F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
D

Failure to Accurately Document and Implement DNR Order

Optalis Health And Rehabilitation Of TroyTroy, Michigan Survey Completed on 04-09-2025

Summary

A deficiency was identified when the facility failed to ensure consistent implementation and documentation of a Do Not Resuscitate (DNR) order for a resident with dementia and a malignant neoplasm of the prostate. The resident, who had moderate cognitive impairment as indicated by a BIMS score of 12, had a DNR order signed by both the resident and their physician. However, the electronic medical record (EMR) demographic page incorrectly listed the resident as "Full code," meaning cardiopulmonary resuscitation (CPR) would be performed in the event of cardiac arrest. During interviews, both a nurse and a social worker reviewed the resident's EMR and initially reported the resident as "Full code." It was only after further review that the social worker discovered the signed DNR order in the record and acknowledged the discrepancy. The social worker was unaware of how the error occurred and indicated the need for correction to reflect the resident's actual wishes as documented in the DNR order. Facility policy requires that a fully executed DNR form be uploaded into the resident's electronic health record and that the physician's order for DNR be entered so the code status is accurately displayed in the chart header and face sheet. In this case, despite the presence of a valid DNR order, the resident's code status was not accurately reflected in the EMR, leading to confusion among staff regarding the resident's end-of-life care preferences.

Plan Of Correction

578 Request/Refuse/Discontinue treatment; Formulate Adv Dir It is the practice of the facility to ensure the resident right to request, refuse and/or discontinue treatment, to participate in or refuse to participate in experimental research and to formulate an advance directive. Element 1 Resident 408 remains in the facility and has been unharmed by the deficient practice. The resident's code status order has been corrected to DNR (do not resuscitate). Element 2 Residents residing in the facility who have signed a DNR are at risk. An audit was completed by the DON/designee of all residents with a signed DNR to ensure their physician order and demographics page match. The plan of care has been reviewed and updated by the interdisciplinary team. Element 3 The interdisciplinary team reviewed the advanced directive policy and deemed it appropriate for use as written. The licensed nursing staff and social work staff were educated on the policy. Element 4 The administrator/designee will audit all new admits/readmits to ensure appropriate advance directives orders and documentation is in place weekly x4 and monthly x3. Element 5 The administrator/designee holds the ultimate responsibility of compliance: date of compliance May 6, 2025.

Penalty

Inspection fine: $224,315
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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 F0578 citations
Advance Directive Not Maintained in Resident Record
D
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

Advance Directive Not Maintained in Resident Record: A resident with dementia, muscle weakness, and protein-calorie malnutrition had documentation indicating an advance directive was in the chart, but record review did not locate a living will or DPOA for health care. The CNO confirmed the record did not include an advance directive and the facility did not have a living will on file.

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.
Incomplete Advance Directive Documentation
D
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

Incomplete Advance Directive Documentation: The facility failed to keep complete and accurate advance directive records for two residents. One resident's chart contained a representative-signed acknowledgement that did not specify the type of advance directive, and another resident's record had no signed acknowledgement showing that advance directives were discussed. The SSD stated she was responsible for the documentation and that one form was filled out incorrectly while the other resident's paperwork could not be found.

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.
Delayed Response to Changes in Condition and Family Requests for Hospital Evaluation
D
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

The facility failed to timely respond to changes in condition for two residents, including one with severe cognitive impairment and another with dementia, CHF, diabetes, and a history of UTIs. Family members and DPOAs reported concerns about confusion, agitation, pain, SOB, and other worsening symptoms, but hospital evaluation was delayed while staff waited for physician input. Both residents were later admitted to the hospital with serious infections and other acute conditions, including sepsis, pneumonia, and respiratory failure.

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.
Physician Orders Did Not Match POLST Code Status
E
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

A facility failed to ensure that active physician orders matched residents’ POLST code status for three residents. One resident with COPD, A-Fib, and anxiety had a POLST indicating DNR but no active code status order; another resident with dementia, hypothyroidism, and HTN had a POLST indicating DNR but a physician order for CPR; and a third resident with COPD, respiratory failure, and diabetes had a POLST indicating DNR but no active code status order. The DON confirmed the records were inconsistent and that physician orders and POLST should match.

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.
Advance Directive Not Available in Resident Record
D
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

A resident with dementia with agitation, stroke, and PE had an advanced directive noted in a care conference review, but the document could not be found in the medical record. Staff later confirmed the resident did not have an advance directive on file.

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 Offer Advance Directive Opportunity
D
F0578 F578: Honor the resident's right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.
Short Summary

Failure to offer a resident the opportunity to create an advance directive. Record review showed the resident had no advance directive on file, and the SS Director stated there was no documentation that education was provided or that any attempts were made to obtain one. The resident had HTN, CKD, and mild cognitive impairment.

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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