Inadequate Staff Competency in Behavioral Health Documentation
Summary
The facility failed to provide sufficient staff with the necessary competencies and skills to meet the behavioral health needs of its residents, as evidenced by the case of one resident. This resident, who was admitted with diagnoses including bipolar disorder, generalized anxiety disorder, and depression, reported increased anxiety over several weeks. Despite the resident's reports, the nurse practitioner did not adjust the anti-anxiety medication due to a lack of documented symptoms in the nursing records. The facility's policy requires behavioral health services to be provided in accordance with comprehensive assessments and care plans, but the documentation did not reflect the resident's increased anxiety symptoms. The resident's clinical records showed that anxiety behavior tracking was inconsistently documented in the Medication Administration Record (MAR) and progress notes. For the month of March, the majority of shifts lacked documentation of anxiety behavior tracking, with only 11 incidences recorded in the MAR and 5 additional shifts noted in progress notes. A psychiatry note indicated the resident's anxiety was affecting sleep, yet staff documentation did not reflect these symptoms. An interview with the Director of Nursing confirmed the lack of documentation per physician orders, highlighting the facility's failure to employ staff with the necessary competencies to ensure resident safety and well-being.
Penalty
Resources
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Failure to document behavioral interventions and resident responses for three residents with behavioral health needs. One resident had confusion, stroke-related deficits, depression, anxiety, and intellectual disabilities; another had diabetes, depression, anxiety, seizures, chronic lung disease, and dialysis dependence; and a third had colon cancer, psychotic disorder, epilepsy, depression, and dementia. Although care plans directed staff to record behaviors, interventions, and responses, records showed missing or incomplete documentation of behaviors, interventions, and the residents’ responses.
Staff were not trained or in-serviced on trauma, trauma-informed care, PTSD, or trauma assessments, despite the facility’s policy requiring all staff to receive education on these topics and nursing staff to be trained on screening tools and identifying triggers. The in-service schedule showed no trauma-related training, employee files for sampled CNAs, an LVN, and RNs had no documentation of such training, and the SSD, DSD, and DON all stated that these topics had not been part of routine training or onboarding.
Staff were not consistently informed of PTSD triggers for two residents with PTSD. One resident’s care plan identified being touched by male personnel as a trigger, and another resident’s care plan identified loud noises and yelling; however, CNAs stated they were not made aware of these triggers unless the residents told them directly. Interviews with the resident, CNAs, RNS, and DON confirmed that staff awareness of PTSD triggers was lacking despite the residents having intact cognition and requiring maximal assistance with ADLs.
Failure to assess and care plan PTSD-related behaviors: A resident receiving prazosin for chronic PTSD with night terrors had no PTSD, trauma, nightmare, or medication-related focus in the care plan, and the MDS and EHR did not reflect the diagnosis. Staff documented crying, yelling, pushing, grabbing, and calling out, but the MAR lacked behavior monitoring and staff interviews showed they were unaware of the PTSD diagnosis, triggers, or any non-pharmacological interventions.
Failure to Ensure Staff Competency for Behavioral Health Needs: The facility identified residents with Level II PASRRs, intellectual disabilities, dementia, and behavioral symptoms, but did not provide requested staff competency assessments or a competency policy. Although its education calendar listed topics such as Dementia and Behavior Management and Caring for Residents with Mental/Psychosocial Disorders, the facility could not produce documentation showing the education was provided as scheduled. Staff interviews showed limited, inconsistent training on managing aggressive behaviors and psychiatric conditions, with some staff relying mainly on experience or sending residents to the ER when behaviors escalated.
Inadequate 1:1 Staffing Assignment: A resident with significant behavioral health diagnoses, including suicidal ideations, was placed on facility-issued 1:1 supervision, but staffing records and staff interviews showed the assigned CNA was also pulled to work another hall. The CNA was away from the resident’s room for a period of time, and the schedule did not clearly identify the resident for the 1:1 assignment, resulting in inadequate staffing to meet the resident’s behavioral safety needs.
