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

Deficiencies in Pressure Ulcer and Nail Care Management

Midtown Center For Health And RehabilitationMemphis, Tennessee Survey Completed on 09-05-2024

Summary

The Quality Assurance Performance Improvement (QAPI) committee at the facility failed to effectively identify and address issues related to pressure ulcers and nail care for several residents. The committee did not implement appropriate actions or monitor the effectiveness of these actions, leading to deficiencies in care. Specifically, the facility's QAPI program did not adequately address the needs of residents with pressure ulcers, as evidenced by the presence of Stage 3 pressure wounds, which should have been identified and treated earlier. The facility's policy required regular assessments and monitoring, but these were not effectively carried out, resulting in the progression of pressure ulcers to more severe stages. The facility's administration and nursing leadership were not fully informed or involved in the management of pressure ulcers. The Administrator did not attend weekly wound meetings and relied on the Director of Nursing (DON) for updates, which led to a lack of awareness about the severity of the pressure wounds. The DON was aware of the presence of Stage 3 pressure wounds but did not ensure that the wound nurses were properly certified to stage these wounds. Additionally, the Medical Director was not informed about the severity of the pressure wounds, indicating a breakdown in communication and oversight within the facility's leadership. The facility also failed to provide adequate nail care for a vulnerable resident, resulting in actual harm when the resident's toenails adhered to the skin, causing pain. This incident highlights the facility's failure to provide care consistent with professional standards of practice. The lack of proper assessments, documentation, and communication contributed to the deficiencies in care, as the facility did not ensure that staff were adequately trained and informed about the residents' needs and the facility's policies.

Removal Plan

  • Identification of residents affected or likely to be affected
  • All residents had an updated Braden Assessment completed
  • Ensure initial skin assessments were completed
  • Facility policies and procedures related to skin care, wound care, and pressure injury prevention were reviewed and revised
  • Provided education to all licensed nurses on the completion of the Braden Score Assessment policy, and completed treatments on all new admissions
  • Daily audit of the Treatment Administration Record to ensure accurate and complete documentation of skin related treatments as ordered
  • Daily audits of skin related treatments including documentation, Braden Assessments, and orders
  • PIP initiated to report on above monitoring and will continue

Penalty

Inspection fine: $188,37916 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 Monitoring Deficiencies for Skin Assessments and Food Sanitation
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI monitoring was deficient when the facility failed to ensure performance improvement activities were properly implemented and tracked for incomplete skin assessments and food labeling issues in the snack room. The CEO stated there were three PIPs, but benchmark measurements were not consistently documented, one PIP remained active after completion because the facility did not want to fall off track, and the current measurement method did not adequately track whether improvement had occurred since implementation.

No penalty information released
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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.
Failure to Develop a Staffing PIP
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 failed to develop and implement a PIP for staffing concerns after those issues were identified in QAPI. The DON stated staffing had been discussed, but no current staffing PIP existed, and later said a PIP was not started because the owner said there was no staffing issue. The Administrator reported short staffing for about a month, with call outs and no shows worsening after delayed paychecks, and staff said staffing concerns were discussed in QAPI along with efforts to find solutions and hire CNAs and nurses.

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 Long Call Light Wait Times
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 address resident concerns about long call light wait times, which were linked to cares not being performed and toileting tasks not being completed in a timely manner. QAPI notes showed repeated discussion of call light delays over several months, including a 9-minute response goal, follow-up by nurse managers, daily report review, and adding management staff around mealtimes, but there was no discussion about increasing facility staffing related to the concern.

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 Maintain Clean and Homelike Environment
D
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 Maintain Clean and Homelike Environment: Surveyors found that resident rooms, shower rooms, and common areas were not kept clean and homelike, with black buildup in grout, damaged grout, chipped floor tiles, and dusty ceiling vents. On revisit, the same environmental deficiency recurred, showing the facility did not sustain compliance with the cleanliness requirement.

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 Program Failed to Analyze Repeated Incontinence Care Neglect
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI Program Failed to Analyze Repeated Incontinence Care Neglect: Multiple FRIs substantiated repeated failures to provide incontinence care, including not honoring a resident’s bedpan preference and instructing the resident to urinate in an incontinence brief. Although the facility used audits, staff education, and disciplinary action, the audit tool lacked meaningful documentation, and QAPI minutes did not include data analysis, RCA, or a PIP/action plan for the recurring incontinence care 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.
Ineffective QAPI Oversight and Tracking of 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

Ineffective QAPI oversight and tracking of PIPs: The facility’s QAPI minutes showed multiple ongoing PIPs for concerns such as staffing, hand hygiene, incontinence care, care conferences, tray accuracy, narcotic counts, HR, and showers, but many lacked measurable goals, dates, or a designated point person. Prior action items were not shown to be revisited or followed through in later meetings, and the Administrator, DON, and Corporate RN acknowledged that not all concerns were turned into PIPs. Several of the same issues later appeared as survey deficiencies.

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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