Inaccurate controlled substance documentation and backdated entries
Summary
The facility failed to ensure accuracy of medical records for four sampled residents when controlled substance documentation did not match between the controlled drug records (CDR), medication administration records (MAR), and progress notes. For Resident 24, who was admitted with schizoaffective disorder and anxiety disorders, a physician order for lorazepam 2 mg as needed was created on 8/5/25 with a start date of 8/1/25, resulting in a four-day backdate. The Assistant Director of Nursing stated she received a verbal order on 8/1/25 and could not recall why the order was not entered right away. The Consultant Pharmacist stated controlled drugs such as lorazepam could not be renewed or reordered verbally unless written and signed by the physician, and only a pharmacist may receive verbal orders for controlled drugs from the physician in emergency situations. Resident 24’s CDR showed eight doses of lorazepam signed out between 7/18/25 and 8/2/25 that were not documented on the MAR. Progress notes for those doses were created later, with effective dates matching the administrations but creation dates ranging from 4 to 18 days later. Similar discrepancies were found for Resident 121, who had schizoaffective disorder and a lorazepam order; three doses were signed out on the CDR but not documented on the MAR, and corresponding progress notes were created 4 to 9 days later. Resident 29, who had polyneuropathy and chronic pain, had two oxycodone doses signed out on the CDR without MAR documentation, and progress notes for those doses were created two days later. Resident 69, who had a right clavicle fracture, had two Roxicodone doses signed out on the CDR without MAR documentation, and progress notes were created 3 to 4 days later. The Consultant Pharmacist stated that when a controlled substance is pulled out, nursing staff are expected to document on both the CDR and MAR, and that failure to match the records would be considered a discrepancy. The Medical Record Directors stated the CDR should reflect the MAR, documentation should be completed as soon as medication is given, and the resident’s chart should contain complete and accurate documentation. Facility policies stated controlled substance prescriptions must be valid and complete, controlled substances must be reconciled through records including MARs, and medication administration must be recorded immediately following administration. The report also stated that inaccurate recording of controlled substances had the potential for abuse and drug diversion.
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