Failure to Document Behavioral Interventions and Resident Responses
Penalty
Summary
The facility failed to ensure that behavioral interventions and residents’ responses to those interventions were documented for three residents with behavioral health needs. Resident #102 was described as alert with confusion and dependent on staff for ADLs, with diagnoses including stroke with right-sided hemiplegia and hemiparesis, anxiety, adjustment disorder, major depression, mild intellectual disabilities, and Asperger’s syndrome with behaviors. Although the behavioral care plan directed staff to document behaviors and the resident’s response to interventions, review of the POC Response History and daily behavior task charting showed only one behavior entry and no documentation of interventions used or the resident’s response. Resident #103 was alert and his own person, dependent on staff for ADLs, and had diagnoses including diabetes, major depression, adjustment disorder with anxiety, seizures, abusive language, chronic lung disease, and dependence on renal dialysis. The behavioral care plan directed staff to document behaviors and responses to interventions, but the POC Response History contained no documentation of behaviors, interventions, or resident response, even though nursing notes documented a behavior on 6/12/26. Resident #104, who had a guardian and diagnoses including colon cancer, psychotic disorder, anxiety, epilepsy, depression, and dementia, had a behavioral care plan directing staff to attempt non-pharmacologic interventions and document behaviors and responses. The behavior sheet showed behaviors and interventions were documented, but there was no documentation of the resident’s response to interventions.
Staff Not Trained on Trauma-Informed Care
Penalty
Summary
The facility failed to implement its Trauma Informed Care policy by not ensuring staff received training or in-services on trauma, trauma-informed care, PTSD, or trauma assessments. A review of the 2026 in-service schedule did not show any trauma-related education scheduled for staff, and employee files for five sampled staff members, including CNAs, an LVN, and RNs, did not contain records of training on these topics. During interviews, the LVN stated she had not received trauma-related training or in-services. The SSD stated that she or the SSA were primarily responsible for completing the Brief Trauma Questionnaire and that, to her knowledge, no other staff were trained to complete the questionnaire or assess residents for trauma and triggers. The DSD stated that trauma-informed care or PTSD in-services had not been conducted and had never been on the training calendar, and the DON stated that trauma-related in-services were not provided and were not part of routine onboarding or ongoing training. The facility policy stated that all staff were to receive in-service training about trauma, its impact on health, and PTSD, and that nursing staff were to be trained on screening tools, trauma assessments, and identifying triggers associated with re-traumatization.
Failure to Inform Staff of PTSD Triggers
Penalty
Summary
The facility failed to ensure staff were informed of and provided individualized, trauma-informed care for residents with PTSD. Two of three residents reviewed for PTSD, Residents 28 and 66, had care plans identifying specific triggers, but staff interviews showed that CNAs were not consistently aware of those triggers. Resident 28’s care plan identified being touched by male personnel as a trigger, and Resident 66’s care plan identified loud noises and yelling as triggers. Both residents had diagnoses including PTSD, and both MDS assessments indicated intact cognition and maximal assistance with ADLs. During interviews, Resident 66 stated his PTSD triggers included loud noises and fighting people. CNA 4 stated she had not been made aware of which residents had PTSD or their triggers unless residents told her themselves, and she knew Resident 66’s triggers only because he informed her. CNA 3 stated she had not been aware that Resident 28 had PTSD or what his triggers were. RNS 1 and the DON stated staff needed to know which residents had PTSD and their triggers so they would not trigger the residents and so the residents would feel safe and comfortable. The facility policy stated residents with trauma and/or PTSD would receive appropriate person-centered and individualized treatment and services to meet assessed needs.
Failure to Assess and Care Plan PTSD-Related Behaviors
Penalty
Summary
The facility failed to address a resident’s PTSD-related needs in the assessment and care planning process. Admission paperwork scanned into the facility documented that the resident took prazosin 1 mg at bedtime for chronic PTSD with trauma-related nightmares, but the admission care plan did not include focus areas, goals, or interventions for PTSD, nightmares, trauma, or prazosin. The MDS dated 3/08/2026 documented severe cognitive impairment, diagnoses of non-Alzheimer’s dementia, anxiety disorder, and depression, and did not check the PTSD box. A later provider visit note did not include PTSD in the past medical history, and the resident’s EHR did not contain a PTSD diagnosis until staff later located it on the admission orders. Behavior monitoring and symptom documentation were also incomplete. The EHR task section included monitoring behavior symptoms, and the 30-day look back documented episodes of crying, yelling, pushing, grabbing, and yelling/screaming, but the MAR for May 2026 did not include behavior monitoring even though it documented prazosin administration for chronic PTSD with night terrors. During observations, the resident was heard calling out, humming, and yelling in bed. Staff interviews showed they knew the resident sometimes yelled or screamed and called out, but they did not know the cause, were not aware of the PTSD diagnosis or nightmares/night terrors, and could not identify triggers or find documentation of a plan for non-pharmacological interventions.
