Misappropriation of Controlled Narcotics
Summary
The facility failed to ensure residents' rights to be free from misappropriation of controlled narcotics for seven residents. Specifically, the facility did not account for a significant number of narcotic tablets, including Oxycodone and Hydrocodone, for these residents. The missing medications were discovered through a review of pharmacy delivery records, controlled substance count sheets, and controlled drug record sheets. Interviews with staff revealed inconsistencies and lapses in the proper documentation and verification processes for controlled substances. Resident #1 had 48 tablets of Oxycodone 10 mg missing, and the DON could not explain discrepancies in the controlled substance count sheet. Resident #2 had 61 tablets of Oxycodone 5 mg missing, and the controlled drug record sheet for this resident was removed and could not be located. Interviews with staff indicated that proper procedures for witnessing and documenting the removal of controlled substances were not followed. Similar issues were found for Residents #5, #6, #7, #8, and #9, with varying amounts of Hydrocodone and Oxycodone tablets unaccounted for. The facility's failure to properly handle, store, and document controlled medications resulted in Immediate Jeopardy for the affected residents. The DON confirmed that the missing narcotic tablets for these residents could not be accounted for due to missing narcotic sheets and medication cards that were improperly removed from the medication cart. This deficiency highlights significant lapses in the facility's controlled medication management and documentation processes.
Removal Plan
- Resident #6 discharged from the facility. Charges to his insurance was reversed and charged to the facility.
- Resident #1 was assessed for pain, no pain was noted and current residents #1, #5, #8 and #9 were assessed for pain by the DON. No pain was noted.
- Controlled medications were reconciled on every medication cart by the DON.
- The pharmacy was informed of the missing medications for residents #1, #5, #8, and #9. The charges to their insurance for their medications were reversed and charged to the facility.
- The DON and SCC conducted interviews with licensed staff to inquire if they had knowledge of controlled medication unaccounted for or if they had suspicion of anyone working while impaired.
- The DON and SCC began auditing the Controlled Medication delivery logs for Resident #1 to ensure all deliveries were added to carts #1 and #2 on Hall #3.
- The DON and SCC began auditing the Controlled Drug Records for residents that were recently discharged or deceased from Hall #3. An audit of controlled medication logs was conducted for every resident in the facility with an order for a controlled medication to determine if other nurses/residents were involved. This was performed by the DON and SCC. Hall #3 was the only hall identified with controlled medications unaccounted for. Any findings were reported to the legal and regulatory authorities: Health Facilities Commission, TN Regional Office; TN Bureau of Investigation; Police Department, Ombudsman and APS.
- The affected residents with a BIMS of 8 or greater were interviewed by the DON, and all stated they received their pain medications, and all denied pain.
- The affected resident with a BIMS less than 8 was assessed for pain by the DON, there was no complaint or signs of pain.
- Pain assessments were completed for all residents on Hall #3 by the nurse managers to determine if any had uncontrolled pain. There were no residents experiencing uncontrolled pain.
- The nurse managers interviewed residents on Hall #3 with a BIMS equal or greater than 8 to determine if their pain is controlled and as needed (PRN) medications had been administered when requested. All stated their pain is controlled and they receive their PRN medications when requested.
- The DON reviewed documented pain levels for uncontrolled pain. No one had uncontrolled pain levels.
- One nurse was suspended due to reasonable suspicion and remains suspended. This nurse was reported to the Tennessee (TN) Board of Nursing. The TN Bureau of Investigation is continuing the investigation.
- A root cause analysis was conducted. It was determined that the nurse did not follow the process for removing controlled medications; obtaining a witness to verify the removal of controlled medications. The process was changed to prevent the nurses/medication aides from removing completed medication cards or discontinued medication cards. The DON or Unit Managers will remove controlled medications from the medication cart; completed medication cards/sheets and discontinued medication cards/sheets.
