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

QAPI Committee Fails to Address Abuse Allegations

Walker Rehabilitation Center, IncCarbon Hill, Alabama Survey Completed on 11-30-2024

Summary

The facility's Quality Assurance and Performance Improvement (QAPI) committee failed to thoroughly review and address allegations of abuse that occurred on multiple occasions, specifically on 07/08/2023, 07/09/2023, 09/06/2023, and 05/10/2024. These incidents involved several residents and were not adequately analyzed to identify causal factors or to implement corrective actions to prevent future occurrences. The QAPI committee did not ensure that the facility's abuse policy was fully implemented, which includes identifying, stopping, and reporting abuse, as well as conducting thorough investigations. Interviews with facility staff, including the Director of Nursing (DON) and the Administrator, revealed that the QAPI meetings did not include discussions about the specific incidents of abuse. The DON admitted that the incidents involving certain residents were not discussed in any QAPI meetings, and the Administrator confirmed that while the number of abuse incidents was recorded, they were not reviewed or discussed in detail. This lack of discussion and analysis prevented the facility from addressing the culture and behavior of staff that led to the abuse. The Director of Operations, who was responsible for day-to-day operations, also acknowledged that she had not participated in QAPI meetings and expected them to occur monthly. She agreed that allegations of abuse should be discussed during these meetings to conduct root cause analysis. The failure to review and discuss these incidents in QAPI meetings resulted in the facility's noncompliance with regulatory requirements, which was determined to have caused or was likely to cause serious harm to residents.

Removal Plan

  • Administrator resigned and the new administrator hired.
  • Director of Clinical Services trained the Director of Operations on the abuse policy and how to conduct a thorough investigation, how to identify contributing factors and take corrective action to prevent further abuse.
  • The Director of Operations in-serviced the new administrator on QAPI program and all the elements related to abuse including screening, training, prevention, identification, investigation, protection, reporting/response, and QAPI.
  • The administrator trained following employees who attended QAPI committee meeting include RN supervisor, medical records, director of rehab, director of nursing, infection preventionist/restorative nurse, environmental services, director of operations, and corporate human resources director on QAPI program and all the elements related to abuse including screening, training, prevention, identification, investigation, protection, reporting/response, and QAPI.
  • All abuse investigations were reviewed by the Administrator to ensure all allegations were identified by staff, residents were immediately protected, allegation reports per policy, investigations were completed appropriately, had appropriate witness statements collected, all causal factors were identified, and appropriate corrective action was taken.
  • Employees who failed to report are no longer employed with the company and the residents are not in the facility at this time.
  • The Director of Operations provided 1-on-1 in-service to Administrator and DON regarding conducting QAPI meeting.
  • Monthly QAPI meetings were reviewed to ensure no other residents were affected. Reviewed to make sure nothing was missed in QAPI.
  • The Ad Hoc QAPI meeting was completed. QAPI committee was informed and the plan was made that one member of the corporate team will be included in all meetings to ensure allegations of abuse and monthly QAPI meeting to ensure all causal factors are addressed.
  • The causal factors will be identified through the root cause analysis using the five Why's method. QAPI team will need to be educated on conducting root cause analysis.
  • QAPI meeting held to develop and implement a process to ensure all substantiated allegations of abuse are reviewed and analyzed to ensure the appropriate corrective actions is taken to address all contributing factors of abuse.
  • The administrator will be responsible for bringing all allegations of abuse to the QAPI meeting utilizing root cause analysis and the five why's method to ensure all casual factors have been addressed.

Penalty

Inspection fine: $235,127
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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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