Unapproved Training Program Used for Paid Feeding Assistants
Summary
The facility failed to ensure that individuals utilized as paid feeding assistants completed a State-approved training program, as required. During meal observations, Activities Assistants were seen assisting residents with feeding in the dining rooms of two units. Although the Director of Nursing (DON) stated that all Activities Staff had been trained to feed residents, it was later revealed that the training program used by the facility had not been submitted to the State of Massachusetts for approval. The DON was unsure if the program met state requirements and confirmed that an application for approval was only being completed after the surveyor's inquiry. Further interviews indicated that Activities Staff were assigned to assist with feeding by CNAs or nurses, and were instructed not to assist residents with swallowing difficulties. The Activities Director confirmed that all Activities Staff, including herself, had completed the facility's paid feeding assistant training, but could not confirm if a licensed nurse was always present during meals, only that a CNA was always available. The deficiency centers on the use of unapproved training for paid feeding assistants and the lack of assurance that state requirements for such training and supervision were met.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
The facility did not provide required annual in‑service training and skills evaluations for two of four paid feeding assistants. Records showed that the Director of Rehabilitation and another feeding assistant each completed a state‑approved Feeding Assistant Program with skills review, but there was no documentation of any annual refresher training or competency review afterward. One feeding assistant confirmed there had been no additional training, and HR reported being unaware of the annual training and skills review requirement, while the NHA stated an expectation that such refresher training would occur per state regulations.
The facility did not maintain required documentation showing that all paid feeding assistants had successfully completed a State-approved training course. Review of facility records showed 12 staff functioning as paid feeding assistants and 9 residents approved for the paid feeding assistant program, but the DON reported that documentation of completed training could only be found for 6 staff. The DON stated that a Life Enrichment Coordinator and several Dining Room Assistants had completed the training and assisted with feeding, yet the facility was unable to locate records verifying their training completion.
A facility failed to train a non-licensed employee, Activities Aide B, with the State-approved course for feeding assistance. During a breakfast observation, the aide was seen feeding a resident requiring a mechanical soft diet, despite not being certified or trained. The DON confirmed only CNAs should provide such assistance, and the facility lacked paid feeding assistants. The aide's file showed no certification or training, and the job description did not include feeding duties, increasing the risk of feeding complications.
The facility did not provide state-approved training for paid feeding assistants, impacting 18 residents. Five feeding assistants lacked formal training, receiving only one-on-one instruction from the DON and staff. The DON was unaware of the state training requirement, leading to non-compliance.
The facility failed to provide State-approved training for a Certified Dietary Manager (CDM) who was observed feeding a resident a pureed diet without proper training. The CDM had only received a refresher from the DON years ago, and the facility lacked comprehensive documentation and policies for feeding assistance. This deficiency put residents at risk of complications such as choking.
A resident with severe cognitive impairment was assisted with eating by another resident's wife, who was not a certified paid feeding assistant. This was against the facility's policy, which requires only staff to assist residents with meals. The Director of Nursing confirmed that family members or visitors should not assist non-family member residents.
Failure to Provide Required Annual Training and Skills Review for Feeding Assistants
Penalty
Summary
The facility failed to ensure that its Feeding Assistant Program included required annual training and skills review for two of four paid feeding assistants reviewed. Wisconsin state requirements for feeding assistants, aligned with 42 CFR 483.60(h), specify that feeding assistants must receive an annual in‑service on relevant feeding topics and must be evaluated yearly to document satisfactory skill performance and feeding competence. Surveyor review of the Director of Rehabilitation’s (DOR K) Feeding Assistant Training Program documents showed that DOR K completed the state‑approved program, including training and skills review, on 4/17/24, but there was no documentation of any annual training or skills evaluation after that date. Similarly, review of feeding assistant records for staff member [NAME] V showed successful completion of the state‑approved Feeding Assistant Program, including training and skills review, on 4/17/24, with no subsequent annual training or skills monitoring documented. During an interview, [NAME] V confirmed that there had been no additional training after completion of the initial Feeding Assistant Program. In a separate interview, the Human Resources representative (HR W) stated that no additional training had been provided to feeding assistants and acknowledged being unaware of the requirement for annual training and skills review. The Nursing Home Administrator (NHA A) stated that she would have expected refresher training to be completed in accordance with state regulations.
