Failure to Follow Two-Person Transfer Protocol
Summary
The facility failed to ensure that nurse aides demonstrated competency in skills necessary to care for resident needs, specifically for a resident requiring two-person assistance with bed mobility and mechanical lift transfers. On one occasion, a Certified Nursing Assistant (CNA) independently turned and positioned the resident and used a mechanical lift for transfer without assistance, contrary to the facility's policy and the resident's care plan. The resident involved had severe cognitive impairment and functional limitations due to Alzheimer's Disease, Cerebral Infarction, and Type 2 Diabetes Mellitus. The care plan and physician's orders specified the need for two-person assistance for transfers, which was not followed by the CNA. This resulted in the resident sustaining a bruise on the forehead, indicating a failure to adhere to the established care plan. Interviews revealed that the CNA did not seek assistance for the transfer, despite the availability of staff, and had a history of similar incidents. The CNA admitted to transferring the resident alone, believing a nurse was nearby, but no assistance was provided. The Director of Nursing confirmed the CNA's actions were against the facility's policy and unsafe for the resident.
Plan Of Correction
Plan of Correction: Approved December 31, 2024 I. The following actions were accomplished for the residents identified in the sample: Resident #73 On 11/18/24, the IDCP Team reviewed the resident’s plan of care related to risk for accidents and determined that the resident continues to require two-person assistance with bed mobility and two-person assistance with a mechanical lift for transfer in and out of bed. CNA #14, who repositioned the resident and completed the mechanical lift transfer without a second staff member providing assistance to complete these tasks was terminated. On 12/30/24, the Chief Nursing Officer met with the Staff Educator to review her responsibility to monitor and ensure that all required CNA annual competencies, including two-person assisting with turning and positioning in bed and mechanical lift transfers are completed by each CNA. II. The following corrective actions will be implemented to identify other residents who may be affected by the same practice: All residents who require two-person assistance with turning and positioning and/or require the use of a mechanical lift for transfers have been identified as potentially being affected by the same practice. The Staff Educator will identify all CNAs who have not completed competencies related to two-person assistance for turning and positioning in bed and completing a mechanical lift for transfer during 2024. All identified CNAs will have these competencies completed by 01/31/2025. III. The following system changes will be implemented to assure continuing compliance with regulations: The Chief Nursing Officer and Staff Educator will review the facility’s list of annual CNAs competencies and will revise the competency list as needed. Annual competencies will continue to include two-person assistance with turning and positioning/bed mobility and two-person assist mechanical lift transfers. The Staff Educator/designee will schedule and complete annual competency training for all CNAs during 2025 to ensure that all CNAs are able to demonstrate that they are competent to provide care and services as outlined in each resident’s person-centered plan of care. The RN Supervisors and Nurse Managers will continue to monitor for compliance with the Nursing staff following the plan of care during routine and random rounds and observations of care being provided, staff assistance with bed positioning, and transfers being completed with a mechanical lift and two-person assist to ensure the plan of care is being followed and staff demonstrate care practices consistent with facility policy. Immediate corrective actions, such as staff reeducation on bed mobility assistance, transfer/use of a mechanical lift and responsibility to follow the plan of or revision of the plan of care to meet a resident’s care needs based on a change in status. IV. The facility’s compliance will be monitored utilizing the following quality assurance system: The facility will develop an audit tool to monitor compliance with all CNAs completing the required CNA competency training annually. The Nurse Manager/designee will complete 5 random unannounced competency observation audits to assess compliance with safe provision of care consistent with the ADL/transfer assist instructions weekly x 4 weeks then monthly x 3 months inclusive of all 3 shifts. Residents requiring two-person assistance with bed mobility and/or two-person assist with a mechanical lift transfer will be included in the audit sample. Auditing will begin early 01/2025. The Staff Educator/designee will review and summarize all observation audits on a weekly then monthly basis as outlined above and will report all findings to the Chief Nursing Officer and Administrator. Corrective actions will be implemented based on summary information. The Staff Educator will report competency audit findings to the QAPI Committee monthly during the 4-month monitoring period for discussion, evaluation, and follow-up corrective action. At the end of the 4-months a decision will be made regarding the need for ongoing auditing and at what frequency. Completion Date: 01/31/2025 Responsibility: Staff Educator
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Insulin Pen Priming Competency Not Verified: An LPN administered Humalog insulin to a resident without priming the Kwik Pen first and stated she was unaware that priming was required. The facility could not produce the nurse's skills check sheet, and the competency form reviewed did not include priming an insulin pen, despite the insulin instructions stating the pen must be primed before each injection.
