Resident funds were commingled with facility operating funds and not properly refunded
Summary
Facility staff failed to maintain a system that assured a full, complete, and separate accounting of resident personal funds and allowed resident money to be commingled with facility operating funds for three residents. The facility policy required resident funds deposited with the facility to be held, safeguarded, managed, and accounted for as fiduciary funds, with amounts over $50 kept in separate interest-bearing accounts and not commingled with facility funds. The policy also required a full and complete separate accounting for each resident’s personal funds and timely conveyance of funds after discharge or death. For one resident, the accounts receivable aging report showed a current resident liability credit balance of $7,961.30. Transaction records showed multiple resident payments totaling that amount, and MO Healthnet Vendor Notices showed a zero dollar Medicaid surplus amount effective as of February 2024 and for subsequent months. The BOM stated the resident’s payer source had been Medicaid pending until the notices verified Medicaid approval, that the resident’s money was kept in the operating account while the BOM wanted to verify there was no surplus amount, and that the money belonged to the resident. The BOM also stated no refund had been made and there was no written authorization to hold the resident’s money in the facility operating account. For two discharged residents, the accounts receivable aging report showed private pay credit balances of $1,367.50 and $2,100. One resident’s family made a payment that created a credit balance after discharge to home, and the other resident’s lawyer sent a check to pay a statement balance, but the payment was deposited to the operating account and left a credit balance after discharge to home. The BOM stated both amounts belonged to the residents, no refund actions had been taken, and there was no written authorization to hold the money in the facility operating account. The administrator stated the BOM was responsible for resident funds and accounts receivable, should review accounts receivable at least weekly, and should contact the responsible person and refund resident funds, but the administrator did not know why the credit balances had not been refunded.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Inaccurate accounting of a resident’s personal funds occurred when the facility, acting as payee for Social Security and pension, failed to apply the correct personal allowance amount and used the resident’s full Social Security payment to cover liability instead of sending the prorated amount to the POA after the resident transferred to another facility. The account was later closed with a zero balance after a check was issued to the new facility, and the BOM and Co-Owner verified the third-party biller did not provide the correct amount of personal funds due.
Failure to Provide Quarterly Resident Trust Fund Statements: The facility did not provide quarterly trust fund statements to two residents, including one resident with intact cognition and decision-making capacity and another resident with moderate cognitive impairment and no capacity to make decisions. The BOM confirmed the facility did not follow its Resident Trust Funds policy requiring quarterly statements to residents or RP, and the RP stated they had not received account statements for about a year and did not know the resident’s account balance.
Failure to provide quarterly trust fund statements to two residents was identified. Staff stated residents should receive statements quarterly, but the NHA could not find documentation that the statements were mailed or handed out, and the two residents said they had never seen their statements.
The facility failed to ensure quarterly personal fund statements were provided to the resident or responsible party for two residents whose money was held by the business office. One resident had severe cognitive impairment and a POA daughter who said she did not receive the statement, while the other resident had no cognitive impairment but stated she did not know who received the statement. Staff reported that statements were printed and placed in an activities box for delivery, but the activities director could not recall which residents received them.
Resident funds were not properly tracked or kept separate from facility funds. Staff kept resident money in envelopes in a lock box, but an LPN said several envelopes had inaccurate accounting, missing receipts, and unclear balances. Review of multiple residents’ envelopes showed mismatched totals, missing money, undated entries, and a gift card recorded without a clear final accounting. The Administrator also acknowledged that Medicaid dollars had been comingled with business funds and that checks could not be accounted for because of errors.
Failure to provide quarterly resident trust fund statements. A cognitively intact resident with multiple chronic conditions said she never received a written statement for her personal funds account after admission and instead only received verbal balance updates when she asked the business office. Facility policy and the resident’s authorization form both required quarterly statements, but the BOM did not send statements or have documentation showing they were issued.
Inaccurate Accounting of Resident Personal Funds
Penalty
Summary
The facility failed to ensure accurate accounting of a former resident’s personal funds account. Review of the personal funds account showed the resident’s account was closed after transfer to another facility, and the facility was the payee for the resident’s Social Security and pension. The resident’s personal allowance increased from $50 to $75 on 01/01/26, but the account was still allotted a $50 allowance in January 2026. The account balance was $100.01 at the start of the year, and the resident was hospitalized until 02/03/26. In February 2026, the facility allotted the $75 allowance when a Social Security check for $2,791.00 was deposited, but the resident transferred to another facility on 02/09/26. On 02/20/26, $75.03 was withdrawn from the account, and on 03/18/26 a check for $150.06 was sent to the resident’s new facility, leaving a zero balance. The facility did not send the prorated amount of Social Security due to the new facility to the resident’s POA so she could pay the resident’s portion of the bill there. The Business Office Manager and Co-Owner verified that the third-party biller failed to provide the resident the correct amount of personal funds due and used the entire February Social Security check to pay the resident liability instead of sending the prorated amount to the POA.