Missing Documentation of State-Approved Training for Paid Feeding Assistants
Penalty
Summary
The facility failed to maintain records of successful completion of a State-approved paid feeding assistant training course for 6 of 12 staff members functioning as paid feeding assistants. Surveyors reviewed facility lists showing 12 staff designated as paid feeding assistants and 9 residents approved for the paid feeding assistant program. During an interview, the DON stated the facility could only locate documentation of completed State-approved training for 6 of the 12 paid feeding assistants. The DON identified specific staff, including the Life Enrichment Coordinator and multiple Dining Room Assistants, who had reportedly completed the paid feeding assistant training and had assisted residents with feeding, but the facility was unable to locate documentation verifying that these individuals had completed the required training. No additional clinical details or medical histories of the 9 residents approved for the paid feeding assistant program were provided in the report, and the deficiency centers on the absence of required training documentation for staff who assisted with feeding.
Untrained Staff Providing Feeding Assistance
Penalty
Summary
The facility failed to ensure that a non-licensed employee, Activities Aide B, received the State-approved training course for feeding assistance to residents. During a breakfast observation, Activities Aide B was seen feeding a resident who required assistance with a level 3 advanced mechanical soft diet. When questioned, Activities Aide B stated that she was providing assistance because other staff were unavailable. The Director of Nursing confirmed that only Certified Nurse Aides are allowed to provide feeding assistance, and the Nursing Home Administrator verified that the facility does not employ any paid feeding assistants. A review of Activities Aide B's employee file revealed that she was not certified and had not completed the required State-approved training course for feeding assistance. This training includes essential skills such as feeding techniques, communication, safety procedures, and recognizing changes in residents' behavior. Additionally, the facility's job description for the Activity Aide position did not include feeding assistance as part of the essential functions and responsibilities. This oversight resulted in an increased risk of feeding complications for the residents requiring assistance during mealtimes.
Lack of State-Approved Training for Feeding Assistants
Penalty
Summary
The facility failed to provide state-approved training for paid feeding assistants, affecting 18 residents out of a census of 78. A review of the facility's list of paid feeding assistants revealed that five individuals had not completed the required formal training. During interviews, a nurse aide admitted to not attending a state-approved course, instead receiving one-on-one training from the Director of Nursing (DON) and experienced staff. The DON confirmed that each feeding assistant underwent one-on-one training on specific topics but was unaware of the requirement for state-approved training courses, indicating a lack of compliance with regulatory standards.
Failure to Provide State-Approved Training for Feeding Assistants
Penalty
Summary
The facility failed to ensure that non-licensed employees, specifically a Certified Dietary Manager (CDM), received the State-approved training course for feeding assistance to residents. During a breakfast observation, the CDM was seen feeding a resident a pureed diet without having completed the required training. The CDM admitted to receiving only a refresher from the Director of Nursing (DON) several years ago, rather than the comprehensive State-approved training. The DON confirmed that the CDM had not taken the official training course and was unaware of its requirements, indicating a lack of proper training for staff involved in feeding residents. The deficiency was further highlighted by the facility's inadequate documentation and policies regarding feeding assistance. The facility provided a brief and undated procedure for feeding residents a pureed diet, which lacked comprehensive guidelines. Additionally, a policy allowed the DON to train kitchen staff on feeding procedures, but it was also undated and lacked detail. This lack of formal training and documentation put residents, particularly those on pureed diets, at risk of complications such as choking, as acknowledged by the CDM during the observation.
Uncertified Individual Assisted Resident with Eating
Penalty
Summary
The facility failed to ensure that a person assisting a resident with eating was a certified paid feeding assistant. This deficiency was identified for one resident out of fifteen reviewed, with the facility having a total census of 42 residents. The resident in question had a severe cognitive impairment, as indicated by a Brief Interview for Mental Status score of 99, which showed the resident was unable to complete the interview. During an observation in the dining room, the resident was assisted with eating by another resident's wife, which was against the facility's policy. The facility's policy, revised in March 2022, stated that only facility staff should serve resident trays and assist residents who require help with eating. The Director of Nursing confirmed that the expectation was for family members or visitors not to assist non-family member residents with dining.
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