Failure to Use QAPI to Address Infection Control and Staffing During Influenza Outbreak
Summary
The facility failed to utilize its Quality Assurance and Performance Improvement (QAPI) program to identify, analyze, and correct systemic failures in infection prevention and control, as well as staffing, during an influenza outbreak affecting all 59 residents. The outbreak occurred over several days, during which the facility did not recognize the outbreak, did not initiate droplet precautions, failed to notify the local health department, and did not ensure that antiviral medications were administered as prescribed. There was also a lack of monitoring for staff illness and compliance with infection control measures, resulting in continued exposure and spread of influenza within the facility. Staff interviews and record reviews revealed that the QAPI Committee did not meet during or after the outbreak, and the incident was not discussed in any quality review process. The Medical Director was not fully informed about the number of affected residents, the implementation of infection control measures, or staffing shortages. The Infection Preventionist was not aware of the specific infection control measures implemented, did not maintain illness logs, and was unfamiliar with the facility's infection control policies. The Administrator and DON did not consider the outbreak an emergency, did not update the facility assessment or contingency plan, and did not verify the implementation of appropriate precautions or notification procedures. No internal investigation was conducted regarding missed medications, and the pharmacy and state agency were not notified. During the outbreak, there was insufficient licensed nurse coverage, with only one nurse responsible for 58 residents overnight, leading to missed medications and inadequate monitoring. The facility assessment lacked required details on staffing needs by shift and unit, and the contingency plan for staffing emergencies was not actionable. The Administrator and DON described the incident as isolated and made no changes to policies or procedures as a result. The QAPI process was not used to review or address the deficiencies in infection control or staffing, and no lessons were identified or learned from the incident.
Removal Plan
- The Administrator held an emergency Quality Assurance and Performance Improvement meeting with the Medical Director, Director of Nursing, Infection Preventionist, Medical Records nurse, Life Connections Coordinator, Wound Care nurse and others as part of the Interdisciplinary team to discuss findings from the State Agency, discuss immediate actions, and further interventions. Immediate actions were decided as in-servicing all staff on Abuse and Neglect, in-servicing nurses on medication administration and medication errors, in-servicing all staff on flu outbreak and isolation precautions. The Administrator would review policy for Quality Assurance and Performance Improvement for any changes needed and as re-education in policy. The Administrator would review and update facility assessment to identify updated needs to staff per unit and the contingency plan for emergencies. Administrative nurses would complete a 100 percent audit on all medication carts compared to medication orders to ensure all medications were accessible in the building. The Infection Preventionist would be in-serviced on the roles and responsibilities of an Infection Preventionist. Policies on Abuse and Neglect, medication administration, medication errors, QAPI, flu outbreak, isolation precautions, and the expectations of the Infection Preventionist were all reviewed and updated. Staff were in-serviced with new policies.
- The Administrator notified Medical Director of missed medications during QAPI meeting. All missed medications were reviewed with Medical Director during this meeting. No new orders were given. No adverse reactions were noted due to missed medications.
- The Director of Nursing began an in-service for all staff on the policies and procedures of Abuse and Neglect. No employee was permitted to return to work until they completed the in-service.
- The Director of Nursing began an in-service on medication administration and medication errors to educate all nursing staff. This in-service included procedures for when medication cannot be located anywhere in the facility. If medication is not available, staff should contact pharmacy and pull medication from emergency kit. Any missed medications are to be reported to the Director of Nursing and Medical Director immediately, an incident report is to be completed, the resident observed for any adverse reactions, and the family/resident representative is to be notified. Any tasks left undone are to be reported to relief during report for oncoming shift. No employee was permitted to return to work until they completed the in-service.
- Administrator and Director of Nursing reviewed Flu outbreak and Isolation precautions policy and procedures. The Director of Nursing began an inservice for flu outbreak and isolation precautions to educate all staff. All staff are to continue to monitor residents and staff for flu-like symptoms and report any findings to the immediate supervisor. No employee was permitted to return to work until they completed the in-service.
