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

Deficiencies in QAPI Program and Notification Compliance

Highpointe On Michigan Health Care FacilityBuffalo, New York Survey Completed on 09-16-2024

Summary

The facility failed to ensure that its Quality Assurance and Performance Improvement (QAPI) program effectively identified, developed, and implemented plans to prevent and protect residents from sexual abuse. Specifically, the program did not address repeated patterns of sexually inappropriate behaviors by a resident. This deficiency was highlighted by an incident where a resident was found in another resident's room with exposed breasts, and the offending resident was observed inappropriately in common areas and other residents' rooms on multiple occasions. Despite these incidents, the QAPI committee did not review or discuss the sexual abuse allegations in a timely manner, as meetings were canceled, and the issue was not added to the agenda when meetings resumed. Additionally, the facility failed to comply with regulations regarding hospital transfer/discharge notifications and bed hold policy notices. The records of two residents who were transferred to the hospital and readmitted multiple times showed no evidence that the required notifications were completed and provided to the residents or their representatives. This oversight was not identified by the facility's QAPI program until it was pointed out during the survey, indicating a systemic failure in the notification process. Interviews with facility staff, including the Director of Nursing and the President of Long-Term Care, revealed that the QAPI committee did not adequately review incidents reported to the Department of Health. The committee's purpose was to assess issues, interventions, and determine if additional actions were needed to ensure resident safety and improve outcomes. However, the failure to address the sexual abuse allegations and the lack of compliance with notification requirements demonstrate significant lapses in the facility's quality assurance processes.

Penalty

Inspection fine: $129,149
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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
Failure to Include Abuse and Injury Incidents in QAPI Review
E
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 failed to include adverse event monitoring of alleged physical and sexual abuse in its QAPI activities. Surveyors reviewed 2 FRIs involving injuries of unknown origin and 4 FRIs involving alleged abuse, and the DON stated these incidents had not been reviewed or tracked through the QAPI process, despite facility policy requiring abuse, neglect, and misappropriation investigations to be reviewed by QAPI.

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 Fully Analyze Elopement and Smoking Noncompliance Events
E
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 identify all causal factors related to two elopements and smoking noncompliance involving two residents. The committee did not determine all contributing factors or what actions were needed to prevent further resident safety concerns. The facility’s policy required systematic analysis and root cause review, but the investigation showed the events involved a resident accessing clippers and cutting a screen, a window that was not properly secured, and smoking concerns tied to the absence of a locked container for smoking materials.

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 Address 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

QAPI Committee Failed to Address Repeated Deficiencies: The facility’s QAPI committee did not successfully implement prior plans of correction tied to repeated survey deficiencies. Current findings showed ongoing problems with MDS accuracy, care plan creation and revision, quality care, safety hazards, incontinence and catheter care, IV catheter maintenance, narcotic accountability, and infection control, despite prior audit-based plans being reported to the QAPI committee.

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.
Ineffective QAPI Program Fails to Correct Repeated Medication Storage 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

Surveyors found that the facility’s QAPI/QAA program was ineffective in correcting repeated deficiencies related to improper medication storage (F0761). Despite having a written QAPI policy, holding monthly QAA Committee meetings attended by the administrator, DON, medical director, and other department heads, and reporting that direct care staff were invited to participate, the same medication storage deficiency previously cited during an earlier survey recurred. With 94 residents in care, the facility’s QAPI activities did not produce an effective plan of action to resolve and prevent the ongoing medication storage problem.

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.
QAA Committee Failed to Identify Multiple Deficient Practices
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The QAA Committee failed to identify and address multiple deficient practices, including missing Medicare/Medicaid coverage liability notices, lack of a stop date for an as-needed antianxiety med, missing bed hold notification, failure to report a change in condition after an unresponsive episode, inadequate fall investigations, failure to address weight loss, missing dialysis assessments and care planning, kitchen sanitation issues, an incomplete facility assessment, and failure to provide EBP for a resident with a Foley catheter. Admin staff stated monthly QAA meetings were held with the MD, but the facility had not self-identified or corrected the deficiencies through PI 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.
Ineffective QAPI Oversight and Incomplete Performance Improvement Plans
F
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 process was found ineffective because multiple QAPI action plans lacked a specific point person, clear completion dates, and documented monthly progress. Review of QAPI minutes showed repeated issues involving falls, dietary services, infection control, wound care, discharge documentation, pharmacy services, MDS assessments, and other areas, with no evidence that prior action items were revisited or that full PIPs were completed. The Administrator, DON, and RDI acknowledged there was no evidence of auditing, education, or other documented monitoring tied to the identified concerns, and the Administrator stated there was not yet a mechanism for residents and staff to report issues to QAPI.

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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