Failure to Safely Manage and Reconcile Controlled Substances, Including Oxycodone
Summary
The deficiency involves the facility’s failure to maintain a safe and effective medication system for controlled substances, specifically oxycodone, by not following its own policies and procedures for counting, documenting, and removing narcotic medications. The facility’s written policy required controlled substances to be counted upon delivery, jointly verified and signed by the receiving nurse and the delivery person, stored in separately locked compartments, and reconciled at each shift change by the oncoming and offgoing nurses. The policy also required that only one dose at a time be removed from the emergency medication kit as needed, with proper documentation and reconciliation of all controlled substances, including waste and destruction. Surveyor review showed that these procedures were not consistently followed, leading to an unaccounted-for card of oxycodone and undocumented doses removed from the emergency medication kit. The resident involved had multiple medical conditions, including a fracture of the lower end of the right femur, cognitive communication deficit, major depressive disorder, osteoarthritis of the knee, seizure disorder, chronic pain, and severe cognitive impairment as indicated by a BIMS score of 7. The resident used a wheelchair, had limitations in both arms and legs, was dependent on staff for ADLs, and reported moderately rated pain. Hospital discharge orders included oxycodone 5 mg every eight hours as needed for moderate to severe pain, and the facility’s physician orders later reflected oxycodone 5 mg every four hours as needed for pain. On one occasion, an RN documented that after giving scheduled pain medication, the resident continued to experience significant pain, including yelling and screaming during care and dressing changes, and the RN removed three oxycodone 5 mg tablets from the emergency kit, administering one dose but not documenting the disposition of the remaining two tablets. Record review and staff interviews revealed systemic failures in controlled substance handling and documentation. The facility’s investigation showed that nurses could not consistently recall how many oxycodone cards were present for the resident, and the DON found that none of the interviewed nurses had signed the Controlled Drug Count sheet for the relevant dates, despite their statements that counts were done at shift change. The Daily Controlled Substances Audit form showed nurses were signing to verify card counts without actually performing the required counts. When medication cards were destroyed, nurses documented changes such as +1 or -2 without initials or clear indication of which card was added or subtracted. One LPN reported that on a later date he/she observed that a previously present third card of oxycodone was missing, with the corresponding narcotic count sheet page folded over as if for destruction or return, but with no documentation. Multiple nurses, including LPNs and RNs, stated they routinely removed multiple doses (e.g., several tablets at once) from the emergency medication kit, sometimes eight or nine tablets, and then included any unused tablets in the narcotic count, explaining that they had been trained by other nurses to do this, even though the DON and Administrator stated staff were expected to remove and document only one dose at a time from the emergency kit. These actions and inactions resulted in an unaccounted-for card of oxycodone and undocumented controlled substance doses, in violation of the facility’s controlled substance policy. Additional interviews with leadership confirmed the expectations that were not met. The DON stated that controlled substances should be counted at each shift change by both oncoming and offgoing nurses, that each medication cart and each card’s pill count should match the narcotic count sheets, and that staff should sign the narcotic count book and count medications each time the medication room keys changed hands. The DON also stated that staff should remove only one dose at a time from the emergency medication kit and document removals in the emergency kit carbon notebook for communication with the pharmacy. The Administrator similarly stated that staff were expected to follow the facility’s policy on counting controlled substances and to remove only one dose at a time from the emergency medication kit. Despite these stated expectations, the documented practices and staff interviews showed that counts were not reliably performed or reconciled, documentation was incomplete or inaccurate, and multiple doses were removed from the emergency kit at once without proper tracking, leading to the identified deficiency in the facility’s medication management system for controlled substances.
Penalty
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Medication labeling and storage deficiencies were observed during med pass and cart/room checks. An LPN prepared hydrocodone-acetaminophen for a resident from blister packs whose labels did not match the EMR orders, another cart contained a loose pill in an unlabeled state, and a rehab unit med room had a controlled-medication lock box that was not affixed to the refrigerator. The DON and Administrator stated labels should match orders, carts should not contain loose pills, and controlled meds should be securely locked.
Unattended RT Medication Cart Left Unlocked: RT Medication/Treatment Cart A was observed unlocked and unattended in the 200 Hall with the keys hanging from the opened lock while no staff or residents were within eyesight. RT F stated she had stepped away briefly to check on a resident and acknowledged she should have locked the cart. Medications and supplies were visible in the cart, and RT F said she did not know when she was last trained on keeping the cart locked when unattended. The DON and ADM stated staff were expected to keep carts locked when not with them.
