognition, walked and transferred with the extensive assistance of one staff member, and used just a walker.
A review of R62's physician orders revealed no order for the use of the seat belt restraint.
A review of a Physical Restraint/Alarm Evaluation/ Re-Evaluation for R62 dated 9/27/22 revealed the following: . Gets out of bed, stands from chair, recent hip fx (fracture) . Recommended three day trial of least restrictive physical restraint/alarm: Date : (blank) X Seat belt . There were no reminders checked off regarding the consent, order or care plan, and the final recommendation section was blank. There was no staff signature or signature date.
On 11/30/22 at 3:26 p.m., the Director of Nursing (DON) was asked about the unfinished assessment and lack of signature for R62's restraint assessment as well as the lack of physician order for use of the restraint. The DON reported it was her mistake, and that the assessment was scanned before she could finish it or sign it. The DON reported she knew the restraint needed a physician order, but that it was missed.
A review of R62's fall care plan initiated on 6/6/21 revealed the following: .a seat belt will be placed on (R62's) wheelchair (9/28/22) .
A review of R62's care plan for the seat belt was initiated on 11/3/22 and revealed, (R62) uses a seat belt alarm d/t (due to) inability to ambulate independently since her hip fracture . (Interventions) I often forget that I cannot stand independently so please respond quickly if my alarm rings (11/3/22) .
Resident #66
On 11/28/22 at 11:36 a.m., Resident #66 (R66) was observed in her wheelchair near the staff bathroom. R66 was wearing a seatbelt and there was an alarm on her wheelchair as well. R66 was asking about the staff bathroom and when asked if she needed to go to the bathroom she stated she did. This surveyor went to the nurses station to report R66's request for assistance.
On 11/28/22 at 12:38 p.m., R66 was observed at a dining table waiting for the lunch meal with her seat belt on.
On 11/29/22 at 12:30 p.m., R66 was observed being pushed up to dining room table in wheelchair with seat belt on by RN K.
On 11/30/22 at 12:45 p.m., R66 was observed seated at the dining room table. She started to push her wheelchair backward and undid her seatbelt which started to alarm, and exclaimed Its loud! CNA M went over to R66 and stated, You keep unplugging it that's why it's being loud. Put it back together. R66 buckled the seatbelt and pushed R66 back toward the table. R66 started, to say I don't which CNA M interrupted with Do you need to do something? R66 quietly stated, Well no. CNA M informed R66 that she had not finished her lunch.
On 11/30/22 at 4:20 p.m., R66 was in the common area of the unit and was observed unplugging her seat belt. Licensed Practical Nurse (LPN) R encouraged R66 to re-buckle her seat belt. LPN R stated to R66, Can you hook that up? Do you know why its on? to which R66 stated, Because they don't want me getting out. Approximately two minutes later R66 unplugged her seat belt again, and CNA O asked her to keep her seat belt on. R66 then asked this CNA O who was carrying a load of laundry to a room if she could help her and the CNA O responded No.
A review of R66's medical record revealed she admitted to the facility on [DATE] with diagnoses including dementia, adjustment disorder, adult failure to thrive, and history of falling. A review of the most recent 11/1/22 Significant Change MDS Assessment revealed she scored 3/15 on the BIMS assessment, indicating severely impaired cognition and had no falls since readmission or the previous assessment. R66 was assessed as needing extensive assistance of two staff for toileting and bed mobility, and extensive assistance of one staff for ambulation. A review of her MDS assessment dated [DATE] revealed she required only supervision of one staff for toileting and bed mobility, no supervision or assistance for transfers, and just supervision of one staff for ambulation requiring no mobility devices. The 9/27/22 MDS had no alarms or restraints documented, but the 11/1/22 MDS revealed she had three alarms in place daily (bed, chair, and other).
A review of R66's medical record revealed she was found to have a right femoral fracture on 10/25/22 after a potential unwitnessed fall 10/24/22. R66 had surgical repair of the fracture and was readmitted to the facility on [DATE].
A review of R66's physicians orders revealed no order for a seat belt or seat belt alarm.
A review of a Physical Restraint/Alarm Evaluation/Re-evaluation assessment for R66 signed on 10/28/22 revealed the following: X admission . Current least restrictive physical restraint/alarm in place: X tab alarm. X sensor pad . Gets out of bed, stand from chair, odes not call for help, does not remember she broke her up . Recommend three day trial of least restrictive physical restraint/alarm: Date: 10/28/22: X seat belt . X institute consent form as necessary. X Add to care plans, treatment sheets at time of trial recommendation and final recommendation. This was a three-day trial assessment and the Final Recommendation portion was blank.
A document titled, Physical Restraints Record of Informed Consent for R66 showed Verbal consent POA . was listed under the signature dated 10/28/22, but the form was not completed with a check of whether consent was or wasn't given, and did not include the type of restraint or reason for use.
A review of a progress note for R66 revealed, 11/29/22 . (R66) did remove her seat belt a few times this shift, redirect to buckle and she complied. She also complained about the alarm sounding, re-assured that it was there for her safety.
A review of R66's falls care plan initiated 4/7/22 revealed, (R66) is high risk for falls . (Interventions) A belt alarm in my wheelchair may help me remember to only get up with assistance (10/28/22) . I have had a hip fracture and may forget I need assistance .(10/27/22) . The Resident needs activities that minimize the potential for falls while providing diversion and distraction. While (R66) is in the wheelchair, please provide activity that (R66) enjoys doing like folding laundry or cleaning tables. She typically is at fall risk because she is trying to do these things while standing up from her wheelchair to reach an item .(11/9/22) .
