Untrained Staff Assisted Resident with Dysphagia
Summary
The facility failed to ensure that staff assisting residents with meals completed the required training. On a specific date, a Unit Secretary, who was not trained or certified, assisted a resident with a diagnosis of dysphagia during breakfast. This resident, admitted in 2018, has severe cognitive impairment and is dependent on staff for eating, as indicated by the Minimum Data Set Assessment. The resident's speech therapy discharge summary highlighted the need for staff training in feeding assistance and swallow-safe strategies. During the incident, the Unit Secretary, who had previously worked as a CNA but had not maintained her license or training, assisted the resident due to a lack of available staff in the dining room. The Unit Manager intervened and requested a CNA to assist the resident instead. Interviews with the Director of Nursing and Staff Development Coordinator confirmed that only certified or trained staff should assist with meals, and the Unit Secretary's actions were not in line with facility expectations. The facility did not provide a policy regarding staff assistance with meals.
Penalty
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The facility did not provide required annual in‑service training and skills evaluations for two of four paid feeding assistants. Records showed that the Director of Rehabilitation and another feeding assistant each completed a state‑approved Feeding Assistant Program with skills review, but there was no documentation of any annual refresher training or competency review afterward. One feeding assistant confirmed there had been no additional training, and HR reported being unaware of the annual training and skills review requirement, while the NHA stated an expectation that such refresher training would occur per state regulations.
The facility did not maintain required documentation showing that all paid feeding assistants had successfully completed a State-approved training course. Review of facility records showed 12 staff functioning as paid feeding assistants and 9 residents approved for the paid feeding assistant program, but the DON reported that documentation of completed training could only be found for 6 staff. The DON stated that a Life Enrichment Coordinator and several Dining Room Assistants had completed the training and assisted with feeding, yet the facility was unable to locate records verifying their training completion.
A resident with Alzheimer's disease, GERD, severe protein-calorie malnutrition, and dysphagia-related aspiration risk was observed being fed breakfast by a manager in the resident's room. The manager later confirmed she was feeding the resident even though she was not a certified feeding assistant or CNA, and the facility policy listed only RN, LPN, and STNA/CNA staff as responsible for feeding impaired residents.
The facility did not ensure that paid feeding assistants working as Home Health Aides had completed the required NYSDOH-approved 8-hour feeding assistant training before feeding residents. Surveyors observed aides feeding residents with dementia and other conditions, including residents who needed meal assistance and one resident on aspiration precautions, while staff stated the aides were used to feed residents on the units and the SLP’s competency review was not the State-required course.
A facility failed to train a non-licensed employee, Activities Aide B, with the State-approved course for feeding assistance. During a breakfast observation, the aide was seen feeding a resident requiring a mechanical soft diet, despite not being certified or trained. The DON confirmed only CNAs should provide such assistance, and the facility lacked paid feeding assistants. The aide's file showed no certification or training, and the job description did not include feeding duties, increasing the risk of feeding complications.
Activities Assistants were observed assisting residents with feeding after completing a training program that had not been approved by the State of Massachusetts. The DON and Activities Director confirmed that the program was not state-approved and that Activities Staff were assigned to assist with feeding by CNAs or nurses, with uncertainty about licensed nurse supervision during meals.
Failure to Provide Required Annual Training and Skills Review for Feeding Assistants
Penalty
Summary
The facility failed to ensure that its Feeding Assistant Program included required annual training and skills review for two of four paid feeding assistants reviewed. Wisconsin state requirements for feeding assistants, aligned with 42 CFR 483.60(h), specify that feeding assistants must receive an annual in‑service on relevant feeding topics and must be evaluated yearly to document satisfactory skill performance and feeding competence. Surveyor review of the Director of Rehabilitation’s (DOR K) Feeding Assistant Training Program documents showed that DOR K completed the state‑approved program, including training and skills review, on 4/17/24, but there was no documentation of any annual training or skills evaluation after that date. Similarly, review of feeding assistant records for staff member [NAME] V showed successful completion of the state‑approved Feeding Assistant Program, including training and skills review, on 4/17/24, with no subsequent annual training or skills monitoring documented. During an interview, [NAME] V confirmed that there had been no additional training after completion of the initial Feeding Assistant Program. In a separate interview, the Human Resources representative (HR W) stated that no additional training had been provided to feeding assistants and acknowledged being unaware of the requirement for annual training and skills review. The Nursing Home Administrator (NHA A) stated that she would have expected refresher training to be completed in accordance with state regulations.
