Failure to Implement and Follow Hospice Opioid Orders Resulting in Uncontrolled End‑of‑Life Pain
Summary
The deficiency involves the facility’s failure to implement an effective pain management program for a hospice resident with chronic and end‑of‑life pain, including failure to timely implement and consistently administer ordered opioid medications. The resident had extensive diagnoses including chronic pain syndrome, Parkinsonism, osteoarthritis, neuropathy, prior shoulder replacement, cerebral infarction, and was receiving hospice services for terminal care. The care plan identified the resident as at risk for pain and chronic pain, with interventions to administer pain medications as ordered, monitor for effectiveness and side effects, observe for non‑verbal signs of pain, and notify the physician or hospice for breakthrough pain. The resident’s hospice plan of care included multiple analgesics (Lidocaine patch, Gabapentin, Ibuprofen, Tylenol, and Oxycodone) and recognized that the resident grimaced with movement and had constant pain despite scheduled medications. Hospice recommended increasing Oxycodone to every eight hours scheduled and every four hours as needed, with Zofran as needed, and the physician approved these changes. However, the new Oxycodone and Zofran orders dated one day were not implemented in the facility’s record until three days later at 7:43 p.m., despite narcotic control documentation showing the Oxycodone order had been received earlier. During this period, there was no evidence in the medical record that the new dosing regimen was in place. Additionally, the MAR showed that scheduled Oxycodone doses at 10:00 p.m. and 6:00 a.m. on two consecutive days were not administered because the resident was sleeping, even though the narcotic control sheet showed a 10:00 p.m. dose signed out without documentation of waste. There was also no evidence that as‑needed Oxycodone was administered over several days, despite the resident’s known chronic and hospice‑related pain and staff‑documented non‑verbal indicators of pain on the MDS. Further documentation showed ongoing inconsistencies and omissions in opioid administration and order management. Progress notes indicated that the resident’s pain had been well controlled when all scheduled Oxycodone doses were given, and that missed 2:00 a.m. doses (charted as not given because the resident was sleeping) and changes in the pain regimen were associated with increased pain noted by hospice. There was confusion between Oxycodone and Morphine orders, including a hospice order for Morphine solution as needed without clear discontinuation of Oxycodone, and later notes indicating that Oxycodone should have been continued until Morphine was started, resulting in missed Oxycodone doses. MARs and narcotic control sheets did not match for Oxycodone 5 mg and 10 mg, with doses documented as given on the MAR but not signed out on narcotic logs, and the DON confirmed there were no narcotic control records to support certain documented administrations. Hospice notes and interviews described the resident exhibiting non‑verbal signs of pain and distress (anxiety, crying, moaning, fidgeting, yelling, smacking, kicking, and tense posture), and staff and family reported that at least one nurse did not administer pain medication per hospice orders, sometimes stating the resident did not need it or was fine because she was sleeping. The surveyors concluded that these failures resulted in uncontrolled pain at end of life and required escalation and changes in the resident’s pain regimen to regain control. Additional information in the record showed that the resident’s daughter repeatedly voiced concerns that pain medications were not being administered when the resident was sleeping and that she wanted her mother awakened to receive ordered pain medication. A guest satisfaction concern form documented the daughter’s complaint that a nurse was not giving pain medication when the resident was sleeping, and anonymous staff interviews confirmed that the daughter was upset because a nurse did not administer medications per hospice orders and did not believe in hospice. The facility’s own soft file and corporate review acknowledged family concerns about pain management, and hospice documentation noted that a previous Oxycodone order had not been placed in the resident’s orders, resulting in the resident not receiving it until hospice intervened to have it added back. The DON and Administrator confirmed delays in implementing hospice orders, missed scheduled Oxycodone doses due to the resident sleeping, confusion over concurrent Oxycodone and Morphine orders, and lack of narcotic control documentation to support certain MAR entries. The surveyors determined that these actions and inactions constituted a failure to provide safe, appropriate pain management for a resident requiring such services, resulting in actual harm in the form of uncontrolled end‑of‑life pain. The record also referenced another resident who had concerns that pain medication was not provided upon request in a timely manner, though this concern was not incorporated into the facility’s investigation of pain management issues. The facility’s pain management policy stated that residents’ pain would be evaluated and identified, including in residents with dementia who cannot verbalize pain, and that behaviors such as calling out, facial expressions, refusing to eat, striking out when moved, or increased confusion could indicate pain. Despite this policy, the documentation for this hospice resident showed repeated non‑verbal signs of pain and family reports of suffering, alongside missed or delayed implementation of opioid orders, inconsistent documentation between MARs and narcotic logs, and staff decisions not to administer ordered opioids when the resident was sleeping. These documented events formed the basis of the cited deficiency for failure to provide safe, appropriate pain management.
