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

Failure to Maintain Effective QAPI Program for Sexual Abuse Prevention

Orchard Health And RehabilitationPulaski, Georgia Survey Completed on 04-03-2025

Summary

Facility staff failed to maintain an effective Quality Assurance/Performance Improvement (QAPI) program, specifically regarding the Performance Improvement Plan (PIP) for sexual abuse. The QAPI committee did not identify or prioritize problems and opportunities based on performance indicator data, resident and staff input, or other relevant information. Despite multiple allegations of sexual abuse, including a significant incident where one resident sexually abused another in her room, the QAPI team did not implement any changes in procedures or action plans to address these issues. Meeting minutes from several months showed that abuse allegations were discussed, but no procedural changes were made. The facility's PIP documentation for incidents of inappropriate touching and abuse lacked essential elements such as baseline data and identification of barriers, and did not specify which residents were involved. The PIP was marked as ongoing, but no further information or updates were provided to the survey team. The QAPI process, as outlined in the facility's own policy, was not followed, and the committee failed to conduct root cause analyses or implement systematic actions to address the recurring abuse allegations. Interviews with facility leadership confirmed that after months of abuse allegations, the only action taken was to instruct nursing staff to report incidents to the DON and Administrator, with no changes to existing procedures. Staff were required to discuss incidents with leadership before reporting, and no new processes or interventions were introduced following the sexual abuse incident. The facility's approach to handling sexual abuse remained unchanged, limited to notifying authorities and family, without any proactive measures to prevent recurrence or address systemic issues.

Removal Plan

  • The QAPI committee reviewed reportable adverse events to determine if any trends were identified, noted that some behaviors were a result of GDRs, and established a communication tool to provide to the behavioral health provider upon entrance and to schedule an exit meeting after the visit to include review of GDRs.
  • An ad hoc meeting was held by the Director of Quality and Regulatory to review F-835, F-867, F-740, and F-600, and a performance improvement plan was developed.
  • The policy for abuse education was reviewed to include response to sexual abuse and non-pharmacological interventions to manage behaviors.
  • Patient interviews were completed by social service director to interview residents to ensure they feel safe and associate interviews to ensure they know process for reporting and can identify abuse to include sexual and physical aggression. Audit will continue until IJ removed.
  • QAPI education was provided to include trending RCA to analyze resources needed to decrease or prevent reoccurrence.
  • A communication tool was developed and implemented by DON to improve the communication between the behavior provider and center to provide notification of any recommendations timely. The behavior provider will meet with the DON, ADON, and/or nurse supervisor upon entrance and exit to make aware of any new recommendation and to receive report of new adverse events.
  • Nurse Managers will update the patient care plan with any non-pharmacological interventions to the patient care plan.
  • An audit tool was developed by DON to review patients with inappropriate behaviors to ensure they have non-pharmacological interventions noted on care plan. Audit will continue until IJ removed.
  • Education of this process has been provided to the nurse leadership and behavior provider by the DON.
  • Any noncompliance will be brought back through QAPI process and addressed through the PDSA framework to identify RCA through the QAPI committee.
  • A daily review for oversight will be completed by the Divisional President and/or Senior Director of Clinical Standards to ensure that audits were completed for F600, F867, and F740, ensuring that patients were safe and that staff understood the education on non-pharmacological interventions for inappropriate sexual/physical behavior, and QAPI review completed as indicated on reportable for trends.
  • Any noncompliance noted will be addressed through written education by the Divisional President.

Penalty

Inspection fine: $57,161
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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
QAPI Committee Failed to Correct Repeat 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

The facility QAPI committee failed to correct repeated quality deficiencies and did not ensure that plans to improve care and services effectively addressed them. A prior survey had cited the facility and included QAPI-related plans of correction, but the current survey found multiple repeat deficiencies, including F604, F609, F628, F700, F880, F883, and PA1020. The NHA confirmed the facility had multiple repeat deficiencies and had not corrected the quality issues.

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 PIP for Pressure Ulcers Lacked Documented Interventions and Analysis
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 minutes showed an ongoing PIP for pressure ulcers, but the facility did not document clear interventions, data analysis, or a plan showing how it would reach its stated goals. The minutes contained inconsistent pressure ulcer entries, blank or incomplete PIP sections, and separate short-stay and long-stay references without explanation. The DON confirmed the facility had no documented analysis of the PIP and no laid-out plan for how the project would be carried out.

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 Failed to Resolve Repeated Medication, Food Service, and Kitchen Compliance 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

The facility’s QAPI committee failed to resolve repeated deficiencies involving medication storage and labeling, food served at improper temperatures and not palatable, and staff not wearing hair coverings in the kitchen. Prior POCs called for audits and reporting to QAPI, but surveyors again cited the same issues under F761, F804, and F812 on the current survey.

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 Correct 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

A facility’s QAPI committee failed to correct recurring deficiencies involving a clean, homelike environment, pressure ulcer prevention, drug regimen reviews, safe food storage/preparation/service, and infection control. Prior plans of correction relied on audits and reporting to QAPI, but the same deficient practices were again cited in the current survey under F584, F686, F756, F812, and F880.

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 Address Ongoing Rodent Infestation in QAPI
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

Failure to Address Ongoing Rodent Infestation in QAPI: The facility did not use its QAPI process to address a known rodent problem. Rodent feces and traps were observed in resident rooms, dining and food areas, clean dish and linen areas, and other parts of the building. Interviews confirmed the infestation was ongoing, recommended structural repairs had not been made, the issue was not discussed in the QAPI meeting, and no education had been provided to residents or staff.

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 Track and Monitor Shower Room Deficiency
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 failed to track and monitor a black debris issue in the 300-hall shower room. An observation found black debris in the shower’s inner bottom corners, and records showed the QAPI plan only listed environmental rounds monitored by the Administrator and Maintenance without further comments. The Maintenance Supervisor said he knew about the issue, had cleaned it, but did not document weekly rounds or findings, and the Administrator also said he did not document the weekly 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.
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