A review of R66's seat belt care plan initiated 11/3/22 revealed, (R66) has a seat belt alarm r/t (related to) inability to ambulate indecently (sic?) d/t her recent hip fracture . (Interventions) I can release the seat belt by myself but please reposition me and offer to toilet me every 2 hours (11/3/22). If I am attempting to get up from my wheelchair please take me for a walk with my gait belt, walker, and a w/c following me (11/3/22). When my alarm goes off please respond quickly (11/3/22). There were only those three interventions.
On 12/1/22 at approximately 11:31 a.m., the DON was asked about the lack of physician's order for R66 and reported that it had been missed.
A review of the facility policy titled, Use of Restraints dated 3/14 revealed the following, Restraints shall only be used for the safety and well-being of the residents and only after other alternatives have been tried unsuccessfully. Restraints shall only be used to treat the resident's medical symptom(s) and never for discipline or staff convenience, or for the prevention of falls . 5. Restraints may only be used if/when the resident has a specific medical symptom that cannot be addressed by another less restrictive intervention AND a restraint is required to: a. treat the medical symptom; b. protect the residents safety; and c. help the resident attain the highest level of his/her physical or psychological well-being. 6. Prior to placing a resident in restraints, there shall be a pre-restraining assessment and review to determine the need for restraints . 8. Restraints shall only be used upon the written order of a physician and after obtaining consent . the order shall include the following: a. the specific reason for the restraint (as it relates to the resident's medical symptom); b. How the restraint will be used to benefit the resident's medical symptom); and c. The type of restraint, and period of time for the use of the restraint
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Investigate Abuse
(Tag F0610)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview, and record review, the facility failed to ensure an allegation of potential abuse toward one Re...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview, and record review, the facility failed to ensure an allegation of potential abuse toward one Resident (#66) was investigated and reported out of five residents reviewed for abuse. This deficient practice resulted in the potential for continued, unidentified abuse and the potential for harm. Findings include:
Resident #66
A review of R66's medical record revealed she admitted to the facility on [DATE] with diagnoses including dementia, adjustment disorder, adult failure to thrive, and history of falling. A review of the most recent 11/1/22 Minimum Data Set (MDS) assessment revealed she scored 3/15 on the Brief Interview of Mental Status (BIMS) assessment, indicating severely impaired cognition and was not presenting any behavioral concerns.
A review of an Employee Disciplinary Notification for Certified Nures Aide (CNA) J dated 4/14/22 revealed the following: Verbal warning . Minor Infractions: X Inappropriate Communication with Residents/Families/Visitors . There was an interaction between you and a resident with dementia that turned argumentative and in turn upset the resident. As a CNA on a dementia unit you need to understand that their thoughts are real to them and those thoughts are not based on reality . It is also not appropriate to make statements such as you are getting paid to care for them and then continue to argue with the resident using inappropriate language . We realize that burnout occurs however we cannot transfer that to our residents thorough (sic) our actions . If not then you will need to be more cognizant of what your residents are dealing with and meet them at that level, not argue or belittle, and treat them with respect. This was signed by the Director of Nursing (DON) on 4/19/22 but under the employee signature it was written Ref (refused) to sign.
A review of an employee concern form written on 4/13/22 by CNA T with an incident date of 4/12/22. The written statement included the following in part, . I (CNA T) overheard (R66) telling (CNA J) that (R66) was upset that her family would leave her hear and that (R66) just wanted to go home. (CNA J) said something along the lines of 'you have no choice but to stay here' which (R66) replied with 'the he** I am.' (CNA J) then said to (R66) 'are you swearing at me? That is SO disrespectful, don't swear at me.' (R66) was confused and that just escaladed (sic) (R66's) frustration and confusion . (R66) was following her (CNA J) asking her why she was treating her that way and why she needs to stay here. (CNA J) was hollering at (R66) 'I am paid to take care of you and you will be staying here, you have no choice. Take it up with your family an./or your DR (daughter) in the AM.' I (CNA T) could not listen to (CNA J) argue with (R66) anymore . I grabbed (R66's) hand and asked her if she would come walk with me. (CNA J) was still trying to argue with (R66) . (R66) kept asking why someone would treat her that way . I have not seen this side of (R66) since she has arrived her. (R66's) feelings were extremely hurt . This isn't abnormal behavior for (CNA J) to be rude and short with residents .
On 11/30/22 at 4:18 p.m., the Director of Nursing (DON) was asked if the altercation between R66 and CNA J was reported to the state agency. The DON stated, Probably not. When asked about CNA J not signing the statement, the DON stated, No, they usually don't. They think if they don't sign it then it (the write up) doesn't count.
On 11/30/22 at 4:24 p.m., R66 was observed in her wheelchair in the common area of her unit. When asked if she liked the staff who took care of her, R66 stated, Some I do, some I don't. When asked if the staff were ever mean to her or treated her unkindly, R66 stated, Well sometimes they say things that aren't nice. When asked if she reported it to anyone, R66 stated, No, because you know where it will go and they (staff) might get worse, and then you're just stuck here. R66 would not provide any of the names of the staff she was referring to.