Penalty
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The facility failed to follow pain management orders and policy for two residents. One resident with hydrocephalus, neuropathy, and chronic back pain received PRN oxycodone when documented pain scores were below the ordered 7-10 range. Another resident, who was cognitively intact after knee replacement surgery, received PRN oxycodone-acetaminophen multiple times without a documented pain score and without documentation of attempted non-pharmacological interventions before administration. The DON confirmed the findings.
A resident with chronic pain, dementia, and other diagnoses repeatedly requested PRN oxycodone-acetaminophen after being assisted to bed, while multiple CNAs alerted an RN that the resident was also making threatening comments. The RN addressed the behavior but did not complete a documented pain assessment, contact the provider, or give the opioid until hours later, after the resident reported being in agony and said the medication had been withheld because of her statements.
Failure to Document Non-Pharmacological Pain Interventions: Staff failed to document non-pharmacological pain measures before giving PRN analgesics to multiple residents. One resident received repeated Tylenol and oxycodone doses, another received multiple PRN oxycodone doses with a care plan calling for relaxation, guided imagery, music, distraction, and massage, and a third resident had a PRN Tylenol order and pain care plan but no documented evidence that non-drug interventions were attempted or effective.
Failure to Monitor and Treat Severe Pain After Ankle Injury: A resident with acute respiratory failure and COPD sustained an ankle injury while transferring to a wheelchair and reported severe pain rated 8/10 to 10/10. Staff applied ice, elevated the foot, and gave PRN acetaminophen, but the MAR documented it as ineffective and the resident continued to report severe pain for hours. An X-ray later showed an acute fracture, and the resident was not transferred to the ED until late that night after the delayed imaging result was obtained.
A resident with severe dementia, a BIMS of 3, and diagnoses including traumatic subarachnoid hemorrhage, weakness, and difficulty walking was supposed to have pain assessed using nonverbal indicators and PAINAD. Instead, staff documented some pain assessments with a numerical pain scale even though the resident could not verbalize pain levels and was unable to answer questions during observation. The NP, DON, ADM, and nursing staff stated PAINAD was the expected tool for this resident, and the facility’s pain policy required a pain tool appropriate to cognitive status.
A resident with severe cognitive impairment, CVA, Alzheimer's disease, seizure disorder, and osteoporosis had pain that was not comprehensively assessed or consistently managed. Staff documented flinching, swelling, and reported pain, but did not record a pain intensity score or location, and PRN Tramadol was not given for one episode of left leg pain despite an existing order. On another occasion, Tramadol was administered for mild pain, but the assessment still did not identify the pain location, and an LPN stated the resident was not in pain without moving or touching the resident during the assessment.
Failure to Follow PRN Opioid Pain Medication Orders and Documentation Requirements
Penalty
Summary
The facility failed to provide pain management in accordance with physician orders and its pain management policy for two residents. The policy required residents to be assessed for pain using an appropriate pain scale, to attempt non-pharmacological interventions before giving PRN pain medication, and to document medication administration and the resident’s response in the eMAR. The policy also directed staff to give the medication that matched the physician-ordered pain intensity when multiple PRN pain medications were available. Resident 30 was admitted with hydrocephalus, neuropathy, and chronic back pain. The physician ordered oxycodone HCl 5 mg every 4 hours as needed for severe breakthrough lower back pain rated 7 through 10. Review of the eMAR showed oxycodone was administered on three occasions when the documented pain ratings were 4, 5, and 6, which were below the ordered range for administration. Resident 47 was admitted after right total knee replacement surgery and had chronic kidney disease. A quarterly MDS dated June 4, 2026, showed the resident was cognitively intact with a BIMS score of 15. The physician ordered oxycodone-acetaminophen 5 mg/325 mg every 4 hours as needed for moderate to severe pain rated 4 through 10, but the eMAR showed multiple administrations without a documented pain rating and without documentation that non-pharmacological interventions were attempted before the medication was given. The DON reviewed the findings and confirmed the facility failed to ensure pain management was provided in accordance with physician orders, facility policy, and accepted standards of practice.