A facility failed to ensure a QMA had a current license while distributing meds to residents. Record review showed the QMA was scheduled and worked on multiple days across 3 resident units, but the licensure binder and Indiana License Registry showed the QMA's license had expired. The ED stated staff should not distribute meds with an expired QMA license and that the facility had no written policy requiring QMAs to work with a current license.
Missing Mandatory Orientation and Training for Agency CNA: The facility assigned an agency CNA to provide resident care without documentation showing completion of required orientation and in-service training. The CNA stated they did not receive orientation, a training packet, or training on abuse/neglect, dementia care, behavioral health, trauma-informed care, or managing difficult behaviors before working on resident units. The ADON/Staff Educator and DON stated the required training should have been completed and documented in the employee file, but the records could not be located.
CNA Competency Review Completed After Annual Evaluation: The facility failed to ensure that a CNA received a comprehensive clinical competency skills review before the CNA's annual performance evaluation. Record review showed the CNA's annual performance review was completed before the competency review, and the DSD stated she was unaware of the requirement that the skills competency evaluation be completed prior to the annual evaluation.
Incompetent PEG Tube Medication Administration: An LPN was observed administering crushed medication via a resident’s PEG tube but poured the diluted medication directly into the tube without a syringe, causing it to spill. The LPN then did not know how to connect the syringe to the PEG tube and had to call for help, while the DON provided instruction. The resident had diagnoses including an unstageable sacral pressure ulcer, pain, and aphasia following cerebral infarction, and the DON stated the resident did not receive the full dose of medication.
A resident with urinary retention and BPH required a coude catheter, but when the catheter became obstructed, an LPN told the resident to wait until day shift for a change and did not notify the RN supervisor or seek help. Facility records showed no competency training, return demonstration, or skills validation for Foley or coude catheter care, and multiple nurses said they had not received facility-specific education or competency checks for coude catheter management.
Insulin Pen Priming Competency Not Verified
Penalty
Summary
The facility failed to ensure staff possessed the skills and competencies required when a Licensed Nurse administered Humalog insulin to R19 without priming the Kwik Pen first. On 06/02/2026 at 10:13 AM, R19 walked in the hall with a walker, then went to her room with the nurse to receive insulin. The nurse clicked up seven units in the pen and administered the insulin in R19's left arm without priming the pen, and then verified that she had not primed it and stated she was unaware she was supposed to. When the facility was asked for the nurse's skills check sheet, it could not provide it. Review of a blank medication pass competency check sheet showed no competency assessment for priming an insulin Kwik Pen. The insulin pen instructions in the pamphlet directed staff to prime the pen before each injection, and Administrative Nurse D stated she expected staff to prime the insulin pen with two units before administration. She also stated that nurses were required to complete an insulin competency check-off upon hire, and later verified that the nursing skills check lacked a competency item for priming an insulin Kwik Pen.
Expired QMA License During Medication Distribution
Penalty
Summary
The facility failed to ensure that a Qualified Medical Assistant had a current license while distributing medications to residents. A record review showed that QMA 3 was scheduled to distribute medications and had worked as a QMA on multiple days across three resident units from April through the review period. The facility's Employee Certification and Licensure binder showed that QMA 3's license had expired, and the Indiana License Registry website also indicated the license was expired. In interviews, the Executive Director stated that staff should not distribute medications with an expired QMA license and that the facility did not have a written policy requiring QMAs to work with a current license.
Missing Mandatory Orientation and Training for Agency CNA
Penalty
Summary
Certified Nurse Aide #1 was assigned resident care duties on 05/11/2026 as agency staff, but the facility could not provide documentation showing completion of required orientation and mandatory training before the aide worked independently. The missing documentation included, but was not limited to, Abuse/Neglect/Exploitation Prohibition, Behavioral Care Services/Cognitive Impairment/Dementia Training, Trauma Informed Care, Communication Training, and other required orientation and in-service training elements. During the survey, the Assistant Director of Nursing/Staff Educator stated agency staff are required to complete the same mandatory orientation and in-service training as facility staff and that training modules, sign-off documentation, and post-tests are maintained in employee files. However, the facility was unable to locate records verifying that Certified Nurse Aide #1 completed the required training. Certified Nurse Aide #1 stated they did not receive orientation, a training packet, or any of the listed training topics before being assigned to provide resident care on Units 2 and 3. The Administrator also stated that all staff are required to complete mandatory orientation and in-service training prior to working independently and that documentation should have been maintained in the employee file.