On 12/1/22 at approximately 11:31 a.m., the DON was asked for an investigation regarding the CNA J and R66 altercation from May 2022. The DON reported that it wasn't substantiated. When asked if she had an investigation regarding the incident, the DON reported she did not have a written one. When asked to provide CNA Js statement regarding the event, the DON reported she didn't have one and that CNA J had refused to sign the write up or say what happened, but that she didn't say it in that manner. The DON stated about CNA J, (CNA J) gets defensive and tough . She gives good care and is rough around the edges and sometimes its taken as being rude. The DON was asked if R66 was interviewed and reported that R66 didn't remember the incident and did not have a statement for her.
A review of the facility policy titled, Abuse, Neglect, and Exploitation dated October 2022 revealed, .Alleged Violation is a situation or occurrence that is observed or reported by staff, resident, relative, visitor or others but has not yet been investigated an, if verified, could be indication of noncompliance with Federal requirements related to mistreatment, exploitation, neglect, or abuse . A. An immediate investigation is warranted when suspicion of abuse, neglect, or exploitation, or reports of abuse, neglect, or exploitation occur . A. The facility will have written procedures that include: 1. Reporting of all alleged violations to the Administrator, state agency, adult protective services and to all other required agencies .
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0625
(Tag F0625)
Could have caused harm · This affected 1 resident
Based on interview and record review, the facility failed to ensure written information was provided to two Resident/Representatives (#11 & #13) of three reviewed for written notice of bed hold. This ...
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Based on interview and record review, the facility failed to ensure written information was provided to two Resident/Representatives (#11 & #13) of three reviewed for written notice of bed hold. This deficient practice resulted in the potential for residents/representatives being unaware of incurring expenses related to reserve payment. Findings include:
Resident #11
A review of the Progress Notes, in the Electronic Medical Record (EMR), for Resident #11, revealed the following:
11/27/2022 10:33 (a.m.) Nurses Notes Late Entry: . Resident (#11) . This nurse note that he was shallow breathing and appeared to be in distress. Vital signs:165/77 (blood pressure), 97.3 (temperature), 102 (heart rate), 26 (respirations), 85-90% (oxygen saturation) on room air. He exhibited absence of lung sounds in bilat. (bilateral) lower bases an decreased in bilat. upper lobes. He was shallow breathing and struggling . Sound Physicians was notified and wanted him sent to (local Hospital) ER (emergency room) for eval (evaluation) . The ambulance arrived at 1135 (11:35 a.m.) and left with him, via a gurney, at 1145 (11:45 a.m.) . (DON [Director of Nursing]) . requested this nurse call the ER and have them test him for Legionnaires d/t (due to) his HX (history) of this and it being active w(with)/in this building .
A review of the EMR revealed no evidence of a written bed hold notice provided to Resident #11 or Resident Representative.
On 11/30/22 at 2:38 p.m., during an interview, Registered Nurse (RN) CC was asked if there was evidence of a written bed hold notice provided to Resident #11 or the Resident Representative. RN CC stated she was reminded by facility leadership that she was responsible for ensuring the written bed hold notice was provided to residents /resident representatives. RN CC acknowledged she had missed providing these as part of her responsibilities.
Resident #13
A review of the Progress Notes, in the EMR, for Resident #13, revealed the following:
9/18/2022 (3:06 p.m.) Infection Note . Sound physicians contacted and orders received to . (local hospital) for eval (evaluation) .
A review of the facility documentation related to the hospitalization of Resident #13 revealed she was sent out for respiratory arrest on 9/18/22. Further review determined the concern was distress and not arrest.
There was no evidence of written notice of a bed hold presented to the Resident (#13)/Resident Representative in the EMR.
On 11/30/22 at 10:36 a.m., during an interview, Registered Nurse (RN) CC was asked to provide evidence of written notice for the facility bed hold policy being provided to Resident #13 or a Resident Representative.
On 11/30/22 at 2:38 p.m., during a follow-up interview, RN CC stated she was reminded by facility leadership she was the staff person responsible for providing notifications for bed hold policy. RN CC stated this was part of her job and acknowledged she missed this required task.
A review of the facility policy, Bed Hold, dated 12/2008, read in part:
1. When the resident has a temporary absence from the (facility), (facility) will hold a bed open for the resident based on the resident/responsible party's request to do so. This will be done based on a reasonable expectation that the resident will return and (facility) has received payment for the absent period.
2. Written information concerning (facility) Bed Hold Policy will be provided to the resident/responsible party upon admission to (facility) and whenever the resident is transferred and/or admitted to another facility .
. 4. Acceptance or denial of the offering of a bed hold will be documented in the resident's record. The family will be requested to sign the bed hold agreement form indicating acceptance or refusal. If a bed hold is requested, the facility will require a five-day advance deposit billed at the daily rate. The bed hold starts on the day the resident leaves the facility. If determined, during the five-day bed hold period, that resident is not able to come back to (facility) for whatever reason, please note that the bed hold charges will still be applicable up through the day that the resident returns to (facility). If the resident returns before the five days are exhausted, then the bed hold deposit may be credited toward the next absence from (facility) or refunded during the monthly billing cycle.
