Failure to Document and Communicate Residents' Code Status
Summary
The facility failed to have a clear system in place to document residents' choices regarding code status, which indicates the type of resuscitation procedures for a resident if their heart stops beating. This deficiency was identified during an onsite survey and affected seven residents. For example, Resident 11's care plan indicated a Do Not Resuscitate (DNR) status, but there was a lack of evidence of an order regarding the resident's code status for approximately three and a half months. Similarly, Resident 13 had a full code status documented two months after admission, and Resident 26 had a full code status documented four months after admission. Other residents, including Residents 29, 32, 16, and 18, also had discrepancies in their code status documentation, with significant delays between admission and the documentation of their code status in their care plans and physician orders. The survey revealed that the facility did not have a system to indicate a resident's code status on their doors or within their rooms. Interviews with staff members, including housekeeping staff and licensed nurses, confirmed that there was no consistent method to communicate code status. Staff relied on walkie-talkies to notify each other in the event of an emergency, and code status information was located on physician orders and face sheets. However, this approach was not sufficient to ensure that all staff members were aware of each resident's code status promptly. The facility's policy on Residents' Rights Regarding Treatment and Advance Directives stated that the facility would support and facilitate a resident's right to request, refuse, and/or discontinue medical treatments and to formulate an advanced directive upon admission. The policy also required periodic reassessment of the resident's desired changes related to any advanced directives, which should be documented in the resident's electronic health record (EHR). The facility's failure to implement a clear system for documenting and communicating residents' code status had the potential to negatively affect the mental, physical, and psychosocial well-being of the affected residents and placed all residents at risk for potential negative outcomes during an emergency.
Penalty
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Surveyors found that several nurses lacked proper CPR certification required to support residents with full code status. Some LPNs and an RN had no CPR certification documented in their personnel files, while other LPNs held CPR cards that, although covering adult, child, infant, and AED use, did not specify BLS or healthcare provider-level training. The DON confirmed these gaps, which were inconsistent with facility policies requiring verification of necessary licenses and certifications at hire and ongoing BLS CPR certification for key clinical staff involved in resuscitative efforts.
Surveyors found that the AED on the Rehab Hall crash cart had no pads attached and no pads stored in the AED compartments or in the crash cart, despite daily checks being documented on a crash cart checklist that did not include verification of AED function or pad availability. During the observation, the ADON confirmed that no AED pads were readily available. The facility reported that this crash cart and AED would be used in an emergency for 18 of 19 residents on the Rehab Hall who were identified as Full Code.
Three staff members, including a CNA, an RN, and an LPN, were found to be working without current CPR certification, as confirmed by personnel file reviews and staff interviews. The DON was aware of some expired certifications, and all three staff continued to work shifts despite the facility's policy requiring current CPR certification.
A resident with multiple serious medical conditions and a full code status was found unresponsive and exhibiting signs of death. Staff failed to immediately initiate CPR, with delays caused by uncertainty, lack of certification, and panic. When CPR was started, it was performed ineffectively and without proper equipment or technique, as confirmed by EMS upon arrival. Facility policy requiring immediate CPR for full code residents was not followed.
A resident with complex medical conditions had a signed Advance Directives Form indicating DNR CC-A, but the physician order listed the resident as full code for two months before being corrected. The DON confirmed the mismatch between the resident's documented wishes and the code status order, contrary to facility policy.
A resident with multiple serious health conditions and a documented Full Code status was found unresponsive. Facility staff, including an LPN, failed to initiate CPR or promptly call EMS, despite the resident's wishes for all life-saving measures. The hospice nurse confirmed the resident's death, and no resuscitative efforts were made by staff prior to EMS arrival, resulting in a deficiency related to emergency response and code status verification.
Failure to Ensure Nursing Staff Held Proper BLS CPR Certification
Penalty
Summary
The deficiency involves the facility’s failure to ensure that nursing staff held appropriate and current Cardiopulmonary Resuscitation (CPR) certification consistent with facility policy and the needs of residents who had elected full code status. Surveyors reviewed personnel records and found that multiple nurses, including several LPNs and an RN, either had no CPR certification on file or held CPR cards that did not specify Basic Life Support (BLS) or healthcare provider-level training. Specifically, LPNs with certain hire dates had no CPR certification in their files, and an RN also lacked any documented CPR certification. Other LPNs possessed CPR cards that covered adult, child, infant, and AED use, but the cards did not indicate that the training was BLS or designated for healthcare providers. The Director of Nursing confirmed during interview that several identified staff members had no current CPR certification on file and that others had CPR certifications that did not include BLS or healthcare provider designation. Facility policy on Licensure, Certification, and Registration of Personnel required staff who need a license or certification to present verification to Human Resources prior to or upon employment. Another policy on Emergency Procedure Cardiopulmonary Resuscitation required key clinical staff, including non-licensed personnel who would direct resuscitative efforts, to obtain and maintain American Red Cross or American Heart Association certification in BLS CPR. These findings affected residents who had chosen full code status, as the facility did not ensure that staff responsible for providing resuscitation met the specified CPR certification requirements.