- A root cause analysis was conducted. It was determined the excess controlled medication cards/sheets did not need to be on the medication cart. A cabinet with 2 locks was secured in the medication room for overflow-controlled medications and a new form was developed, Controlled Substance Overflow Sheet, to record the addition and removal of controlled medication to that cabinet.
- Education was conducted by the Director of Nursing (DON) and Staff Development Coordinator (SDC) with all staff on the Abuse and Misappropriation Policy. Any staff/agency staff who were not educated will be before working their next shift.
- Education was conducted by the DON and SDC with all licensed staff and Medication Aides on the Controlled Medication Policy and process changes for counting/receiving/removing controlled medication. Any staff/agency staff who were not educated will be educated prior to working their next shift.
- Two nurses will verify the pharmacy delivery manifests for controlled medications in the presence of the driver. Once the quantity has been verified, they will sign the pharmacy delivery manifest. Two nurses will sign the Controlled Drug Record sheet and indicate the total quantity for the prescription (RX) number and the number of medication units, i.e. tablets, on the Controlled Drug Record sheet. Once the quantities are verified the two nurses will add the controlled medications to the medication cart and sign them into the Controlled Substance Record sheet.
- The Unit Managers will audit the pharmacy delivery manifests, daily, to verify controlled medications and Controlled Drug Record Sheets were added to the Controlled Substance Count Sheet and for count accuracy.
- The DON/UM will remove all controlled medications with a witness (empty and discontinued) from the medication cart, reconcile the Controlled Substance Count Sheets and compare the Controlled Substance Count Sheets to the Controlled Drug Records as they are removed from the cart to be secured for destruction. No one will remove controlled medication card/sheets without the DON/UM witnessing. This process, along with the process in #5 above, will prevent the ability to remove a count sheet and medication card without being discovered.
- A secured cabinet with 2 locks was placed in the Four Seasons (hall #2) medication storage room. Overflow of controlled medications will be stored in the secured cabinet. The cabinet has 2 locks with 2 separate keys that are assigned to 2 different licensed nurses (the DON and SDC). The DON and SDC will access the controlled medication cabinet as needed: when multiple cards/sheets are delivered and as the nurses need medications due to running out on the cart. The carts will be checked at the end of the day and before the weekend to ensure the residents will not miss a dose of their controlled medication. The transaction will be recorded on the Controlled Substance Overflow sheet. There will not be a key to this cabinet on any other key ring. In the event the DON or SDC are not in the facility, the DON will designate a Clinical Manager to hold one key.
- The licensed nurses/medication aides were educated by the DON, SDC or UM. Any licensed staff including agency nurses that were not educated will be before their next shift.
- An Ad Hoc QAPI was held via phone, with Corporate Leadership, SCC, Pharmacy President (VP) Strategic Accounts, and the Medical Director to discuss new findings and ongoing investigation.
- An Ad Hoc QAPI was held with Corporate Leaders to discuss audit findings, via phone.
- An Ad HOC QAPI was held with the Medical Director to discuss the event and plan of correction.
- An Ad HOC QAPI was held with the Medical Director, to discuss implementation of a secured overflow cabinet for controlled medications, the process for accessing the cabinet and the recording of adding/removing controlled medications. This new process will be discussed in QAPI meetings to ensure compliance and determine any changes that may be warranted.
- The Clinical Interdisciplinary Team (IDT) will audit every scheduled nurse at shift change for accuracy of the count process daily for two weeks then, weekly times (x) 2 weeks, then monthly x 2 months, then quarterly thereafter.
- The DON/Unit Manager (UM) will audit the medication carts to ensure discontinued/completed controlled medications have been removed from the cart and the Controlled Medication Count Sheet accurately records the removal 5 times per week x 2 weeks then, 3 times per week x 2 weeks then, 2 times monthly x 2 months.
