Failure to Report and Investigate Suspected Financial Exploitation
Penalty
Summary
The facility failed to implement its policies and procedures for reporting a reasonable suspicion of a crime, specifically regarding the possible misappropriation of a resident's property by their conservator. A resident with encephalopathy and an appointed conservator was the subject of concern after staff noted issues with unpaid bills and suspected the conservator might be using the resident's funds for personal use. Staff discussed the issue in an interdisciplinary team (IDT) meeting, and Adult Protective Services (APS) was notified, resulting in the assignment of an APS investigator. However, there was uncertainty among staff about who was responsible for following up on the concern after the IDT meeting. Despite the facility's policy requiring immediate investigation and timely reporting of suspected exploitation to the state survey agency and other authorities, there was no evidence that the allegation was reported through the State Survey Agency reporting portal. Additionally, the facility could not provide documentation of an internal investigation into the exploitation allegation. This failure to report and investigate as required by policy and regulation constituted the deficiency.