Failure to Properly Manage and Account for Resident Trust Funds
Penalty
Summary
The facility failed to properly manage and account for residents' personal funds deposited with the nursing home, as required by regulation and facility policy. The facility did not utilize a generally acceptable accounting system for the resident trust fund, resulting in the commingling of residents' trust fund money with the facility's operational and payroll accounts. The Administrator routinely transferred resident funds from the trust fund account into the facility's operational and payroll accounts, and wrote checks for resident allowances and other disbursements from these facility accounts rather than from a dedicated trust fund account. There was no written consent from residents or their representatives to allow this commingling of funds. The facility also failed to maintain accurate and complete records for all residents whose funds were managed. For several residents, there were no individual ledger pages to track deposits, withdrawals, and balances, and in some cases, there was no signed authorization for the facility to manage personal funds. Errors were found in the accounting of at least one resident's ledger, and the combined balances in the trust fund account did not match the total of the residents' personal ledgers, with significant amounts missing from the account at the beginning of each month reviewed. The Administrator acknowledged that only two residents had ledgers maintained, and that checks for allowances were written from the operational account without documentation of the disposition of funds for other residents. Additionally, the facility did not issue required quarterly statements to residents or their representatives regarding the status of their trust fund accounts. Interviews with residents and their representatives confirmed that they did not receive any statements or documentation about their funds. The Administrator admitted to not being familiar with the federal regulations governing resident trust funds and confirmed that no quarterly statements were provided. The Director of Nursing and Assistant Director of Nursing stated they had no role or access to the resident ledgers or bank accounts.