- The DON will conduct random audits of the Pharmacy Delivery Report to ensure the delivered controlled medications were accurately added to the medication carts and Controlled Substance Count Sheets; 5 deliveries per week x 2 weeks then, 3 deliveries per week x 2 weeks then, 3 deliveries per month x 2 months.
- The Quality Assurance (QA) Team will review staff education and QA audits for completion and accuracy. Findings of audits will be reported to the QAPI Committee which includes the Administrator, DON, Unit Managers, SDC, Social Services Director, Maintenance Director, Dietary Manager, Life Enrichment Director, Rehab Manager, and Medical Director. The QAPI meetings will be held weekly for 4 weeks then, 2 times per month for the next 30 days then, monthly thereafter or until the QAPI Committee determines substantial compliance has been achieved. The QAPI Committee reserves the right to modify or extend monitoring times according to outcomes.
- Regional oversite has been in place daily. The Senior (Sr.) Signature State Care Consultant has been in the facility assisting with interviews, education, audits, process changes, attending Ad Hoc QAPI meetings and oversight of compliance with process changes. Regional oversite has occurred onsite or by phone from the Sr. Signature State Care Consultant, the Regional VP of Clinical Operations, or the Regional VP of Operations. The Regional team has collaborated with the facility team on process changes and attended Ad HOC QAPI meetings via phone to discuss audit findings and develop a plan of correction.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Two residents were involved in misappropriation findings. One resident with major depressive disorder, HF, and DM had a resident fund account with direct deposit income, a monthly allowance, and Medicaid patient liability issues tied to MITS and county income reporting. Another resident with COPD, oxygen dependence, and HF reported giving a former AA his bank card for purchases, and the state investigation found the AA misappropriated the resident’s property through fraudulent bankcard purchases.
Misappropriation of Resident Funds: A resident with dementia was not protected from alleged misappropriation of property when an LVN reportedly withdrew money from the resident’s bank account without consent. The resident said his bank card went missing from his drawer, a staff member helped him go to the bank, and he learned of unauthorized withdrawals linked to the LVN’s name on the bank statement.
Misappropriation of controlled medications occurred when staff could not account for missing oxycodone for several residents and liquid hydromorphone for another resident. One resident was severely cognitively impaired and others were cognitively intact or moderately impaired, with orders for scheduled opioid pain meds. Pharmacy records, MARs, and narcotic counts showed missing tablets, incomplete documentation, and a liquid opioid that appeared to have been replaced with water.
Unaccounted Resident Oxycodone: The facility failed to ensure a resident’s Oxycodone was properly accounted for after the pharmacy delivered 30 tablets for pain management. An LPN reported receiving the medication, placing it on a dresser at another LPN’s direction, and signing the controlled substance tracker as if it had been handed off, but the tracker did not document the Oxycodone and the facility could not account for the missing medication.
A resident with severe cognitive impairment and dependence for most ADLs had his debit card taken and used for $1,103.11 in unauthorized purchases. A friend who helped manage his bills discovered the account was overdrawn and found multiple disputed transactions, including charges at local stores and the facility vending machines. Police later arrested a CNA at the facility and found the resident’s debit card and SS card on him; the resident could not explain what happened.
Misappropriation of resident property occurred when a CNA was believed to have taken a resident’s debit card and made unauthorized purchases, and also took another resident’s debit card and cash. One resident had Alzheimer’s disease and the other was cognitively intact; both reported missing cards and unauthorized charges were confirmed through bank records, police review, and security footage, with the CNA admitting to taking the card and money.