CONCERN
(D)
📢 Someone Reported This
A family member, employee, or ombudsman was alarmed enough to file a formal complaint
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0657
(Tag F0657)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on interview and record review, the facility failed to revise care plans for 2 Residents (#56 & #67) of 18 residents revie...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on interview and record review, the facility failed to revise care plans for 2 Residents (#56 & #67) of 18 residents reviewed for care planning. This deficient practice resulted in the potential for further incidents related to falls and elopements. Findings include:
Resident #56
A review of the Progress Notes section of the Electronic Medical Record (EMR) revealed the following:
10/31/2022 (8:15 a.m.) Incident Note . Heard yelling out- entered room and observed resident lying on the floor alongside her bed, head @ foot of bed and feet @ head of bed, on her right side . She was very incontinent of urine, in her PJ's, w/o (without) footwear on, alarm in place, not sounding .
During an interview on 11/29/22 at 3:24 p.m., Family Member (FM) X stated Resident #56 had falls a few days after her admission to the facility and ended up with two black eyes and bruised ribs with one out of place on August 19th, 2022. FM X stated she felt there were not enough staff to watch everybody. FM X stated she was ready to move Resident #56 out of the facility, but felt the staffing and care was much better now.
A review of the incidents for Resident #56 revealed the following:
A review of the incident report dated 6/10/22 at 6:30 p.m., revealed Resident #56 was heard yelling and was found lying on her back with blood coming from her right eyebrow. Non-skid shoes/socks were implemented after this fall.
A review of the incident report dated 8/21/22 at 8:50 p.m., revealed Resident #56 was observed on the floor in front of the clean linen room for the unit. Resident # 56 was unable to say what she was trying to do. There was no new intervention identified in this incident following the fall.
A review of the incident report dated 8/31/22 at 9:35 a.m., revealed Resident #56 was observed lying on her back, calling for help in the doorway of her room, and had fallen and hit her head. The incident report went on to discuss Resident #56 was persistently complaining of needing to go to the bathroom. Resident #56 was toileted after the fall and had a bowel movement.
A review of the incident report dated 10/31/22 at 7:13 a.m., revealed Resident #56 was heard yelling out and upon entering the room was found lying on the floor next to her bed on her right side.
On 11/29/22 at approximately 4:05 p.m., during an interview, the Director of Nursing (DON) was asked if non-skid shoes and socks would be a baseline care planning intervention for fall risk reduction. The DON stated yes, but Resident #56 would be one to take them off. The DON went on to stated Resident #56 was very ambulatory and often took herself to the bathroom. When asked if the other two interventions on her fall care plan should be baseline interventions, the DON agreed they would be considered baseline.
On 11/29/22 at 4:15 p.m., during a follow-up interview, the DON acknowledged the care plans were not where they needed to be and were in the process of being cleaned up. When asked if she felt a toileting program would be appropriate, the DON agreed a toileting program would be appropriate for Resident #56. The DON also acknowledged encouragement of a resident who lacks cognitive ability to use a call light should not be encouraged to use the call light as an intervention and would not be appropriate.
A review of the Minimum Data Set (MDS) assessment dated [DATE] for Resident #56, revealed short term and long term memory issues and Resident #56 was severely cognitively impaired.
A review of the care plan High risk for falls, with an initiation date of 6/17/22, had interventions which included the following:
Anticipate and meet (Resident #56)'s needs. Initiated on 6/17/22.
Be sure (Resident #56)'s call light is within reach and encourage (Resident #56) to use it for assistance as needed. Initiated on 6/17/22 and revised on 11/18/22.
Non-skid socks or shoes with non slip soles. Initiated on 6/10/22.
Provide activities that promote exercise and strength building where possible. Provide 1:1 activities if bedbound. Initiated on 6/10/22.
There were no other care planning interventions to address the falls sustained by Resident #56 on 8/21/22, 8/31/22 or 10/31/22.
Resident #67
On 11/28/22 at 2:01 p.m., during an observation and interview attempt, Resident #67 was perseverating on going out to look at a fallen tree across the street. Resident #67 was upset that he was told he could not go and look at this tree that fell down. Resident #67 did not present as cognitively intact and demonstrated word salad communication at times during the interview.
A review of an Elopement incident dated 10/14/22, revealed Front Desk Staff FF had let Resident #67 out of the facility. Staff FF thought Resident #67 was a visitor and let him out when Resident #67 identified himself as a visitor and stated he needed to go outside and get the keys out of his car.
A review of a Behavior Note dated 10/14/22 at 8:58 p.m., revealed the following:
During dinner today, (Resident #67) was actively exit seeking. With redirection he sat down to eat his soup. This nurse was at the med cart prepping medication when I heard CNA ([Certified Nurse Aide] HH) yellout(sic) hey that's (Resident #67)! to which this nurse looked up and saw (Resident #67) walking outside in the parking lot with his walker .I talked to the front desk asking how hegot(sic) out without the alarm going off to which he stated (Resident #67) knocked on the door and told the front desk he was a visitor and needed to go out to his car and grab his keys, to which the front desk let him out and entered the code to the door, so the alarm did not go off .The front desk was unaware of who (Resident #67) was and did in fact believe he was a visitor .