Missing Documentation of State-Approved Training for Paid Feeding Assistants
Penalty
Summary
The facility failed to maintain records of successful completion of a State-approved paid feeding assistant training course for 6 of 12 staff members functioning as paid feeding assistants. Surveyors reviewed facility lists showing 12 staff designated as paid feeding assistants and 9 residents approved for the paid feeding assistant program. During an interview, the DON stated the facility could only locate documentation of completed State-approved training for 6 of the 12 paid feeding assistants. The DON identified specific staff, including the Life Enrichment Coordinator and multiple Dining Room Assistants, who had reportedly completed the paid feeding assistant training and had assisted residents with feeding, but the facility was unable to locate documentation verifying that these individuals had completed the required training. No additional clinical details or medical histories of the 9 residents approved for the paid feeding assistant program were provided in the report, and the deficiency centers on the absence of required training documentation for staff who assisted with feeding.
Unqualified Staff Fed a Resident With Dysphagia
Penalty
Summary
The facility failed to ensure that staff assisting residents with feeding were competent or certified, affecting one resident observed being fed by staff. Resident #16 was admitted with diagnoses including Alzheimer's disease with late onset, gastro-esophageal reflux disease without esophagitis, and unspecified severe protein-calorie malnutrition. The resident's care plan identified a risk for aspiration related to dysphagia and directed staff to assist with meals, feed at times, and not leave the resident alone, with the intervention assigned to CNA/STNA, RN, and LPN staff. During observation, a manager was seen assisting Resident #16 with eating breakfast in the resident's room, and later verified that she was feeding the resident even though she was not a certified feeding assistant or certified nursing aide. The facility policy on feeding impaired residents identified RN, LPN, and STNA/CNA staff as the roles responsible for feeding impaired residents.
Feeding Assistants Lacked Required State Training
Penalty
Summary
The facility did not ensure that paid feeding assistants working under the title Home Health Aides had successfully completed the required State-approved 8-hour feeding assistant training before feeding residents. During the recertification survey, there was no documentation that 12 of 12 reviewed Home Health Aides had the required training, even though the facility provided certificates showing completion of Home Health Aide courses from an outside agency. An email from that agency stated its Home Health Aide program did not include the separate NYSDOH-approved Feeding Assistant Training. Facility records also showed the Home Health Aide job description did not include feeding residents, despite staff statements that these aides were used for feeding and transportation. Surveyors observed Home Health Aide #4 feeding a resident with dementia, hypertension, and Alzheimer’s disease who needed assistance with meals, and later feeding another resident with Alzheimer’s disease, psychosis, and depression who had severe cognitive impairment and aspiration precautions. Home Health Aide #36 was observed feeding a resident with hypertension, type II diabetes, and dementia who had severe cognitive impairment and needed assistance with meals, and Home Health Aide #38 was observed feeding the resident with dementia, hypertension, and Alzheimer’s disease. Staff interviews confirmed that aides were feeding residents on the units, including puree, chopped, and modified diets, while the DON stated they were not aware of the required 8-hour training and the SLP stated the competencies performed were not State course certification.
Untrained Staff Providing Feeding Assistance
Penalty
Summary
The facility failed to ensure that a non-licensed employee, Activities Aide B, received the State-approved training course for feeding assistance to residents. During a breakfast observation, Activities Aide B was seen feeding a resident who required assistance with a level 3 advanced mechanical soft diet. When questioned, Activities Aide B stated that she was providing assistance because other staff were unavailable. The Director of Nursing confirmed that only Certified Nurse Aides are allowed to provide feeding assistance, and the Nursing Home Administrator verified that the facility does not employ any paid feeding assistants. A review of Activities Aide B's employee file revealed that she was not certified and had not completed the required State-approved training course for feeding assistance. This training includes essential skills such as feeding techniques, communication, safety procedures, and recognizing changes in residents' behavior. Additionally, the facility's job description for the Activity Aide position did not include feeding assistance as part of the essential functions and responsibilities. This oversight resulted in an increased risk of feeding complications for the residents requiring assistance during mealtimes.
Unapproved Training Program Used for Paid Feeding Assistants
Penalty
Summary
The facility failed to ensure that individuals utilized as paid feeding assistants completed a State-approved training program, as required. During meal observations, Activities Assistants were seen assisting residents with feeding in the dining rooms of two units. Although the Director of Nursing (DON) stated that all Activities Staff had been trained to feed residents, it was later revealed that the training program used by the facility had not been submitted to the State of Massachusetts for approval. The DON was unsure if the program met state requirements and confirmed that an application for approval was only being completed after the surveyor's inquiry. Further interviews indicated that Activities Staff were assigned to assist with feeding by CNAs or nurses, and were instructed not to assist residents with swallowing difficulties. The Activities Director confirmed that all Activities Staff, including herself, had completed the facility's paid feeding assistant training, but could not confirm if a licensed nurse was always present during meals, only that a CNA was always available. The deficiency centers on the use of unapproved training for paid feeding assistants and the lack of assurance that state requirements for such training and supervision were met.
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