F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
E

QAPI Program Failed to Identify and Correct Multiple Care and Documentation Deficiencies

Marshall Nursing And Rehabilitation CommunityMarshall, Michigan Survey Completed on 09-08-2025

Summary

The facility failed to maintain an effective, comprehensive, data-driven QAPI program, as shown by multiple deficiencies involving discharge documentation, activity programming, wound care, advance directives, and audit accuracy. The report states that the facility policy required the QAPI plan to address data collection, monitoring, analysis of quality deficiencies, corrective actions, and evaluation of effectiveness, but the facility did not demonstrate ongoing documentation or accurate completion of its audits and related processes. For one resident who was hospitalized and readmitted after surgery for a displaced left tibia fracture, the record did not show that bed hold, transfer, or discharge notices were discussed or documented when the resident went out to the hospital. The DON stated staff were supposed to report these events, but also stated he did not know how the issue did not show up in audits and that he did not write a progress note when the resident was sent out. The resident stated he did not receive bed hold, transfer, or discharge paperwork before going to the hospital or when he returned. For another resident with dementia and multiple chronic conditions, the activity director stated she did not track or document who participated in activities, did not have an October calendar because the computer crashed, and could not provide an activity calendar or activity involvement record for the resident. The resident stated he had nothing to do and was not taken to activities. The record showed the resident had preferences for cooking, movies, music, and radio, but there was no documentation supporting participation in preferred activities or whether he was asked to participate. The report also documented wound care and audit failures for a resident with a facility-acquired stage 3 coccyx pressure ulcer. The resident was ordered repositioning every 2 to 3 hours, a low air loss mattress, and specific wound care including wound cleanser, skin prep, Medi-honey, hydrogel, collagen, and a foam border dressing. Surveyors observed that the resident was on a regular mattress, had no heel protective boots, and the wound care performed did not follow the physician’s orders because the wound was not cleaned with wound wash and Medi-honey and skin prep were not applied. Expired wound care supplies were also found mixed with non-expired supplies in the medication room. Additional deficiencies involved advance directives and bed hold audits. One resident’s DNR order lacked witness signatures and dates, yet the facility’s audit tool marked the advance directive as completed accurately. Another resident’s DNR form had incorrect witness information and missing date information, but the audit tool again marked it as accurate. A separate resident’s bed hold policy was not found in the record, and the resident was not included in the facility’s discharge and bed hold audits because the DON was not aware of the discharge. The report also noted that two hydration pass coolers were not self-draining even though the facility had alleged compliance that they were fixed, and maintenance could not provide documentation showing the coolers had been repaired or replaced.

Penalty

No penalty information released
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

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See other F0865 citations
QAPI Program Failed to Address Consent, Transfer, and Fall-Prevention Deficiencies
F
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

The facility failed to maintain an effective QAPI program to address multiple quality deficiencies before survey. Staff did not obtain informed consent for bedrails for several residents, did not properly train CNAs on safe Hoyer lift use during a transfer, and did not ensure a planned fall-prevention intervention was in place for a resident whose care plan called for a bed overlay to define the bed edges. The QAPI team was reportedly meeting regularly and tracking several improvement areas, including UTI/ABX stewardship, hand hygiene, hydration, and CNA documentation.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Committee Failed to Address Call Light Response Time Concerns
F
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

QAPI committee failed to identify and address resident call light wait time concerns, despite meeting minutes noting call lights were the #1 issue. The concern was not documented in subsequent QAPI meetings, and the administrator stated there was no documentation showing follow-up, audit results, or staff feedback related to the issue. The VPO said the facility’s QAPI process should include data analysis, root cause review, action planning, and monitoring, but the administrator acknowledged the issue had not been on her radar and staff had not been informed or asked for input.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Conduct QA Activities for Identified Facility-Wide Concerns
D
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

Failure to Conduct QA Activities for Identified Facility-Wide Concerns: The facility did not carry out QA activities to obtain feedback, use data, or analyze underlying causes for facility-wide issues affecting quality of care, quality of life, and resident safety. The QAPI policy called for a systematic, interdisciplinary, data-driven approach, but staff did not discuss resident personal funds or activities in QA. A PIP for the dementia unit noted inactivity, wandering, falls, and inconsistent participation in structured activities, yet the records lacked further evaluation of the PIP and lacked documentation of QA activities related to resident access to personal funds.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Use QAPI to Review Medication Diversion Incident
D
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

The facility failed to use its QAPI process to review a medication diversion incident involving an LPN who entered unauthorized med orders for two residents and took one medication for personal use. The event was investigated and discussed with corporate leadership, but it was not brought to the QAPI committee to review system failures, develop corrective actions, or monitor the effectiveness of interventions.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Program Failed to Correct Prior Deficiencies
E
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

QAPI Program Failed to Correct Prior Deficiencies: The facility's QAPI program did not correct previously cited deficiencies after prior survey findings and plans of correction were reviewed. The POC for food safety issues included staff education, removal of items stored on the floor, and ongoing monitoring of dietary practices, but the DON later confirmed the facility failed to correct the quality deficiencies and did not ensure plans to improve care and services effectively addressed the identified concerns.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Program Failed to Correct Repeat Deficiencies
E
F0865 F865: Have a plan that describes the process for conducting QAPI and QAA activities.
Short Summary

QAPI failed to correct 3 repeat areas of concern identified on the current recertification survey that matched prior complaint and recertification citations: Infection Prevention and Control, Reporting of Alleged Violations, and Investigate/Prevent/Correct Alleged Violation. The facility's QAPI policy required data review, root cause analysis, system improvement, benchmarks, and communication of QAPI activities, and the Administrator acknowledged the repeat concerns and stated the QAPI committee needed more extensive audits to address them.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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