Unlabeled medication cups and supplies were left unattended at the bedside of two residents. A CNA stated cream was left in one resident’s room and later applied, while another resident had a clear cup with a spoon and cream on the nightstand. Staff confirmed neither resident had an order to self-administer medications, and an LPN and the DON stated the residents did not have self-administration orders. The facility policy required medications and biologicals to be stored in locked compartments.
Medications in two med carts and one med room were found without opened-on dates, including eyedrops, creams, gels, ointments, and an insulin pen. RN-A and RN-B stated these items should be dated when opened, and the DON confirmed staff were expected to affix and complete date-opened stickers for these medications. Facility policy required containers or vials to be dated when the original seal was broken.
Missing Medication Refrigerator Temperature Monitoring: The facility failed to monitor temperatures in 3 of 3 medication refrigerators. Temperature logs for Station 1, Station 2, and Station 3 showed multiple missing daily entries, and the Administrator confirmed staff were expected to check the refrigerators daily but there was no back-up temperature monitoring system on the days with blank temperatures.
Expired and discontinued medications were left available in multiple medication carts, including Pantoprazole, ABH Gel syringes, and Propranolol. The DON, an LPN, and a medication aide stated the medications should have been removed from the carts and placed in the return-to-pharmacy bin, but they remained on the 100-hall cart and both 200-hall carts.
Medication Labeling and Storage Deficiencies
Penalty
Summary
The facility failed to ensure drugs and biologicals were stored and labeled in accordance with accepted professional principles. During a medication pass observation, an LVN prepared to give Resident #51 hydrocodone-acetaminophen from the 700/800 hall nurse cart using a blister pack labeled Hydrocodone-Acetaminophen 10-325 mg, give 1 tablet by mouth every 6 hours as needed, while the EMR order for that medication was Hydrocodone-Acetaminophen 10-300 mg, give 1 tablet by mouth every 6 hours as needed. The LVN stated the EMR order did not match the blister pack label and that the order would need to be clarified with the prescriber. A second medication pass observation showed another LVN preparing to administer hydrocodone-acetaminophen from the 800 hall medication aide cart to Resident #51 from a blister pack labeled Hydrocodone-Acetaminophen 10-325 mg, give 1 tablet by mouth every 6 hours as needed, while the EMR order for that medication was Hydrocodone-Acetaminophen 10-325 mg, give 1 tablet by mouth twice daily. The LVN stated the PRN-labeled blister pack should not have been in the medication aide cart and that the cart should have contained a blister pack with routine dosing for the resident. The DON stated the prescription labels on blister packs needed to match the EMR orders and that staff were expected to follow physician orders and clarify orders when needed. On another observation, a loose pill was found in the third drawer of the 500/600 hall nurse cart, and RN B stated loose pills should not be in medication carts because they are unlabeled and could be taken or consumed without knowing what they are. In the rehabilitation unit medication room, the lock box for controlled medications was observed not affixed to the refrigerator. RN G stated the box should be affixed so it could not be removed, and the DON and Administrator both stated lock boxes for controlled medications should be affixed to the refrigerator. Resident #51 had diagnoses including depression, anxiety, seizures, and diabetic neuropathy, with a BIMS score of 14 and opioid use documented in the MDS.
Unattended RT Medication Cart Left Unlocked
Penalty
Summary
The facility failed to ensure drugs and biologicals were stored in accordance with accepted professional principles for 1 of 2 RT carts reviewed. During an observation on 06/11/26 at 8:44 AM, RT Medication/Treatment Cart A was seen in the 200 Hall unlocked and unattended, with the keys hanging from the opened lock. No staff or residents were within eyesight of the cart at that time. During an observation and interview at 8:46 AM, RT F stated she had gone into a resident's room quickly to see what he needed and acknowledged she should have locked her cart when she stepped away from it. RT F opened the top drawer, and medications and supplies were observed in the cart. RT F stated she did not know when she was last trained to keep her cart locked when unattended and did not know of a potential negative outcome to residents. The DON and ADM later stated they expected staff to keep carts locked when not with them and that keys should be kept in their pocket or on their person. The facility policy stated medication carts and supplies are to be locked or attended by authorized persons.
