F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
L

Failure to Honor Resident's DNR Status and Inadequate QAPI Response

Highlands Rehabilitation And Wellness CenterBirmingham, Alabama Survey Completed on 05-13-2024

Summary

The facility's Quality Assurance Performance Improvement (QAPI) committee failed to address all causal factors related to four staff members providing Cardiopulmonary Resuscitation (CPR) to a resident with an Advanced Directive for Do Not Resuscitate (DNR). The QAPI committee also failed to notify the Governing Body of the adverse event. The incident involved a resident whose end-of-life wishes were not honored, as licensed staff did not review the resident's chart for code status prior to initiating CPR. Additionally, the resident's nurse was not in the facility at the time of the code and could not immediately locate the appropriate paperwork to identify the resident's DNR status when she returned. All licensed staff performing CPR on the resident did not have current CPR certification at the time of the incident. The facility did not develop or implement an action plan to prevent recurrence of such events. The incident occurred when a Certified Nursing Assistant (CNA) noticed the resident's breathing was shallow and their color had changed. The CNA called for help, and a Registered Nurse (RN) and a CPR Instructor responded. The RN began chest compressions, and the CPR Instructor called a Code Blue. The resident's nurse returned to the facility during the code but was unable to verify the resident's DNR status. The resident expired after CPR was performed. The QAPI committee's documentation did not include a performance improvement plan or any corrective actions to address the incident. Interviews with staff revealed that the nurses involved in the incident assumed the code status had been checked and proceeded with CPR. The Director of Nursing (DON) confirmed that the facility's policy on CPR and Advance Directives was not followed. The Administrator acknowledged that the incident was discussed in a QAPI meeting, but no performance improvement plan was developed. The Regional President of the facility's management company was not notified of the adverse event until much later and expressed concern that the facility did not honor the resident's end-of-life wishes. The incident was not reported to the State Agency as required.

Removal Plan

  • Clinical operations (Clin-Ops) nurse will in-service the Executive Director (ED), Director of Nursing (DNS) and Quality Assurance and Performance Improvement (QAPI) committee on new policy A.3a. titled, Accident/Incident & Adverse Events.
  • ED and DNS will in-service 100% of licensed staff on Accident/Incident & Adverse Event Documentation and Investigation. No licensed staff member will be allowed to work until completion of in-service.
  • System to be followed per policy, Notification and Documentation in the Resident's Medical Record: a. The Licensed Nurse shall place the resident on the 24-Hour Report, document the incident, and notify the supervisor and Director of Nursing for follow through prior to the end of shift in which the accident/incident or adverse event occurs.
  • The Licensed Nurse may complete a Nurses' Note and update the Resident Care Plan.
  • The Nurse's Notes could contain the following documentation.
  • The Executive Director/Director of Nursing will notify the State Department of Health in accordance with reporting guidelines in the event the accident/incident is reportable.
  • The Executive Director/Director of Nursing will monitor, track, and trend the accident/incident and adverse event through utilization of the electronic medical record quality assurance reports. These reports will be reviewed through the weekly Risk Review Meeting attended by the Interdisciplinary team (IDT). The event log will be reviewed in the Quality Assurance Performance Improvement (QAPI) meeting.
  • Through investigation and root cause analysis, performance improvement plans will be implemented to correct all causal factors of the adverse event.

Penalty

Inspection fine: $24,83454 days payment denial
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

Below are regulatory guidelines relevant to this citation:

See other F0867 citations
QAPI Committee Failed to Correct Repeat Deficiencies
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The facility QAPI committee failed to correct repeated quality deficiencies and did not ensure that plans to improve care and services effectively addressed them. A prior survey had cited the facility and included QAPI-related plans of correction, but the current survey found multiple repeat deficiencies, including F604, F609, F628, F700, F880, F883, and PA1020. The NHA confirmed the facility had multiple repeat deficiencies and had not corrected the quality issues.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI PIP for Pressure Ulcers Lacked Documented Interventions and Analysis
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI minutes showed an ongoing PIP for pressure ulcers, but the facility did not document clear interventions, data analysis, or a plan showing how it would reach its stated goals. The minutes contained inconsistent pressure ulcer entries, blank or incomplete PIP sections, and separate short-stay and long-stay references without explanation. The DON confirmed the facility had no documented analysis of the PIP and no laid-out plan for how the project would be carried out.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Failed to Resolve Repeated Medication, Food Service, and Kitchen Compliance Deficiencies
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The facility’s QAPI committee failed to resolve repeated deficiencies involving medication storage and labeling, food served at improper temperatures and not palatable, and staff not wearing hair coverings in the kitchen. Prior POCs called for audits and reporting to QAPI, but surveyors again cited the same issues under F761, F804, and F812 on the current survey.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Committee Failed to Correct Repeated Deficiencies
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

A facility’s QAPI committee failed to correct recurring deficiencies involving a clean, homelike environment, pressure ulcer prevention, drug regimen reviews, safe food storage/preparation/service, and infection control. Prior plans of correction relied on audits and reporting to QAPI, but the same deficient practices were again cited in the current survey under F584, F686, F756, F812, and F880.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Address Ongoing Rodent Infestation in QAPI
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

Failure to Address Ongoing Rodent Infestation in QAPI: The facility did not use its QAPI process to address a known rodent problem. Rodent feces and traps were observed in resident rooms, dining and food areas, clean dish and linen areas, and other parts of the building. Interviews confirmed the infestation was ongoing, recommended structural repairs had not been made, the issue was not discussed in the QAPI meeting, and no education had been provided to residents or staff.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Committee Failed to Track and Monitor Shower Room Deficiency
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI failed to track and monitor a black debris issue in the 300-hall shower room. An observation found black debris in the shower’s inner bottom corners, and records showed the QAPI plan only listed environmental rounds monitored by the Administrator and Maintenance without further comments. The Maintenance Supervisor said he knew about the issue, had cleaned it, but did not document weekly rounds or findings, and the Administrator also said he did not document the weekly monitoring.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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