Controlled Medication Accountability and Narcotic Reconciliation Failures
Summary
Pharmaceutical services were not provided in a way that ensured controlled medications in the Emergency Kit (E-Kit) were routinely accounted for. During observation of the medication room, a secured container in the medication refrigerator contained an E-Kit with a broken numbered plastic tag, a list of contents on the outside, and insulin pens inside. A second secured container in the same refrigerator held three ABH topical dispensers for residents 11 and 77 and an unlabeled unopened bottle of liquid Ativan in its original box. The medical records/CMA stated the Ativan bottle was part of the E-Kit but was too large to fit inside it, and the DON stated there was no process for regularly monitoring the tag number or accounting for the contents of that bottle. The DON also stated there was no process for accounting for the Ativan bottle and that diversion would be difficult to identify if it were removed or accessed. Narcotic administration and reconciliation were not accurately documented for resident 31. On one oxycodone reconciliation sheet, the record showed tablets remaining after administrations on several dates, but one line was missing the date, time, dose, and signature, and another line showed oxycodone removed for administration without a documented dose or signature. The resident’s MAR did not show oxycodone administered on that date, yet the nurse later stated she had given two oxycodone tablets and failed to document them on the MAR. The DON stated the accountability error had been brought to her attention by the pharmacy provider, but there was no documentation in the EMR, MAR, or reconciliation sheet explaining the discrepancy. A second oxycodone reconciliation sheet for resident 31 also contained an unexplained discrepancy at discharge, showing 24 tablets should have remained while 23 tablets were released to the resident or responsible party. The DON could not explain the difference. In addition, resident 98’s diphenoxylate-atropine reconciliation sheet showed two tablets removed for administration, but the quantity remaining was altered from 16 to 15 without explanation. The MAR showed one dose was administered, one was refused, one was held due to illness, and one was refused, and there was no documentation that the two tablets that were not administered were destroyed or otherwise accounted for. The facility policies reviewed stated that emergency kit contents were to be maintained in a designated locked area, medication administration was to be recorded immediately after giving the dose, unused controlled medication was to be documented on the accountability record, and controlled drugs were to be reconciled at final disposition.
Penalty
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