Unlabeled Medications Left at Bedside
Penalty
Summary
The facility failed to follow standards for medication storage for 2 of 6 halls reviewed for unattended medication. During observation, a clear medication cup containing cream was found at the bedside of Resident #86, and the cup was not labeled. Two normal saline flush syringes were also observed on top of the resident’s nightstand. In interviews, the resident’s representative stated staff came in and applied the cream when they changed the resident, and a CNA stated the wound care nurse gave her the cream that morning, she left it in the resident’s room, and later applied it. An LPN stated she was not aware of any cream or normal saline flushes and had not done any of it. A similar observation was made at the bedside of Resident #38, where a clear medication cup with a spoon and cream was left on the nightstand. The resident stated staff apply the cream when they change him. A CNA confirmed the cup with the spoon was at the bedside and said it was cream to apply when the resident was changed, but it should not have been left there. An LPN stated the resident did not have an order to self-administer medication, and the DON later stated that Residents #86 and #38 did not have orders to self-administer medications. The facility policy titled Medication Labeling and Storage stated that medications and biologicals are stored in locked compartments under proper controls and only authorized personnel have access to keys.
Medications Missing Opened-On Dates
Penalty
Summary
The facility failed to ensure medications were appropriately labeled with an opened-on date in 2 of 2 medication carts and 1 of 1 medication rooms reviewed for medication labeling and storage. During observation and interview, the North medication cart contained multiple medications without opened-on dates, including Nizoral shampoo, Victosa insulin pen, Diclofenec Sod Top Gel, Biofreeze gel 4%, Hydrocortison cream 1%, Nystatin cream, Hemorrhoidal ointment, Calmoseptine ointment, Diclofenca Sod Top Gel 1%, and Triamcinolone Acetonide Cream. RN-A stated that all eyedrops, creams, gels, and similar medications in tubes should be dated as soon as they are opened, and that nurses and TMAs should check for an opened-on date when using these medications. The medication room also contained opened medications without opened-on dates, including Sustane eye drops, Ketoconazole cream 2%, Bacitracin ointment, Hydrocortisone cream 2.5%, and Dorzolamide Hydrochloride and Timolol Maleate Ophthalmic Solution 2%. In the East wing medication cart, Hydrocortisone Cream 1% and Diclofenac Sodium Gel 1% were also missing opened-on dates. RN-B stated that if a medication was missing the opened-on date it should not be used because it could be expired and the resident would not get the actual prescribed dose. The DON stated all medications should have an opened-on date clearly affixed and that staff should place an opened-on sticker and fill it out each time a new bottle of eyedrops, creams, gels, or similar medications was opened. Facility policy stated that when the original seal is broken, the container or vial will be dated and the nurse shall place a date-opened sticker and enter the date opened and new expiration date.
Missing Medication Refrigerator Temperature Monitoring
Penalty
Summary
The facility failed to monitor temperatures in 3 of 3 medication refrigerators. A review of the temperature logs for Station 1, Station 2, and Station 3 for 5/2026 showed multiple missing daily temperature entries, including 10 missing days for Station 1, 9 missing days for Station 2, and 12 missing days for Station 3. On 6/4/26, the Regional Director of Clinical Operations provided the logs, and on 6/5/2026 the Administrator stated staff were expected to check the medication refrigerators daily and confirmed the missing temperatures. The Administrator also stated the facility did not have a back-up temperature monitoring system on the days with blank temperatures.
Expired and Discontinued Medications Left in Medication Carts
Penalty
Summary
Drugs and biologicals were not maintained in accordance with accepted storage and labeling practices because expired and discontinued medications were left in medication carts. During an observation with the DON, the 200-hall upper medication cart contained a Pantoprazole 40 mg medication card with 27 pills remaining and a pharmacy expiration date of 5/31/26, even though the physician’s order had been discontinued on 3/9/26. The expired Pantoprazole remained available for use in the cart. Nurse #1 stated the medication had been overlooked and should have been removed from the cart and placed in the return-to-pharmacy bin in the medication room when the order was discontinued. Additional observations showed similar issues on other carts. The 100-hall medication cart contained a bag of ABH Gel syringes with 15 syringes remaining and a pharmacy expiration date of 6/1/26, although the physician’s order had been discontinued on 6/1/26. The 200-hall lower medication cart contained Propranolol 20 mg tablets with 25 pills remaining and a pharmacy expiration date of 11/30/25, although the order had been discontinued on 7/15/25. Staff interviews indicated that nurses and medication aides were expected to check expiration dates before administration, and that discontinued or expired medications should be removed from the carts and placed in the return-to-pharmacy bin, but these medications remained on the carts and available for use.
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