Author Licensed Practical Nurse (LPN) GG
During an interview on 11/30/22 at 8:06 a.m., the DON was asked why there was nothing in the body of the policy to address elopement prevention, only what to do when an elopement occurs. The DON acknowledged the policy should include education to staff on how to prevent elopements from happening in the first place, and to make sure they are not letting out residents without supervision. During this interview, Receptionist II proceeded to show this surveyor a binder kept at the receptionist desk which contained pictures of all the residents at the facility. Receptionist II stated the facility has always had this binder at the desk as far as she knew. The DON stated she was not aware of this binder being located at the reception desk. Both the DON and Receptionist II agreed staff who sat at the desk should be aware of the binder and check it before letting anyone off the units and out of the building.
During an interview on 11/30/22 at 3:49 p.m., LPN GG confirmed Staff FF had let Resident #67 off the unit and out of the facility under the premise he was a visitor and not an employee. LPN GG also confirmed Resident #67 was .very skillful in his exit seeking . and that she had educated Staff FF to please make sure to ask the nurse for the unit before letting anyone off the unit.
A review of the care plan Elopement risk, for Resident #67, with an initiation date of 8/12/12 had the following interventions:
1:1 staff as necessary when agitated and exit seeking Initiated on 8/15/22.
A name tag will be made up for (Resident #67) to be clipped to the back of his shirt to alert people that he is a resident of (facility). Initiated on 10/18/22.
A picture of (Resident #67) is posted throughout the facility. He will also wear a picture/resident ID tag(to be provided). Initiated on 8/12/22.
Call administrators cell phone number when agitated and unable to redirect so he can speak with him. Initiated on 8/12/22.
Distract (Resident #67) from wandering by offering pleasant diversions, structured activities, food, conversation, television, book. (Resident #67) prefers: Pepsi, talking about his past, Bingo, old shows and movies (TV land and westerns). Initiated on 8/12/22.
Monitor location every 15 min. (minutes) Document wandering behavior and attempted diversional interventions in behavior log. Initiated on 8/12/22.
Provide structured activities: toileting, walking inside and outside, reorientation strategies including signs, pictures and memory boxes. Initiated on 8/12/22.
(Resident #67) triggers for wandering/elopement are looking for his car, getting [NAME](sic), getting to work, etc (Resident #67) behaviors is de-escalated by redirecting and listed interventions. Initiated on 8/12/22.
The care plan provided by the facility did not show any new interventions to address Resident #67's specific elopement concern with staff not recognizing him and letting him out of the building.
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 observation, interview and record review, the facility failed to ensure appropriate monitoring and assessment of a pres...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to ensure appropriate monitoring and assessment of a pressure ulcer for one Resident (#32) of five residents reviewed for pressure ulcers. This deficient practice resulted in the potential for unidentified worsening of the pressure ulcer, delayed healing and infection. Findings include:
Resident #32 was admitted to the facility on [DATE] and had diagnoses including stroke, left side hemiparesis, neurogenic bladder, and urinary tract infections. A review of Resident #32's most recent Minimum Data Set (MDS) assessment, dated 9/20/2022, revealed the Resident required extensive, two-person assistance with bed mobility and toileting (including management of an indwelling, urinary catheter).
An observation of perineal (area of body surrounding genitals) care on 11/30/2022 at 11:33 a.m., revealed an indwelling, urinary catheter leading from Resident #32's penis to a securing device attached to the Resident's left upper thigh and leading to a urine collection bag attached to the Resident's left, lower bedframe. An observation of the catheter insertion site at the urethral meatus (opening of the urethra located at tip of penis) revealed the urethra was eroded (worn away) beginning at the meatus and cleaving down the full thickness of the inferior (lower) aspect of the glans (head of penis). A dark red, dried substance was observed on the proximal catheter tubing and on the left side portion or Resident #32's glans of his penis. Registered Nurse (RN) Y reported the dried substance was blood. RN Y confirmed the presence of the tear in Resident #32's urethra and reported the wound was normal for him (Resident #32). RN Y was unsure what caused the wound.
A review of Resident #32's physician progress note, dated 4/21/2022, revealed the following, in part: Just prior to exam today, was noted to have inferior, urethral meatus tear . slight bleeding. Denies remembering when this occurred. He states he thinks bleeding started a couple days ago . Diagnosis, Assessment and Plan: . Urethral tear, meatus from Foley (indwelling, urinary catheter). Local wound care. Not a candidate for closure .
A review of Resident #32's electronic medical record (EMR), including all skin assessment, wound care notes, skilled nursing assessments, treatment administration records and progress notes from 4/01/2022 through 12/01/2022 revealed no documentation of wound care or wound assessments for Resident #32's urethral wound. Review of the EMR from 2/01/2022 through 12/01/2022 revealed no documentation of a traumatic injury resulting in injury of Resident #32's urethra.
During an interview on 12/01/2022 at 8:19 a.m., the Director of Nursing (DON) reported Resident #32's urethral erosion should be assessed by nursing staff on a regular basis and documented in the EMR to allow for identification of delayed healing and infection. The DON stated all skin abnormalities should be documented on weekly skin assessments.
During an interview on 12/01/2022 at 9:18 a.m., Physician EE reported Resident #32's urethral erosion was noted several months ago. Physician EE stated urethral erosion was a result of pressure from the catheter tubing lying against the urethral wall. When asked the importance of regular assessments of the wound, Physician EE confirmed regular nursing assessment of the wound was important to identify worsening or infection.
On 12/01/2022 at approximately 11:00 a.m., the facility wound care nurse, Licensed Practical Nurse (LPN) DD reported she was unaware of Resident #32's urethral erosion. LPN DD stated she did not provide care or assessment of the wound, including measurements to evaluation healing or worsening of the wound.