Failure to Ensure Staff Competency for Behavioral Health Needs
Penalty
Summary
The facility failed to ensure staff had the basic competencies and skill sets needed to meet residents’ behavioral health needs, despite identifying in its Facility Assessment that it cared for residents with dementia, mental health conditions, trauma history, Level II PASRRs, and intellectual disabilities. The assessment stated the facility provided assistance with behavioral symptoms for 28 residents and described staffing and training expectations that included orientation, ongoing education, and competencies for all staff. However, surveyors found the facility did not provide the requested staff competency assessments, and the facility did not produce a Staff Competency Assessment policy during the survey. The facility also failed to provide the education it had identified in its own assessment as necessary for staff competency. The 2026 education calendar listed monthly topics including Dementia and Behavior Management, Caring for Residents with Mental/Psychosocial Disorders, Person Centered Care, and other resident-care subjects. When surveyors requested the 2025 Education Calendar, attendance records for the March 2026 education program, the competency policy, the outline of the March 2026 material, and the credentials of the speaker, the facility did not provide the 2025 calendar, attendance records, or the competency policy. The facility provided an outline for Resident Rights presented by the Long-Term Care Ombudsman, but did not provide documentation for the scheduled Dementia and Behavior Management education. It also provided a documentation training sign-in sheet and an undated LTC staff training handout on Schizophrenia and Bipolar Disorders, but there was no validation of when the information was presented, who provided it, or copies of completed post-education quizzes. Staff interviews reflected that education specific to managing behavioral symptoms and psychiatric conditions was limited or inconsistent. An LPN stated staff had to be reactive and flexible to keep residents safe and learned mostly from practice. Another LPN said staff were not really educated with specifics for managing resident behaviors and that the only option for aggressive and threatening behaviors was often to send the resident to the ER. An RN stated staff were not really educated to manage complex conditions and aggressive behaviors, and that there was not a plan to ensure staff had the knowledge needed. CNAs stated they were unsure whether behavior or psychiatric education was covered in staff meetings and could only recall general approaches such as trying a different staff member when a resident was difficult. Another RN stated the facility now had a more diverse population with younger, more mobile residents with psychiatric problems and that staff did the best they could with what they had.
Inadequate 1:1 Staffing Assignment
Penalty
Summary
The facility failed to provide adequate staffing to meet the behavioral safety needs of all residents, affecting one resident reviewed for behavior management. The resident was admitted with diagnoses including major depressive disorder, borderline personality disorder, suicidal ideations, conversion disorder, anxiety disorder, bipolar disorder, post-traumatic stress disorder, insomnia, and other medical and behavioral conditions. Her MDS assessment dated 04/29/26 indicated she was cognitively intact, and progress notes dated 04/21/26 showed she was placed on facility-issued one-on-one staff supervision on that date. As of 05/13/26, there was no documentation showing she had been removed from one-on-one supervision. Interview with a CNA confirmed that on 05/01/26 she was scheduled as one-on-one staff, but the schedule did not identify which resident she was assigned to. The CNA stated she initially went into the resident’s room, but was later pulled to work on the back of the 100 hall because staff there were needed, and about 40 to 45 minutes later a night shift nurse supervisor told her she needed to be in the resident’s room because that was where she was assigned. The CNA confirmed she was not aware of anyone being in the resident’s room during the time she was away, and the night shift nurse supervisor stated no one had been in the room. The Administrator and VPCS confirmed the CNA was listed as one-on-one on the schedule while also assigned to the back of the 100 hall, and the facility schedule for 05/01/26 showed the CNA scheduled for the back of the 100 hall with 1:1 noted next to her name.
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