QAPI Committee Lacks Documentation and Required Review Processes
Summary
The Quality Assurance and Performance Improvement (QAPI) committee failed to meet several regulatory requirements over four reviewed quarters. Meeting minutes from multiple dates showed that the committee did not document attendance, making it impossible to confirm if required members, such as the DON, medical director, infection preventionist (IP), and administrator, were present. The minutes only included a typed list of members without specifying who attended or was absent. Additionally, there was no evidence that the committee received or reviewed regular reports from the IP regarding infection control activities, process and outcome surveillance, outbreaks, staff illness, or the Antibiotic Stewardship Program (ASP). The QAPI director confirmed that while the IP sometimes gave verbal updates, these were not documented, and there was no record of discussion, goals, or plans for improvement. Furthermore, the committee did not document the review of State Agency (SA) or incident reports, as required by facility policy. Interviews with the QAPI director, administrator, and DON revealed uncertainty about whether these reports were discussed with the medical director and confirmed the absence of documentation regarding their review. The facility's QAPI policy mandates maintaining documentation to confirm compliance with CMS requirements, including the composition of the committee and the review of relevant reports, but these requirements were not met during the period reviewed.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
The facility failed to ensure QAPI meetings were held quarterly. Requested meeting minutes were not fully provided, and the DON stated the January meeting was not held, a planned reschedule did not occur, and fall meeting notes could not be opened or were never resent. The QAPI Plan stated concerns, updates, or changes are to be reviewed at quarterly meetings.
Medical Director Did Not Participate in Quarterly QAA Meetings: The facility failed to ensure the Medical Director took part in quarterly QAA meetings. Record review showed no documentation of the Medical Director attending any QAA program meetings over several months, and both the Administrator and the previous Medical Director confirmed the absence of attendance.
The facility did not maintain a QAA committee with the required members. The policy required the DON, Medical Director, Administrator, at least two other staff members, and the infection control and prevention officer, but the QA/QAPI attendance sheets did not include an IPC at two quarterly meetings. The NHA acknowledged that the IPC does not always attend and should attend the meetings, and the DON stated she was not certified in infection prevention and control.
QAPI committee attendance records showed the facility did not hold a meeting during the first quarter and that the Infection Preventionist did not attend the documented meeting. The NHA confirmed the findings during interview.
Failure to hold required QAA meetings. Review of QAA attendance records showed only one committee meeting in one quarter and one meeting in a later quarter, and the NHA confirmed the facility did not conduct QAA meetings at least quarterly with all required committee members.
QAPI Committee Lacked Required IP Attendance: The facility failed to document that the Infection Preventionist attended QAPI meetings on a quarterly basis. Policies identified infection prevention as part of the QAPI process, but attendance records showed no documented evidence that the IP was present at the meetings, and the Administrator and Regional Administrator stated they knew the requirement but did not know why the IP had not attended.
Failure to Hold Quarterly QAPI Meetings
Penalty
Summary
The facility failed to ensure that QAPI meetings were held on a quarterly basis. Record review and interview showed that the last three QAPI meeting minutes were requested by email, but only the April 6 meeting minutes were provided initially. The remaining two sets of minutes were requested again on multiple occasions, but were not provided. On interview, the DON stated the facility had not conducted its QAPI meeting in January, had planned to reschedule it, but was unable to do so. The DON also stated the facility had met in the fall, but the notes could not be opened, and despite being given the opportunity to resend them or provide them in another format, the document was never provided. The facility's QAPI Plan, last updated 6/19/2024, stated that QAPI concerns, updates, or changes are to be reviewed and discussed at quarterly meetings.
Medical Director Did Not Participate in Quarterly QAA Meetings
Penalty
Summary
The facility failed to ensure the Medical Director participated in the Quality Assessment and Assurance (QAA) process quarterly meetings. Review of the Monthly and Quarterly QAA records showed no documented evidence that the Medical Director attended any QAA program meetings from 12/2025 through 05/2026. During interview, the Administrator confirmed the previous Medical Director had not attended any QAA program meetings during that period and stated she should have. In a separate telephone interview, the previous Medical Director also confirmed she had not attended any quarterly QAA meetings from 12/2025 to 05/2026.
QAA Committee Missing Required IPC Member
Penalty
Summary
The facility did not maintain a quality assessment and assurance committee with the required members, including the infection control and prevention officer, as outlined in its policy. Record review showed the facility's Quality Assurance/Assessment and Performance Improvement Plan required the QAA Committee to include the Director of Nursing Services, the Medical Director, the Administrator, at least two other staff members, and the infection control and prevention officer. During the entrance conference, the DON identified IPC T as the facility's infection prevention and control nurse, but the QA committee attendance sign-in sheets dated 10/24/25 and 4/24/26 did not include an IPC. The DON stated she was not certified in infection prevention and control, and the NHA stated the Medical Director, NHA, pharmacist, and DON were the required QAPI members, while also acknowledging that IPC T does not always attend and should attend the meetings.
QAPI Committee Failed to Meet Quarterly and Lacked Required Member
Penalty
Summary
The facility failed to ensure the QAPI committee met at least quarterly and included the required minimum members, specifically the Infection Preventionist. Review of QAPI meeting attendance records dated August 26, 2025, through April 30, 2026, showed that no meeting was held during the first quarter of 2026, with meetings documented on December 30, 2025, and again on April 30, 2026. The April 30, 2026 attendance record also showed that the Infection Preventionist did not attend the meeting. The Nursing Home Administrator confirmed these findings during interview on May 21, 2026, at 11:03 AM.
Failure to Hold Required QAA Meetings
Penalty
Summary
The facility failed to conduct Quality Assessment and Assurance (QAA) meetings at least quarterly and failed to include all required committee members. Review of QAA Committee meeting sign-in sheets showed only one meeting in August 2025 and one meeting in April 2026. During an interview on 5/21/26 at 1:09 p.m., the Nursing Home Administrator confirmed that the facility did not conduct QAA meetings at least quarterly with all required committee members as required.
QAPI Committee Lacked Documented Infection Preventionist Attendance
Penalty
Summary
The facility failed to maintain a Quality Assessment and Assurance Committee with the required members and to document that the Infection Preventionist attended the Quality Assurance and Performance Improvement meetings on a regular quarterly basis. The report states that the committee was required to include, at a minimum, the DON, the Medical Director or designee, at least three other staff members, one in a leadership role, and the Infection Preventionist, but the facility could not provide documented evidence that the Infection Preventionist was present at the QAPI meetings quarterly. The facility’s QAPI policies described a data-driven program to monitor clinical care, resident safety, regulatory compliance, and operational performance, and identified infection prevention as an area reviewed annually. The facility assessment stated that the infection prevention and control program was headed by a certified Infection Preventionist, and that infection prevention education covered hand hygiene, isolation, standard universal precautions, PPE, and environmental cleaning. Review of quarterly QAPI attendance records from 05/30/2025 to 02/25/2026 showed no documented evidence that the Infection Preventionist attended the meetings, and during interview the Regional Administrator and Administrator stated they knew the regulation and did not know why the Infection Preventionist had not attended the meetings at least quarterly.
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