A review of the facility policy titled Pressure Ulcer Treatment, revised 6/13/2017, revealed the following, in part: The purpose of this procedure is to provide guidelines for the care of existing pressure ulcers and prevention of additional pressure ulcers. The pressure ulcer treatment program should focus on the following strategies: Assessing the resident and the pressure ulcer(s) . The following information should be recorded in the resident's medical record: Any change in the resident's condition. All assessment data (i.e., color, size, pain, drainage, etc.) when inspecting the wound.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Incontinence Care
(Tag F0690)
Could have caused harm · This affected 1 resident
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to ensure indwelling, urinary catheter equipment was main...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to ensure indwelling, urinary catheter equipment was maintained in a sanitary manner for one Resident (#43) of two residents reviewed for catheter care. This deficient practice resulted in the potential for contamination of catheter equipment with infectious agents and urinary tract infection. Findings include:
Resident #43 was admitted to the facility on [DATE] and had diagnoses including dementia and urinary retention. A review of Resident #43's most recent Minimum Data Set (MDS) assessment revealed the Resident required extensive, one-person assistance with transfers and toileting (including management of an indwelling, urinary catheter).
An observation on 11/30/2022 at 8:40 a.m., revealed Resident #43 self-propelling in a wheelchair from the lounge area of the locked, dementia care unit toward the dining room. Resident #43's catheter tubing was observed to be leading from the Resident to a drainage bag attached under the seat of the wheelchair. The catheter tubing was observed to be dragging on the floor under the wheelchair. Resident #43 was observed to park the chair at a table in the dining room with the catheter tubing resting directly on the floor and her right foot resting directly on top of the catheter tubing. Further observation revealed Licensed Practical Nurse (LPN) R approach Resident #43 and inquire if the Resident was ready for her medications. LPN R was kneeling in front of Resident #43 with the catheter tubing resting on the floor and directly in front of the LPN. LPN R arose and began to walk to the medication cart at which time a query was made as to what the appropriate placement of Resident #43's catheter tubing should be. LPN R looked back at Resident #43 and confirmed the catheter tubing was resting directly on the floor. LPN R stated the tubing should be secured in a manner to prevent touching the floor in order to prevent cross contamination and infection. LPN R was observed securing Resident #43's catheter tubing under the Resident's wheelchair and off the floor.
A review of the facility policy titled Catheter Care, provided by the Director of Nursing (DON) and last reviewed 3/2022, revealed no direction as to positioning of catheter tubing or drainage bags.
During an interview on 12/01/2022 at 1:10 p.m., the DON reported staff were to ensure catheter bags and tubing were maintained and positioned off the floor to prevent contamination and infection.
CONCERN
(D)
Potential for Harm - no one hurt, but risky conditions existed
Deficiency F0726
(Tag F0726)
Could have caused harm · This affected 1 resident
Based on interview and record review, the facility failed to ensure competency was evaluated for two Certified Nurse Aides (CAN's) employed by the facility reviewed for competency evaluations. This de...
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Based on interview and record review, the facility failed to ensure competency was evaluated for two Certified Nurse Aides (CAN's) employed by the facility reviewed for competency evaluations. This deficient practice resulted in the potential for CNAs to lack training and skills needed to care for residents who reside in the facility. Findings include:
On 11/29/22 at approximately 2:30 p.m., training, in-services, and competency evaluations for CNA G and CNA H who were current employees were requested.
On 11/30/22, the files that contained competency evaluations for CNAs were reviewed. There was no evidence that CNA G or CNA H had a competency evaluation verified by staff at the facility, prior to being employed. It was confirmed that both CNA G and CNA H were employees being used by a third-party agency.
CNA G Skills Checklist completed by CNA G, dated 10/21/22 marked himself as minimal experience for care for a combative patient, care for confused patient, application of protective devices: bed alarms, and chair alarms.
CNA H Skills Checklist completed by CNA H, dated 6/30/2022 marked herself as no experience for tympanic temperature, maintain patient dignity and privacy at all times, pulse, respirations, shampoo, dental care, assist patient with urinal, bedside commode, foley catheter, care for a confused patient, care for a combative patient, care for patient with DNR (Do Not Resuscitate) order, hand hygiene, standard/universal precautions, droplet precautions, personal protective equipment, bed alarm, and bed position.
An interview was conducted with CNA H via telephone on 11/30/22 at 2:22 p.m. CNA H stated that she completed the Skills Checklist herself and received no training from the facility prior to starting her employment.
An interview was conducted with Human Resources (HR) I on 11/30/22 at 2:40 p.m. HR I stated that all new employees receive training from current employed staff for two shifts at minimum. HR I was asked to provide documentation that this occurred for CNA G and CNA H and was unable to do so. When asked about the Skills Checklist completed by CNA G and CNA H evaluating their own performance prior to employment, HR I stated that she did not know this was completed by the individuals.
CONCERN
(E)
Potential for Harm - no one hurt, but risky conditions existed
Resident Rights
(Tag F0550)
Could have caused harm · This affected multiple residents
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to treat two Residents (#36 & #66) with dignity and respe...