CNA Competency Review Completed After Annual Evaluation
Penalty
Summary
The facility failed to implement its policy regarding nursing staff competency by not ensuring that CNA 3 received a comprehensive clinical competency skills review before the CNA's annual performance evaluation. During a concurrent interview and record review on 5/29/2026 at 12:18 p.m., the Director of Staff Development reviewed CNA 3's personnel file, the C.N.A. Comprehensive Clinical Competency Review- Skills Checklist form, and the Annual Performance Review form. The review showed that CNA 3's clinical competency review was completed on 1/22/2026, while the annual performance evaluation was completed earlier, on 12/24/2025. During a concurrent interview and record review on 5/29/2026 at 12:26 p.m., the Director of Staff Development reviewed the facility's policy titled Nursing Staffing Competency and stated she was unaware of the facility's requirement that the annual skills competency evaluation be completed prior to a CNA's annual performance evaluation. The policy stated that the facility will identify annual skills competencies needed for each role and establish a schedule or process to facilitate completion of skills and competency evaluations, and that successfully completed orientation and skills check are required prior to the employee's annual evaluation.
Incompetent PEG Tube Medication Administration
Penalty
Summary
The facility failed to ensure licensed nurses had the necessary competency skills to administer medication via PEG tube for one resident. During an observed medication pass, an LPN prepared crushed medication for the resident’s PEG tube, donned a gown and gloves, stopped the tube feeding, and checked placement and residual. The LPN then poured water and the crushed medication into a 30 ml cup and attempted to pour the diluted medication directly into the PEG tube without using a syringe, causing the medication to spill out over and around the tube. The LPN then obtained another cup with diluted medication and a syringe but did not know how to connect the syringe to the PEG tube, hesitated, activated the call light, and stated they would call for assistance. The DON later entered the room and provided instructional assistance to the LPN on administering medication through the PEG tube. The resident had diagnoses including an unstageable sacral pressure ulcer, pain, and aphasia following cerebral infarction. A physician order directed flushing the PEG tube with 30 ml of water before and after medications and 15 ml between each medication. The LPN stated they were unsure how much medication the resident received when the diluted medication spilled during administration. The DON stated the LPN did not correctly administer the medication via the PEG tube, that the medication was spilled and the resident did not receive the full dose, and that the LPN should have notified the physician. The DON also stated the facility used skills competency checklists upon hire and yearly during a skills fair, but the LPN did not have a skills competency checklist completed upon hire and was past the 90-day timeframe for completion.
Lack of competency validation for coude catheter care
Penalty
Summary
The facility failed to ensure licensed nursing staff possessed and demonstrated the competencies needed to safely assess, manage, and provide care for residents requiring a coude catheter. Resident 9 was admitted with urinary retention and benign prostatic hyperplasia with lower urinary tract symptoms, and a care plan dated March 30, 2026, identified the need for a coude catheter. On May 7, 2026, nurse documentation and interview with the DON showed the resident’s coude catheter became obstructed during the night shift, and the LPN on duty told the resident he would need to wait until day shift staff arrived for the catheter to be changed. The DON stated the LPN reported she was not comfortable changing the coude catheter because of a lack of familiarity and experience with that type of catheter, and she did not notify the RN supervisor or seek assistance to ensure timely catheter intervention. Review of facility documentation titled Skilled Nursing Competency Training showed competencies listed for licensed practical nurses, including nephrostomy tubes and suprapubic catheters, but the facility did not include competency training, return demonstration, or skills validation for Foley catheter insertion, Foley catheter management, or coude catheter care and replacement. During interviews, four licensed nurses stated they had general catheter education in nursing school and prior experience with coude catheters at previous employers, but all reported the facility had not provided facility-specific education, training, competency evaluation, or skills validation related to coude catheter care, evaluation, insertion, replacement, or management. The DON was unable to provide documented evidence that licensed nursing staff had completed education, training, competency evaluations, or demonstrated proficiency for Foley catheter care or specialized coude catheter management.
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