Failure to Remove Old Fentanyl Patch Before Applying New Patch
Summary
The facility failed to follow the physician’s order to remove an old fentanyl patch before applying a new patch for a resident with cancer, polyneuropathy due to toxic agents, COPD, and unspecified abdominal pain. The care plan directed staff to administer fentanyl as ordered, and the physician’s order summary specified that a 25 mcg fentanyl patch was to be applied every 3 days, with the old patch removed before the new one was applied and sites rotated. The EMAR showed a 25 mcg patch applied on the left arm and, three days later, another patch applied on the right arm. Clinical records and interviews showed that after the second patch was applied, the resident became confused, lethargic, and unable to answer questions. Staff A, ARNP assessed the resident and noted lethargy and confusion, with a history of urosepsis and hydronephrosis, and sent the resident to the hospital. The EMS report documented that a fentanyl patch was removed en route to the hospital, and the ED physician noted that a second fentanyl patch was removed in the ED. The hospital discharge summary stated that on 9/7 the patient was transferred to the ICU for fentanyl overdose with severe acute hepatic encephalopathy and increased ammonia levels. Interviews indicated the nurse who applied the patch stated she removed the old patch before applying the new one, but she could not identify who witnessed the disposal or where it was documented. Staff A stated she did not look to see how many fentanyl patches were on the resident, though she heard there were two. The Administrator stated the nurse should have removed the prior patch before applying the new one and acknowledged that the ED notes showed two patches were present during transport. The facility policy on medication administration required medications to be given as ordered, and the controlled substance policy addressed disposal of removed patches but did not direct removal of old patches before applying a new patch.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Trusted data from CMS and state health departments
Every citation, penalty and Plan of Correction is sourced from public CMS records (latest release October 8, 2026) and official state health department websites — never guesswork.
In your survey window? See what surveyors are citing.
The Survey-Prep Report maps your facility's risk from 12 months of CMS and state citation data — what's being cited around you and what to check first. $129 one-time.