Failure to Conduct Required Annual EMR Checks for Staff
Penalty
Summary
The facility failed to implement and follow written policies and procedures to prohibit and prevent abuse, specifically by not conducting required annual Employee Misconduct Registry (EMR) checks for two employees, the Van Driver and the Assistant Director of Nursing (ADON). Record reviews showed that the annual EMR checks for both employees, which were due, had not been completed. Interviews with the Administrator and HR confirmed that EMR checks are required upon hire and annually, and that the purpose of these checks is to ensure staff eligibility to work at the facility. Further review of facility policies revealed that while there was a general policy on abuse, neglect, exploitation, or mistreatment, and a background check policy, there was no specific EMR policy in place. The Administrator stated that corporate had informed him there was no EMR policy and that they followed state guidelines. HR acknowledged responsibility for ensuring EMR checks were completed and recognized that failure to do so could result in ineligible staff working at the facility, potentially placing residents at risk.