AED on Rehab Hall Crash Cart Lacked Pads for Full Code Residents
Penalty
Summary
Surveyors identified a deficiency related to the facility’s failure to ensure an Automated External Defibrillator (AED) was ready for use for residents requiring basic life support, including CPR, prior to the arrival of emergency medical personnel. During an observation of the Rehab Hall crash cart with the ADON, the AED was found lying on top of the crash cart with no pads connected, and no pads were located in the AED compartments or in the crash cart. The crash cart had a daily checklist of items, all of which were marked as checked, but there was no checkbox to verify the AED’s working order or the presence of pads. In an interview at the time of the observation, the ADON confirmed that no AED pads were readily available. The facility reported that 18 of the 19 residents on the Rehab Hall were designated as Full Code and that this crash cart and AED would be used in the event of an emergency or code situation. This deficiency was investigated under Complaint Number 2725566. No additional resident-specific medical histories or conditions at the time of the deficiency were provided beyond the facility’s identification of 18 Full Code residents on the Rehab Hall.
Failure to Maintain Current CPR Certification Among Nursing Staff
Penalty
Summary
The facility failed to ensure that three out of five sampled staff members, including a CNA, an RN, and an LPN, maintained current certification in Cardio-Pulmonary Resuscitation (CPR). Personnel file reviews revealed that these staff members' CPR certifications had expired, and interviews confirmed that they were not currently certified. Despite this, all three staff members continued to be scheduled and actively worked shifts throughout the facility. The Director of Nursing (DON) acknowledged awareness of the expired certifications for the CNA and RN but was not aware of the expiration date for the LPN. Facility policy required staff to be properly trained and/or certified in CPR to provide basic life support until emergency medical services arrived, and to maintain current CPR certification. The deficiency was identified through review of personnel files, staff interviews, and facility policy, and was investigated under a specific complaint number.
Failure to Initiate Immediate and Effective CPR for Full Code Resident
Penalty
Summary
A deficiency occurred when staff failed to initiate immediate and appropriate cardiopulmonary resuscitation (CPR) for a resident with a full code status who was found unresponsive. The resident, an elderly male with multiple significant diagnoses including end stage renal disease, dementia, severe sepsis, and metabolic encephalopathy, was noted to be dependent on staff for all activities of daily living and had severely impaired cognition. On the evening in question, the resident was last observed in the dining room and later found unresponsive, cold to the touch, with blue fingertips and signs of rigidity by two certified nursing assistants (CNAs). Upon discovering the resident's condition, the CNAs sought assistance from a registered nurse (RN), who appeared panicked and did not immediately initiate CPR. The RN left the room to verify the resident's code status and retrieve the crash cart, during which time no resuscitative efforts were started. When additional nursing staff arrived, chest compressions were eventually initiated, but not until several minutes had passed. The staff performing CPR were not all currently certified, and the compressions were described as ineffective by emergency medical services (EMS) personnel upon their arrival. No airway management or use of an automated external defibrillator (AED) was observed, and the resident was not placed on a hard surface for compressions. EMS personnel noted that the resident exhibited signs of rigor mortis and had likely been deceased for several hours prior to their arrival, despite staff statements regarding the last time the resident was seen alive. Facility policy required immediate initiation of CPR for residents with full code status, but this was not followed. The incident affected one resident directly, with the facility identifying 178 residents with full code status at the time of the survey.
Failure to Ensure Code Status Orders Match Advance Directives
Penalty
Summary
The facility failed to ensure that a resident's code status orders accurately reflected their wishes as documented in their Advance Directives Form. Specifically, a cognitively intact resident with multiple complex medical diagnoses, including chronic kidney disease, heart disease, and diabetes, had a signed Advance Directives Form indicating a preference for Do Not Resuscitate Comfort Care-Arrest (DNR CC-A). Despite this, the physician order in the medical record listed the resident as full code from the time of admission until two months later, at which point the order was changed to DNR CC-A. This discrepancy was confirmed through medical record review and interview with the Director of Nursing, who acknowledged that the resident's code status order did not match the documented advance directive for a significant period. The facility's policy requires that advance directives be respected and that the plan of care be consistent with the resident's documented treatment preferences, but this was not followed in this case.