Misappropriation of Resident Funds and Personal Property
Penalty
Summary
The facility failed to ensure Resident #61 was free from misappropriation of resident funds. Resident #61 was admitted with diagnoses including major depressive disorder, heart failure, and diabetes mellitus, and was documented as alert and oriented with a BIMS score of 13/15. The resident had a resident fund management services account with direct deposit of Social Security and pension income, a monthly allowance of $75.00, and a Medicaid patient liability of $672.00. Review of the resident fund records showed a current balance of $34,245.19 and quarterly statements showing repeated deposits and automatic withdrawals tied to care costs and patient liability. Facility staff stated the resident’s account was high because the county Medicaid Benefits Center did not receive the resident’s income information correctly, and the Medicaid supervisor stated the facility did not have the right to adjust the patient liability submitted in MITS. The facility also failed to ensure Resident #117 was free from misappropriation of personal property. Resident #117 was admitted with diagnoses including COPD, dependence on supplemental oxygen, and heart failure, and was documented as alert, oriented, and able to make decisions with intact cognition. The resident reported that he had used an outside bank account regularly and that he sometimes gave money or his bank card to a former activity aide to make purchases for him. The resident stated that on one occasion the debit card was given to the aide to purchase items for him and to assist with his Medicaid spend-down. The investigation and state findings identified that the former activity aide had misappropriated the resident’s property by making fraudulent purchases with the resident’s bank card. The employee file showed the aide had previously been terminated for unauthorized possession or use of property belonging to the facility. The ODH investigation record and letter stated that the allegation had a reasonable basis and that the Director adopted the finding of misappropriation against the aide. The facility’s abuse prohibition policy stated residents had the right to be free from abuse and misappropriation of resident property and/or funds.
Misappropriation of Resident Funds
Penalty
Summary
The facility failed to protect a resident from misappropriation of property when an LVN allegedly withdrew money from the resident’s bank account without the resident’s knowledge or permission. The resident had been admitted on December 16, 2025, and had a diagnosis of dementia. During the investigation, the Assistant Administrator stated she reported the allegation to police and was present when police interviewed the resident about the missing funds. According to the Assistant Administrator, the resident said he had gone to the bank with the facility’s BA after noticing his account balance was lower than expected, and the bank informed him of several unauthorized withdrawals. The resident filed a fraud report with the bank, and the bank statement reportedly showed the LVN’s name associated with the withdrawals. The resident later stated his bank card had been in his drawer and then went missing, and that a staff person helped him go to the bank to check his money, where he learned someone had taken a large amount of it. The facility’s Resident Rights policy stated residents have the right to be free from abuse, neglect, misappropriation of property, and exploitation.
Misappropriation of Controlled Medications
Penalty
Summary
Facility staff failed to protect residents from misappropriation of controlled medications, including oxycodone and liquid hydromorphone, for four residents. The report states that Resident #12 had diagnoses including rheumatoid arthritis, contracture of the right shoulder, and hemiplegia/hemiparesis following cerebral infarction, and was severely cognitively impaired with a BIMS score of 3. The resident had an order for oxycodone 5 mg every 8 hours for pain, but review of narcotic control sheets and pharmacy delivery information showed multiple missing tablets that could not be accounted for, with no control sheets available for several date ranges and no destruction documentation located. Resident #44, who was cognitively intact with a BIMS score of 13 and had diagnoses including osteoarthritis of the knee and polyneuropathy, also had an order for oxycodone 5 mg twice daily for pain. The MAR showed doses documented as held, and pharmacy personnel confirmed that 60 tablets had been sent on one delivery and 30 tablets on another, leaving 30 tablets unaccounted for. The facility was unable to account for the missing oxycodone tablets. Resident #90, who had chronic pain and a BIMS score of 15, had an order for oxycodone 5 mg every 6 hours for pain/discomfort. Review of the narcotic sheets and eMAR showed doses that were not documented or accounted for, including discrepancies between the number of doses recorded on the control sheet and the number shown on the eMAR. The facility investigation identified a staff nurse as the alleged perpetrator in the missing controlled substances investigation involving Residents #90 and #91, and the nurse refused a drug screen and later terminated employment. Resident #91 had moderate cognitive impairment with a BIMS score of 7 and was ordered hydromorphone oral liquid 1 mg/mL every 4 hours for pain. The MAR showed two doses not administered before the resident’s death, and during the facility’s narcotic audit the liquid hydromorphone was found to have an abnormal color and consistency and was verified by the pharmacist to appear to have been replaced with water. The facility also reported a narcotic discrepancy during shift-change count and reviewed controlled substance records that required separate narcotic sheets and end-of-shift counts, but the medication was found altered and not properly accounted for.