Failure to Provide Quarterly Resident Trust Fund Statements
Penalty
Summary
The facility failed to provide quarterly financial statements to two sampled residents, Resident 22 and Resident 54, for the quarter period of 1/1/2026 to 3/31/2026. Resident 22 was admitted to the facility on 1/4/2020 with diagnoses including hemiplegia and hemiparesis following cerebral infarction affecting the right dominant side and gout. The MDS dated 2/23/2026 indicated Resident 22’s cognition was intact, and the H&P dated 10/10/2025 stated Resident 22 had capacity to understand and make own decisions. During an interview on 5/18/2026, Resident 22 stated the facility had not provided quarterly financial statements for several months. Resident 54 was originally admitted and later readmitted to the facility with diagnoses including sequelae following unspecified cerebrovascular disease, obstructive hydrocephalus, and presence of a cerebrospinal fluid drainage device. The MDS indicated Resident 54’s cognition was moderately impaired, and the H&P dated 4/6/2026 stated Resident 54 did not have the capacity to understand and make decisions. During a concurrent interview and record review on 5/22/2026, the Business Office Manager stated the facility did not follow its Resident Trust Funds policy by not providing quarterly statements to Resident 54 and Resident 22. The policy required quarterly statements to be provided to each resident or resident representative, dated and documented when provided, and signed as proof of receipt. Resident 54’s representative stated the facility had not provided quarterly statements for about one year and was not aware of Resident 54’s account balance.
Failure to Provide Quarterly Trust Fund Statements
Penalty
Summary
The facility failed to properly hold, secure, and manage residents’ personal money deposited with the nursing home by not providing quarterly banking statements to two of four sampled residents, R56 and R57. Facility staff stated that residents should receive trust fund statements quarterly, but the Nursing Home Administrator found no documentation in the former Business Office Manager’s office showing that the statements had been sent to residents or responsible parties. The administrator later provided one-quarter statements for residents with trust funds, but was unable to show that they had been mailed or handed out. During interviews, R56 and R57 stated they had not seen, and had never seen, their quarterly statements. The Nursing Home Administrator confirmed that the facility failed to provide the quarterly banking statements as required.
Failure to Provide Quarterly Personal Fund Statements
Penalty
Summary
The facility failed to ensure that personal fund statements were provided quarterly to the resident or the resident’s responsible party for two residents whose money was held by the nursing home. For one resident, the daughter served as financial and healthcare POA, substitute decision-maker, and resident representative, and she stated she did not receive a quarterly statement even though the facility held her mother’s money. The resident’s record showed severe cognitive impairment, including being rarely or never understood, having long- and short-term memory problems, and having severely impaired cognitive skills for decision making. A handwritten note on the resident fund statement stated that the resident gets her own and did not send to POA. For the second resident, the resident stated that the facility business office held her money but that she did not receive a statement at least quarterly and did not know who received it. The resident’s MDS showed a BIMS score of 15 with no cognitive impairments. The business office manager stated that quarterly statements were printed and placed in the activities box for the activities director to deliver, and the activities director said she hand-delivered the statements in her box but could not recall which residents received them and could not recall whether she delivered a resident fund statement to this resident.
Resident Funds Were Not Properly Accounted For or Kept Separate
Penalty
Summary
The facility failed to ensure a complete and separate accounting of residents’ personal funds that were deposited with the nursing home, and failed to prevent commingling of resident funds with facility funds or with funds belonging to other residents. Staff described a lock box in the medication room where envelopes containing resident-owned bingo money and money left by families were kept. An LPN stated that resident funds, including monthly $40.00 amounts and bingo winnings, were stored in envelopes with totals written on the outside, but also acknowledged that several envelopes did not have an accurate accounting of the funds and that receipts and change were not consistently documented. Record review showed accounting errors and missing balances for multiple residents. Resident #10’s envelope showed cash and change that did not match the written balance, with a missing amount and no receipts present. Resident #8’s envelope contained numerous undated additions and balance changes, including a gift card entry, with inconsistent totals and no clear final accounting. Resident #9’s envelope also showed a mismatch between the written total and the cash and change present, with missing funds and no receipts available. In addition, the MDS Coordinator stated that when the Administrator was away, resident checks were deposited into whichever account the Administrator indicated, and the Administrator acknowledged that Medicaid dollars had been comingled with business funds and that checks could not be accounted for because errors were made.
Failure to Provide Quarterly Resident Trust Fund Statements
Penalty
Summary
The facility failed to provide evidence that a quarterly statement was given to a resident for personal funds managed by the nursing home. The deficiency involved Resident #65, who was cognitively intact with a BIMS score of 15 out of 15, had diagnoses including osteoarthritis, spinal stenosis, hypertension, major depressive disorder, generalized anxiety disorder, and muscle weakness, and was admitted to the facility over a year and a half earlier. The resident stated she was her own financially responsible person but said she had never received a statement for her personal funds account since admission, and that she instead went to the business office to ask verbally for her balance. Facility policy stated that resident trust fund statements were to be sent to the resident or legal representative within 30 days after the end of each quarter, and the authorization form stated the resident would receive a statement at least quarterly. The business office manager said she prepared account balances for residents with trust accounts but did not send balance statements to residents or representatives, and she had no documentation showing when Resident #65 received statements. The NHA acknowledged that quarterly statements should have been issued and documented for all residents whose money was managed by the facility, including Resident #65.
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