Failure to Initiate CPR and Timely EMS Response for Full Code Resident
Penalty
Summary
A deficiency occurred when facility staff failed to initiate Cardiopulmonary Resuscitation (CPR) or promptly call Emergency Medical Services (EMS) for a resident who had advance directives indicating Full Code status. The resident, who had multiple significant medical diagnoses including chronic obstructive pulmonary disease, diabetes, heart failure, and was receiving hospice services, was found unresponsive. Despite the resident's documented wishes to receive all life-saving measures, no CPR was started by staff, and EMS was not called until nearly an hour after the resident was pronounced deceased. At the time of the incident, the resident was under hospice care but had explicitly chosen to remain a Full Code, as documented in both the physician's orders and the care plan. Staff present at the scene, including an LPN and other aides, failed to recognize or act upon the resident's code status. The hospice nurse who arrived at the scene found the resident with no vital signs and confirmed death after auscultating for a heart rate for three minutes. The crash cart was not brought to the room until much later, and there was confusion among staff regarding the resident's code status and the appropriate emergency response. Interviews and record reviews revealed that the LPN on duty did not know the resident's code status and did not initiate CPR. Other staff members, including another LPN and CNAs, were either unsure of the actions taken or did not participate in resuscitative efforts. Documentation was inconsistent, and there was evidence that staff attempted to retroactively document or misrepresent the provision of CPR. The facility's failure to follow established emergency procedures and to verify and act on the resident's code status resulted in the resident not receiving the life-saving interventions to which they were entitled.
Removal Plan
- Managerial staff, Regional Director of Clinical Services (RDCS) #601, the Administrator, and the DON reviewed data collaboratively, conducted a root cause analysis, and identified that LPN #521 did not know Resident #13's code status and did not initiate CPR.
- The Administrator and DON received education from President of Clinical Services (VPCS) #618 and President of Operations (VPO) #617 on where to locate advanced directives, CPR policy, Code Blue Flow Sheet, that hospice was not a code status and that advanced directives still need checked.
- Staff were educated to check the bed board, with a new process to add code status for staff and contracted service providers.
- Staff were educated to check the bed board, change of condition, communication during a code, the crash cart, and staffing assignments.
- An Ad Hoc Quality Assurance and Performance Improvement (QAPI) meeting was held with management to review education on advanced directives, CPR policy, Code Blue Flow Sheet, hospice not being a code status, and the new bed board process.
- Contracted service providers would be educated to check the bed board, change of condition, communication during a code, crash cart, and staffing assignments.
- Each service provider would receive a memo upon entering the building stating the facility's new process, sign off on receipt and understanding, and memos would also be emailed to appropriate service providers.
- 32 Certified Nurse Aides (CNAs), 19 LPNs, four Registered Nurses (RN), seven housekeepers, six receptionists, 16 therapists, and 2 activity employees were educated on where to locate advanced directives, CPR policy, Code Blue Flow Sheet, hospice not being a code status, and the new bed board process.
- Contracted service providers will be educated to check the bed board, change of condition, communication during a code and crash cart, and staffing assignments by ADON #615 and the DON.
- A whole house audit for 58 residents' code status orders was reviewed for accuracy by ADON #615. This would be reviewed during clinical meetings, and the DON/designee would update and check the code status for new admissions.
- 58 resident care plans were reviewed for accuracy by MDS Coordinator #613.
- ADON #615 audited all current nurse's CPR certification records to ensure nursing staff had current CPR certification. No nurses were permitted to work until their active CPR certification was verified by Administration.
- Former Director of Nursing (FDON) #604 ran the audit report on 58 residents to assess for change of condition that was not addressed. No issues were identified. The DON/designee would audit the report.
- The DON and ADON #615 audited the three LPNs and four CNAs on duty and had them locate in the electronic medical record where the resident's code status was located.
- The DON/designee completed a mock code blue drill to identify areas of struggle.
- The Administrator, RDCS #601, and Regional Director of Operations (RDO) #599, administered a hands-on and written post-test for all nurses working.
- RDCS #601 and RDO #599 went to the units and demonstrated how to use the overhead page, how and where to look in the electronic medical record for code status, and how to use the walkie talkies. Staff performed a return demonstration of locating code status in the electronic medical record.
- An audit of the bed board code status would be reviewed and updated by the DON. Results of the audit would be reviewed through the facility's QAPI process.
- Mock code blue drills would be conducted on alternating shifts. Staff participating in the mock codes would document on the code blue documentation nurses note form. The mock codes would be overseen by the DON or designee. Results would be reviewed through the facility's QAPI process.
- A code blue drill would be conducted on alternating shifts. These audits would be completed by the DON or designee using the code response form.
- The DON or designee would begin auditing reports from the electronic medical record system to audit for any resident changes in condition, to ensure changes in condition were appropriately addressed. Results would be reviewed through the facility's QAPI process.
- Interview questionnaires would be conducted with first floor staff on how to obtain help during emergency situations on alternating shifts. These interviews would be conducted by the DON or designee. Results would be reviewed through the facility's QAPI process.
- The crash cart would be audited by the DON or designee to ensure all needed supplies are contained in the crash cart. The audits would take place on alternating shifts. Results would be reviewed through the facility's QAPI process.
- The DON or designee would audit the first-floor staffing, to ensure scheduled staff members are present as scheduled, on random shifts. Results would be reviewed through the facility's QAPI process.
- RDCS #601 provided additional one-on-one education to LPN #521 regarding what the Code Blue form is and when to utilize it. LPN #521 verbalized understanding.
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