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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Unattended medications were found left at a resident’s bedside, on another resident’s bedside table, and in a dining room where a resident was eating breakfast, even though staff confirmed the residents were not able to self-administer. An LPN also found expired ophthalmic drops in a medication cart, and the DON confirmed the eye drops were expired and should have been discarded.
Medication refrigerator temperatures were not kept within the required range and were not checked consistently. The main med refrigerator was found above range, with missing temperature logs across multiple months. It stored several residents’ insulins and other meds/biologicals, and an LPN later found the unit at about 50 degrees F. The DON stated staff should check refrigerator temperatures daily, and the consultant pharmacist reviewed how long the stored items could remain usable once the safe range was exceeded.
Medication labeling was deficient in the 500 wing med cart. An LPN observed a Lantus insulin pen with no expiration date and two bottles of Systane eye drops with missing opened-on and/or expiration dates; the LPN stated the cart lacked the stickers needed for proper labeling. The DON stated staff were expected to label items such as eye drops, insulin, nasal sprays, and inhalers with opened-on and expires-on dates when medications were checked in from pharmacy.
Unsecured Medication Cart and Expired Medications: An unlocked, unattended med cart was observed in a nursing station with open access, and expired Vitamin B-12 was found on another cart. An MA stated she administered the expired medication without checking the expiration date, while the DON said staff were expected to verify expiration dates and keep med carts locked when unattended.
Medications were left unsecured on medication carts and one cart was observed unlocked and unattended. An RN left an opened antibiotic for a resident on top of a cart, another RN left Polyethylene Glycol and Fluticasone nasal spray on top of a cart while administering meds, and a CMA was observed with an unlocked cart whose drawers were easily opened. The DON stated medications should be locked in the cart and refrigerated meds returned to the refrigerator after use.
An opened vial of Tubersol PPD in the First Floor Main Medication Room refrigerator was found without an open date, and staff could not determine its expiration date. Facility policy required stock medication labels to include the expiration date when applicable, and the ADON confirmed the vial was not dated.
Unattended Medications and Expired Eye Drops Found
Penalty
Summary
Drugs and biologicals were not stored and handled in accordance with accepted professional principles when unattended medications were left at the bedside and in a dining room, and expired medication was found in a medication cart. During observation, a clear medication cup containing a white cream was found behind a picture frame on a nightstand in a resident’s room, and the resident stated nurses apply the cream to the groin area. Staff confirmed the resident was not able to self-administer medication. In another room, a medication cup with two white tablets was left on the bedside table for a resident who was also not able to self-administer medication, and the RN confirmed the medication had been left unattended at bedside. In the memory care dining room, a resident was observed eating breakfast with a medication cup containing five tablets on the table while the nurse stood away from the residents at the medication cart. The LPN later confirmed the resident still had medication in the cup, and the DON stated medications are to be administered with the staff staying with the resident to ensure they are consumed. In addition, an observation of a hallway medication cart found two expired bottles of Brimonidine Tartrate Ophthalmic Solution 0.2% and one expired bottle of Olopatadine Hydrochloride Ophthalmic Solution. Staff stated expired eye drops should be discarded, and the DON confirmed the eye drops were expired and should have been disposed of and reordered.
Medication Refrigerator Temperatures Not Monitored Consistently
Penalty
Summary
The facility failed to keep medication refrigerators within the recommended temperature range for 1 of 2 medication refrigerators. During observation, the main medication storage room refrigerator read 42 degrees F, while the temperature log for July showed the last recorded reading was 39 degrees F. The log had no entries for July 1, 2, 3, 4, or 6, and staff were using food refrigerator temperature logs. The temperature log identified a safe range of 32 to 41 degrees F, and instructions directed staff to report any out-of-range temperature to the supervisor. The LPN verified that the July temperature had been recorded only one time. Review of prior months showed the same issue with incomplete monitoring: June had only four recorded temperatures with 26 days missing, May had no temperature readings available, and April had three recorded temperatures with 28 days missing. The refrigerator contained medications and biologicals including multiple residents’ insulins such as Lantus, NovoLog, Humalog, and Basaglar, as well as Trulicity, calcitonin spray, Evenity, Aplisol, Engerix B, and Comirnaty. The DON stated staff should check refrigerator temperatures daily, and an LPN later found the refrigerator temperature was about 50 degrees F and moved the medications to a different refrigerator. The consultant pharmacist reviewed the medications and identified varying time limits for use once the refrigerator exceeded the safe range, based on the last known temperature reading.