- The Administrator reviewed policy on Quality Assurance and Performance Improvement plan and policy for re-education purposes and to review new policy. The Quality Assurance and Performance Improvement plan and policy was reviewed with the facility's Interdisciplinary Team including the Administrator, Medical Director, Director of Nursing, Infection Preventionist, Medical Records nurse, Life Connections Coordinator, Wound Care nurse and others in a follow up Quality Assurance and Performance Improvement meeting.
- The facility Administrator began reviewing and updating the facility assessment to reflect correct staffing and supervision by shift and by unit related to the facility's acuity level. The Facility Administrator began updating the contingency plan for staffing emergencies within the facility assessment. The contingency plan will be initiated and is as follows: Facility will utilize On-call for staffing needs and call ins. On-call will notify Director of Nursing if not able to cover. Facility will utilize Consultants and/or transfer staff from other nursing facilities within partnership to assist and cover staffing needs. The new facility assessment was reviewed with the interdisciplinary team during follow up QAPI.
- The Infection Preventionist (IP) was included in an in-service held by the Director of Nursing for policy and procedures of outbreak surveillance and staff-illness tracking during an outbreak to be completed before beginning of their next shift. Due to this outbreak being finished, IP nurse was instructed to continue to monitor residents and staff for flu-like symptoms and to report to Director of Nursing any findings.
- The Director of Nursing, Medical Records nurse, and Wound Care nurse completed a 100 percent audit to compare the current medication orders to the medication on the carts and in medication rooms to verify all medications ordered were readily available in the facility. No negative findings during audit.
- The Administrator notified the Mississippi Department of Health of the flu outbreak.
- The Administrator held a follow-up QAPI meeting to discuss all immediate actions that were in place. All in-services and audits were completed. All staff would continue to monitor any residents or staff for flu-like symptoms, staffing would be reviewed daily to ensure all areas were covered according to the facility assessment, and daily reviews of missed medications would be reviewed each morning in clinical meeting.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
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.
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.
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.
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.
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.
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.
QAPI Program Failed to Address Consent, Transfer, and Fall-Prevention Deficiencies
Penalty
Summary
The facility failed to maintain an effective quality assessment and assurance program to address quality deficiencies before survey. The report states that the facility did not obtain informed consent from residents or their legal representatives for the installation of bedrails for four residents. It also states that the facility failed to properly train staff on the use of the Hoyer total body mechanical lift for safe resident transfer, and that one resident was transferred while suspended in the air after both staff members removed their hands from the lift and the resident during the move. The report further states that the facility failed to ensure interventions were being used to prevent resident injury and falls. One resident did not have an overlay on the bed to define the edges as directed by the plan of care. Administrative staff said the QAPI team met at least quarterly and usually monthly, and that current improvement plans included UTI and antibiotic stewardship, staff engagement communication breakout sessions, room-to-room activities, handwashing, snacks and hydration, and CNA documentation. The next QAPI meeting was to include discussion and implementation of an improvement plan for accident and fall prevention.
QAPI Committee Failed to Address Call Light Response Time Concerns
Penalty
Summary
The facility’s QAPI committee failed to identify resident call light wait time concerns before survey and did not make a good faith attempt to correct the deficiency. QAPI meeting minutes dated 3/31/25 stated that call lights tended to be the #1 issue, but call light response times were not included or mentioned again in the next six QAPI meeting minutes. The deficiency had the potential to affect all 42 residents residing in the facility. During interviews, the administrator stated she assumed the QAPI committee had followed up on call light wait time concerns, completed an audit, and determined it was not an issue, but there was no documentation to support that. The vice president of operations stated the organization uses a standardized QAPI meeting format and that facilities are expected to analyze data, discuss findings, review audit results, perform root cause analyses, develop action plans, and monitor the effectiveness of interventions. The administrator later stated the long call light response times found during survey had not been on her radar and admitted there had been no staff meetings where QAPI activities were communicated to employees or where employees were asked for feedback about resident care concerns.