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**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on observation, interview and record review, the facility failed to treat two Residents (#36 & #66) with dignity and respect of 18 residents reviewed for dignity. This deficient practice resulted in a lack of personal dignity and feelings of embarrassment or hopelessness based on the reasonable person. Findings include:
Resident #36 (R 36)
On 11/30/22 at approximately 1:00 p.m., the lunch meal was observed down the 300 hallway. During this time, Certified Nurse Aide (CNA) G was observed at the far right table of the main dining room assisting R 36 with his lunch tray. CNA G was noted to be looking down at a cell phone which was placed underneath the table, holding it with his right hand with the open screen of the phone visible. CNA G then proceeded to look at his phone and was not assisting R 36 with his lunch. During this continued observation, CNA G then placed his cell phone back in his pocked, grabbed a spoon that was on R 36's tray with food, and proceeded to make 'airplane' noises while placing the spoon closer to R36's mouth. R 36 refused to eat the contents on the spoon.
Review of R 36's 10/25/22 Minimum Data Set (MDS) assessment revealed he required extensive one person assist for meals.
Review of the facility's Employee Handbook updated on 12/31/21 read, in part, .Employees are not to carry their personal mobile device(s) of any nature on their person .Personal devices MAY NOT be used in households .Staff shall not utilize their personal devices for the purpose of charting .
On 11/28/22 at 11:28 a.m., CNA G was observed at the nurses station using his phone under the desk.
Resident #66
On 11/28/22 at 11:36 a.m., Resident #66 (R66) was observed in her wheelchair near the staff bathroom. R66 was wearing a seatbelt and there was an alarm on her wheelchair as well. R66 was asking about the staff bathroom and when asked if she needed to go to the bathroom she stated she did. This surveyor went to the nurses station to report R66's request for assistance. Registered Nurse (RN K) was observed at the medication cart. CNA G was again observed sitting at the nurses station using his cell phone under the desk. RN K was notified of R66's need for toileting assistance.
A review of R66's medical record revealed she admitted to the facility on [DATE] with diagnoses including dementia, adjustment disorder, adult failure to thrive, and history of falling. A review of the most recent 11/1/22 MDS assessment revealed she scored 3/15 on the BIMS assessment, indicating severely impaired cognition and was not presenting any behavioral concerns.
A review of an Employee Disciplinary Notification for CNA J dated 4/14/22 revealed the following: Verbal warning . Minor Infractions: X Inappropriate Communication with Residents/Families/Visitors . There was an interaction between you and a resident with dementia that turned argumentative and in turn upset the resident. As a CNA on a dementia unit you need to understand that their thoughts are real to them and those thoughts are not based on reality . It is also not appropriate to make statements such as you are getting paid to care for them and then continue to argue with the resident using inappropriate language . We realize that burnout occurs however we cannot transfer that to our residents thorough (sic) our actions . If not then you will need to be more cognizant of what your residents are dealing with and meet them at that level, not argue or belittle, and treat them with respect. This was signed by the Director of Nursing (DON) on 4/19/22 but under the employee signature it was written Ref (refused) to sign.
A review of an employee concern form written on 4/13/22 by CNA T with an incident date of 4/12/22. The written statement included the following in part, . I (CNA T) overheard (R66) telling (CNA J) that (R66) was upset that her family would leave her hear and that (R66) just wanted to go home. (CNA J) said something along the lines of 'you have no choice but to stay here' which (R66) replied with 'the he** I am.' (CNA J) then said to (R66) 'are you swearing at me? That is SO disrespectful, don't swear at me.' (R66) was confused and that just escaladed (sic) (R66's) frustration and confusion . (R66) was following her (CNA J) asking her why she was treating her that way and why she needs to stay here. (CNA J) was hollering at (R66) 'I am paid to take care of you and you will be staying here, you have no choice. Take it up with your family an./or your DR (daughter) in the AM.' I (CNA T) could not listen to (CNA J) argue with (R66) anymore . I grabbed (R66's) hand and asked her if she would come walk with me. (CNA J) was still trying to argue with (R66) . (R66) kept asking why someone would treat her that way . I have not seen this side of (R66) since she has arrived her. (R66's) feelings were extremely hurt . This isn't abnormal behavior for (CNA J) to be rude and short with residents .
On 11/30/22 at 4:18 p.m., the DON was asked if the altercation between R66 and CNA J was reported to the state agency. The DON stated, Probably not. When asked about CNA J not signing the statement, the DON stated, No, they usually don't. They think if they don't sign it then it (the write up) doesn't count.
On 11/30/22 at 4:24 p.m., R66 was observed in her wheelchair in the common area of her unit. When asked if she liked the staff who took care of her, R66 stated, Some I do, some I don't. When asked if the staff were ever mean to her or treated her unkindly, R66 stated, Well sometimes they say things that aren't nice. When asked if she reported it to anyone, R66 stated, No, because you know where it will go and they (staff) might get worse, and then you're just stuck here. R66 would not provide any of the names of the staff she was referring to.
On 12/1/22 at approximately 11:31 a.m., the DON was asked for an investigation regarding the CNA J and R66 altercation from May 2022. The DON reported that it wasn't substantiated. When asked if she had an investigation regarding the incident, the DON reported she did not have a written one. When asked to provide CNA Js statement regarding the event, the DON reported she didn't have one and that CNA J had refused to sign the write up or say what happened, but that she didn't say it in that manner. The DON stated about CNA J, (CNA J) gets defensive and tough . She gives good care and is rough around the edges and sometimes its taken as being rude. The DON was asked if R66 was interviewed and reported that R66 didn't remember the incident and did not have a statement for her.