Medication Labeling Deficiency in 500 Wing Cart
Penalty
Summary
Medications and biologicals in the facility were not labeled in accordance with accepted professional principles in the 500 wing medication cart. During observation with an LPN, one Lantus insulin pen was found with no expiration date noted. A box containing two bottles of Systane eye drops was also observed; one bottle had an open date but no expiration date, and the second bottle had neither an opened-on date nor an expiration date. The LPN stated that when medications were received, staff were supposed to place an opened-on/expired sticker on the medication and write the date it was first used and the expiration date on the sticker, but no stickers could be found in the cart during the demonstration. The LPN stated that without an opened-on or expiration date, staff would not know how long a medication had been opened or whether it was safe to use. The LPN also stated that eye drops expire 28 days after opening, and the eye drops dated [DATE] were past expiration. During interview, the DON stated she expected staff to place opened-on and expires-on stickers on medications such as eye drops, insulin, nasal sprays, and inhalers when medications were checked in from pharmacy, and that this information was important to ensure the medication was safe to use and still within its therapeutic level. A policy related to medication labeling and storage was requested but not provided.
Unsecured Medication Cart and Expired Medications
Penalty
Summary
Drugs and biologicals were not stored and handled in accordance with accepted professional principles when an unattended medication cart was found unlocked in the C and D Hall nursing station and expired medications were found on the A Hall medication cart. During observation, the C Hall medication cart was left unlocked and unattended inside a nursing station that had two accessible entrances, including one open entrance with no door. The Director of Nursing Services stated the cart should be locked when unattended, and Nurse #1 stated she had locked the cart after handoff but was unsure why it was unlocked and said she was the only person with a key. On the A Hall medication cart, a bottle of Vitamin B-12 500 mcg with an expiration date of 1/2026 was available for use, and Medication Aide #1 stated she had administered it to a resident without checking the expiration date. A second bottle of Vitamin B-12 1000 mcg with an expiration date of 6/2026 was also observed on the cart. The DON stated nurses or MAs were expected to check expiration dates before administering medications and to remove expired medications from carts at the start of each shift, and the Administrator stated expired medications should be removed from medication carts and replaced with non-expired medications.
Unsecured medications left on carts and an unlocked medication cart observed
Penalty
Summary
Medications were not securely stored in three observed medication carts. On 6/30/26, an opened bottle of liquid Amoxicillin-Pot Clavulanate oral suspension for resident 181 was left on top of a medication cart in the 700 hallway outside resident 75's room with no staff present. During the time it remained there, CMA X, an activities assistant, and two unidentified visitors walked past the cart. Clinical care leader S later removed the antibiotic and stated RN V had been assigned to that cart and had left the medication there; RN V acknowledged she had forgotten to return the antibiotic to the refrigerator after leaving the cart. Resident 181 had a physician's order for Amoxicillin-Pot Clavulanate oral suspension via NG tube for acute cystitis without hematuria. On 7/1/26, RN FF was observed preparing medications for residents 47 and 150 and left a bottle of Polyethylene Glycol and a bottle of Fluticasone nasal spray on top of the medication cart while she walked into the dining room to administer medications. RN FF stated she left the Fluticasone nasal spray there so she would not forget to give it to resident 89, who was eating, and said the Polyethylene Glycol bottle was not supposed to be left unsecured. On 7/2/26, RN/clinical nurse leader I and CMA Z were observed with an unlocked medication cart in the 200 hallway with no nurse or medication aide attending it, and the drawers were easily opened. CMA Z stated she thought she had locked the cart. The DON stated medications were expected to be locked in the cart and not left unattended, and refrigerated medications were expected to be returned to the refrigerator after use.
Opened Tubersol Vial Lacked Required Date
Penalty
Summary
Medications were not properly dated when opened in the First Floor Main Medication Room. Review of the facility policy on labeling medication containers stated that stock medication labels must include the expiration date when applicable. Manufacturer guidance for Tubersol PPD stated that vials entered and in use for 30 days should be discarded. During observation of the First Floor Main Medication Room refrigerator, an opened vial of Tubersol was found without an open date, so staff could not determine the expiration date. The Assistant Director of Nursing confirmed that the opened vial lacked an open date.
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