Failure to Conduct QA Activities for Identified Facility-Wide Concerns
Penalty
Summary
The facility failed to carry out Quality Assurance (QA) activities to obtain feedback, use data, and take action to conduct structured, systematic investigations and analysis of underlying causes or contributing factors of problems affecting facility-wide processes that impact quality of care, quality of life, and resident safety. The Quality Assurance and Performance Improvement (QAPI) policy dated April 2025 directed staff to continually assess facility performance using a systematic, interdisciplinary, comprehensive, and data-driven approach to maintain and improve safety and quality. The CMS Form 2567 dated 6/26/25 identified concerns related to residents having access to personal funds and activity provision. During record review and interviews from 7/13/26 to 7/16/26, the same concerns were identified. On 7/16/26, the Administrator stated staff did not discuss personal funds or activities in QA. A Performance Improvement Plan dated 5/26/26, sent by the Administrator on 7/17/26, identified increasing activities in the dementia unit and documented unit observations of inactivity, increased wandering behaviors, increased falls, and inconsistent participation in structured activities. The facility records lacked further evaluation of the activity PIP and lacked documentation of QA activities related to resident access to personal funds.
Failure to Use QAPI to Review Medication Diversion Incident
Penalty
Summary
The facility failed to implement its QAPI program to address a medication diversion event involving unauthorized medication orders and misappropriation of resident medications. The facility had a policy requiring an ongoing, facility-wide, data-driven QAPI program focused on indicators of outcomes of care and quality of life, but there was no documented evidence that the incident was presented to the QAPI committee for review, system failures were identified, corrective actions were developed, or the effectiveness of interventions was monitored. Through staff reporting and investigation, the facility learned that an LPN admitted to entering unauthorized medication orders into the electronic medical record under one resident's record, discontinuing those orders, and taking the medication for personal use in December 2025. The same LPN also admitted to entering another unauthorized medication order for a second resident with the intent to obtain that medication, although the medication was removed from the medication cart before it could be taken. The Administrator stated the incident was discussed with corporate leadership and that the LPN was placed on probation with weekly audits, but the matter was not brought to the QAPI Committee because of concerns regarding employee rights and personnel matters.
QAPI Program Failed to Correct Prior Deficiencies
Penalty
Summary
The facility's QAPI program failed to correct previously cited deficiencies after prior State Survey and Certification surveys and the related plans of correction were reviewed. The facility policy for QAPI, dated 1/6/26, stated that the program is a proactive, systematic approach to improving quality of care, quality of life, and services, and that the facility would take action based on findings, measure success, and track performance to ensure improvements are sustained. However, review of the facility's deficiencies and plans of correction for surveys ending 4/15/26 and 4/24/26 showed that the facility had developed quality assurance systems to maintain compliance with cited nursing home regulations, yet the deficiencies were not corrected. The plan of correction for the survey ending 4/24/26 included education for dietary staff on food handling, food safety, and food storage; immediate removal of items stored on the floor during truck delivery; education of a staff member on food safety and cross contamination; and monitoring of cooks and dietary storage by the dietary manager or designee. It also stated that education, audit, and monitoring would be reported during the next QAPI meeting. During an interview on 7/9/26 at approximately 7:00 p.m., the DON confirmed that the facility failed to correct quality deficiencies and did not ensure that plans to improve the delivery of care and services effectively addressed the identified concerns.
QAPI Program Failed to Correct Repeat Deficiencies
Penalty
Summary
The facility failed to correct its own deficiencies for 3 of 3 areas of concern identified during the current recertification survey. The concerns matched citations from the previous complaint survey and the previous recertification survey and involved Infection Prevention and Control, Reporting of Alleged Violations, and Investigate/Prevent/Correct Alleged Violation. The facility had a census of 39 residents at the time of the survey. The facility's QAPI Program policy, revised March 2020, directed the QAPI committee to collect and analyze performance indicator data, identify and monitor facility systems and processes, use root cause analysis, help departments implement systems to correct issues in quality of care, establish benchmarks and goals, coordinate performance improvement projects, and communicate QAPI activities to the Administrator and governing body. On 7/9/26 at 2:30 PM, the Administrator stated the QAPI committee reviews prior surveys and prior deficiencies to determine root cause and develop a plan to address and correct repeat deficiencies, and acknowledged the repeat concerns identified during this survey and prior surveys. The Administrator stated the QAPI committee must complete more extensive audits to address them.
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.