A review of the facility policy titled, Resident Rights Guidelines for All Nursing Procedures dated 8/2016 revealed, 1. Prior to having direct-care responsibilities for residents, staff must have appropriate in-service training on resident rights, including: . b. Resident dignity and respect .
A review of the facility policy titled, Abuse, Neglect, and Exploitation dated October 2022 revealed, .Alleged Violation is a situation or occurrence that is observed or reported by staff, resident, relative, visitor or others but has not yet been investigated an, if verified, could be indication of noncompliance with Federal requirements related to mistreatment, exploitation, neglect, or abuse . A. An immediate investigation is warranted when suspicion of abuse, neglect, or exploitation, or reports of abuse, neglect, or exploitation occur . A. The facility will have written procedures that include: 1. Reporting of all alleged violations to the Administrator, state agency, adult protective services and to all other required agencies .
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 observation and interview the facility failed to maintain sanitary conditions in the kitchen resulting in an increased potential for cross contamination of food and foodborne illness, potenti...
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Based on observation and interview the facility failed to maintain sanitary conditions in the kitchen resulting in an increased potential for cross contamination of food and foodborne illness, potentially affecting all residents who receive meal services out of the facility's total census of 66 residents. Findings include:
1. On 11/28/22 at 10:39 AM, Chef, staff A, was observed taking off gloves, adjusting their face mask, and putting on a new pair of gloves without washing their hands prior to taking a temperature of, and plating a hamburger for lunch service.
On 11/28/22 at 10:53 AM, Dietary Aide, staff C, was observed donning gloves prior to washing their hands after touching refrigerator door handles, prep counters, and their face mask prior to handling and portioning fruit cups for the days lunch service.
On 11/28/22 at 11:09 AM, and at 11:16 AM, Dietary Aide, staff D, was observed removing and donning new pairs of gloves prior to washing their hands while handling and storing clean equipment and utensils.
On 11/28/22 at 11:39 AM, and 11:52 AM Dietary Aide, staff E, was observed in the Elm kitchenette removing and donning new pairs of gloves prior to washing their hands during the assembly, plating, and serving of meals. On 11/28/22 at 11:33 AM, Dietary Manager, staff F, was observed in the Pine kitchenette removing and donning new pairs of gloves prior to washing their hands during the assembly, plating, and temperature verification for the day's lunch service.
On 11/28/22 at 11:55 AM, the surveyor inquired with the Registered Dietitian, staff B, on the hand hygiene expectations for staff when they choose to use gloves as a hand barrier to which they replied, wash their hands before they put them on. At this time the surveyor requested the facility's hand hygiene policy to review to which staff B replied, let me see what I can find. Upon exiting the facility, the surveyor did not receive a hand hygiene policy to review as requested.
Review of 2017 U.S. Public Health Service Food Code, Chapter 2-301.14 When to Wash directs that:
FOOD EMPLOYEES shall clean their hands and exposed portions of their arms as specified under § 2-301.12 immediately before engaging in FOOD preparation including working with exposed FOOD, clean EQUIPMENT and UTENSILS, and unwrapped SINGLE-SERVICE and SINGLE-USE ARTICLESP and:
(H) Before donning gloves to initiate a task that involves working with FOOD; P and
(I) After engaging in other activities that contaminate the hands.P
2. On 11/28/22 at 11:12 AM, on a counter next to the clean equipment storage rack an unlabeled bulk container containing a white powder and scoop was observed. At this time the surveyor inquired with the Registered Dietitian, staff B, on if they if they were aware of what the contents were in this container to which they replied, it should have been labeled. I think it's probably flour or powdered sugar. I'll have to check with the cooks. On 11/28/22 at 11:14 AM, an unlabeled bulk container containing a brown powder was observed. At this time the surveyor inquired with staff B on if they if they were aware of what the contents were in this container to which they replied, that should be cocoa powder. I'll move the labels closer for my staff.
Review of 2017 U.S. Public Health Service Food Code, Chapter 3-302.12 Food Storage Containers, Identified with Common Name of Food directs that:
Except for containers holding FOOD that can be readily and unmistakably recognized such as dry pasta, working containers holding FOOD or FOOD ingredients that are removed from their original packages for use in the FOOD ESTABLISHMENT, such as cooking oils, flour, herbs, potato flakes, salt, spices, and sugar shall be identified with the common name of the FOOD.
3. On 11/28/22 at 12:22 PM, three bag in a box style containers of juice were observed stored in a cabinet underneath a plumbing drain trap in the Pine unit's dining room. At this time the surveyor inquired with the Registered Dietitian, staff B, on if it is normal to store the juice containers in this cabinet to which they replied, I believe they normally are stored in the cabinet next to this one because of the drain. I'll move them over now. On 11/28/22 at 12:29 PM, four bag in a box style containers of juice were observed stored in a cabinet underneath a plumbing drain trap in the Oak unit's dining room. Upon observation, staff B was observed by the surveyor relocating the juice containers to the neighboring cabinet.
Review of 2017 U.S. Public Health Service Food Code, Chapter Storage under drain lines
3-305.12 Food Storage, Prohibited Areas directs that:
FOOD may not be stored:
(F) Under sewer lines that are not shielded to intercept potential drips;