Failure to Train Agency Staff on Abuse Prevention Policies
Summary
The facility failed to provide abuse prevention training to four agency employees, as determined through staff interviews and a review of employee personnel records. Employees 1, 2, 3, and 4, who were agency staff including a Licensed Practical Nurse, a Registered Nurse, and two nurse aides, reported that they had not received training on the facility's abuse prohibition policy prior to assuming their duties. Employee 1 had been working at the facility on and off for four months, Employee 2 was on her fourth shift, Employee 3 had been working intermittently for six months, and Employee 4 for four months. None of these employees had documentation of having received the required training. The Director of Nursing confirmed that there were no written records to show that these agency employees were trained on the facility's abuse prohibition policies and procedures as part of their orientation. The DON further stated that agency employees are not inserviced on the facility's abuse policy before starting their work. This lack of training is a violation of the facility's obligation to ensure all staff are educated on abuse prevention, as required by 28 Pa. Code 201.20 (a)(b) Staff development and 28 Pa. Code 201.19 (6)(7) Personnel policies and procedures.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Several nurses did not receive required training on abuse, neglect, and exploitation during orientation or annually, as mandated by facility policy. Employee file reviews and staff interviews confirmed missing documentation of this training, despite expectations set by facility leadership and policy requirements. This deficiency had the potential to affect all residents in the facility.
A review of personnel files and staff interviews revealed that five CNAs did not receive required training or competency verification in dementia management and abuse prevention, despite facility policies mandating such education. The DON confirmed the absence of training records, and this deficiency had the potential to impact all residents in the facility.
Failure to Provide Required Abuse, Neglect, and Exploitation Training to Nursing Staff
Penalty
Summary
The facility failed to ensure that four nursing staff members received required training on abuse, neglect, and exploitation during orientation and annually, as mandated by facility policy. Employee file reviews showed that three nurses hired within the past two years had no documented evidence of having completed abuse/neglect training within the last 12 months. Additionally, a recently hired nurse had no documentation of receiving this training at all. These findings were confirmed through staff interviews, where the Director of Nursing, Administrator, and Human Resources Director all acknowledged the expectation that staff complete required in-services and that management should monitor compliance. However, the Human Resources Director was unable to explain why the required abuse training was missing for these staff members. The facility's policy on abuse prevention and reporting, updated in 2018, requires all new employees to receive training on abuse policies during orientation and mandates annual training for all staff. The policy specifies that training must cover definitions of abuse, neglect, and exploitation, reporting requirements, and appropriate interventions. The lack of documented training for these four nurses represents non-compliance with both facility policy and regulatory requirements, with the potential to affect all residents in the facility, which had a census of 92 at the time of the review.
Failure to Provide Required Dementia and Abuse Prevention Training to CNAs
Penalty
Summary
The facility failed to provide required training and competency verification in dementia management and abuse prevention for five Certified Nurse Aides (CNAs) as evidenced by a review of their personnel files. The files for these CNAs, who had hire dates ranging from 2011 to 2023, contained no documentation of training or competency in abuse, neglect, exploitation, or dementia care. This lack of documentation was confirmed during an interview with the Director of Nursing (DON), who acknowledged that the necessary training had not been provided as required and that there were no records of such training for the staff in question. Policy review revealed that the facility's own procedures require in-service training for nurse aides in areas including effective communication, dementia management, and abuse prevention, as well as annual education for existing staff on abuse, neglect, and exploitation. Despite these policies, the facility did not ensure that the five CNAs received the mandated education, which had the potential to affect all 91 residents in the facility.
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