Unaccounted Resident Oxycodone
Penalty
Summary
The facility failed to ensure misappropriation of resident property did not occur for one resident. Resident C had a diagnosis that included chronic pain syndrome. On 6/16/26, the pharmacy delivered 30 tablets of Oxycodone 15 mg for Resident C, and the medication was signed for by an LPN who no longer worked at the facility. An incident report later indicated that one card of Oxycodone was found to be unaccounted for. The written interview statement indicated the LPN who received the medications reported opening the pharmacy bag, signing the manifest, and delivering the medication to another LPN who was in a room with a resident. The first LPN stated she placed the medications on the dresser at the direction of the second LPN and then signed the controlled substance inventory tracker as having given the medications to that LPN. The June 2026 controlled substance inventory tracker did not document Resident C's Oxycodone, and the facility could not account for the missing medication.
CNA Took Resident’s Debit Card and Made Unauthorized Purchases
Penalty
Summary
The facility failed to ensure the right of a resident to be free from misappropriation of property when CNA A took the resident’s debit card and used it to spend $1,103.11 between late June and mid-July 2026. The resident’s record showed altered mental status, cirrhosis of the liver, spinal stenosis, and severe cognitive impairment with a BIMS score of 05. He was dependent on staff for toileting, bathing, dressing, and transfers, and required substantial assistance with eating, oral hygiene, personal hygiene, and rolling left and right. A police report stated that the resident was the victim of fraud involving his debit card. Friend A, who helped the resident with bills, reported that the resident’s account was in the negative after unauthorized transactions were discovered. Friend A stated that a staff member had assisted the resident with a phone bill and then kept the debit card, which was later used for multiple local purchases, including transactions at dollar stores, a liquor store, and the facility vending machines. Screenshots reviewed by surveyors showed 50 disputed transactions totaling $1,103.11. During interviews, the resident could not describe what happened to his debit card and could not identify who may have helped him with his bills. The HR Director stated that CNA A was arrested at the facility and that police found the resident’s debit card and social security card on CNA A’s person. The Administrator stated that the police were notified after Friend A discovered the unauthorized charges and that the facility had no reason to suspect CNA A had taken the card. The facility policy stated that staff must not permit misappropriation of resident property.
Misappropriation of Resident Property
Penalty
Summary
The facility failed to protect residents from the wrongful use of their belongings or money, with theft occurring for 2 of 3 residents reviewed for misappropriation. Resident R4 had diagnoses including Alzheimer’s disease, heart failure, and cirrhosis of the liver, and his MDS documented him as cognitively intact. His care plan identified impaired cognitive function/dementia or impaired thought processes, and an intervention was later added noting he was offered a lock box for cards and money and educated on resident trust accounts. R4’s bank records documented two unauthorized debit card transactions totaling $44.68, and the investigation determined the claims were valid. R4 stated he could not find his debit card and thought he had it at the snack machine the day before; a room search with his approval did not locate the card. The guardian was notified, activity on the card was checked, and it was believed V26, a CNA, took R4’s card and made purchases. R4 later stated his son had full control over his finances and care and had told him there were unauthorized charges on the card. Resident R5 had diagnoses including chronic respiratory failure, type 2 diabetes mellitus, and hypertension, and her state report documented her as cognitively intact. Her state report also documented that police obtained security footage showing V26 using R5’s debit card to make purchases, and it was believed the same staff member took her cash as well. The police spoke with V26, who admitted taking the card and money. R5 stated her card had been stolen, that she reported it missing to a CNA, and that unauthorized charges were later found; she also stated the facility paid her back.
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