Delayed PRN opioid pain medication after repeated requests
Penalty
Summary
The facility failed to provide safe, appropriate pain management for a resident with chronic pain when a nurse did not timely assess and administer a prescribed PRN opioid after repeated requests from the resident and alerts from multiple CNAs. Resident 33 had diagnoses including muscular dystrophy, major depressive disorder, moderate dementia without behavioral disturbance, and personality disorder, and her care plan identified chronic pain with a goal to remain free from pain or at a level of discomfort acceptable to her. Her physician orders included oxycodone-acetaminophen 7.5-325 mg every 6 hours as needed for moderate pain and acetaminophen 325 mg, 2 tablets every 8 hours as needed for pain. On the night of the incident, Resident 33 was assisted to bed and repeatedly requested her pain medication while also making statements about killing people with guns, a BB gun, a paint gun, and a water gun. Multiple CNAs reported both the resident’s statements and her request for pain medication to RN 1. RN 1 entered the room to address the threatening statements, but the resident became hostile and told the nurse to leave. Documentation showed no pain assessment, no contact with the provider or facility leadership, and no documented response to the resident’s repeated requests for pain medication at that time. Resident 33 did not receive pain medication until approximately 4:09 AM, more than 18 hours after the prior dose and more than 4 hours after the initial request during the night. The resident reported that she had been in agony for hours and that the nurse refused to give her the medication because of the statements she had made. CNA statements and RN 1’s own account confirmed that the resident asked for the medication multiple times before it was finally administered. The DON stated that pain must be treated subjectively based on the resident’s report and that if a nurse had safety concerns about giving a narcotic, the nurse must contact the on-call medical provider or facility clinical leadership for guidance.
Failure to Document Non-Pharmacological Pain Interventions
Penalty
Summary
Facility staff failed to document attempts at non-pharmacological pain interventions before administering pain medications for multiple residents. For Resident #124, the record showed PRN orders for acetaminophen 325 mg, 2 tablets every 4 hours for pain 1-5, and oxycodone 10 mg every 4 hours for pain 6-10. The MAR showed repeated administration of Tylenol and oxycodone throughout June 2026, but review of the TAR and progress notes did not show documentation of non-pharmacological interventions before these medications were given. For Resident #18, the record showed active PRN oxycodone orders for moderate and severe pain, and the MAR showed multiple administrations of both strengths in June 2026. The care plan identified non-pharmacological approaches such as relaxation, guided imagery, music, distraction, and massage before, after, and if possible during painful activities or before pain occurs, but the record did not show documented evidence that these interventions were implemented before opioid administration. For Resident #10, the clinical record showed a PRN Tylenol order and a pain care plan with the same non-pharmacological approaches, but there was no evidence staff documented attempts at these interventions or whether they were successful.
Failure to Monitor and Treat Severe Pain After Ankle Injury
Penalty
Summary
The facility failed to comprehensively monitor and implement appropriate interventions for a resident’s new onset and worsening pain in accordance with physician orders and facility policy. Resident 105 was admitted with acute respiratory failure and COPD, and her admission MDS showed she was cognitively intact with a BIMS score of 15. The facility’s pain policy stated that pain management should be provided consistent with professional standards, the care plan, and resident goals and preferences, and that pain should be reassessed at established intervals with revisions made if pain was not adequately controlled. On June 10, 2026, Resident 105 activated the call bell at about 4:30 AM and was observed halfway off the bed while trying to transfer to a wheelchair. She stated she struck her ankle on the wheelchair while attempting to go to the bathroom, could move the foot and ankle and wiggle her toes, and reported pain rated 10 out of 10. Staff applied ice, elevated the foot, and notified the nursing supervisor. At 5:40 AM, the resident reported continued pain radiating up the leg and requested acetaminophen. The MAR showed acetaminophen 650 mg was given for pain and documented as ineffective at 5:26 AM, and the pain level tab recorded pain ratings of 8 out of 10 at 4:30 AM, 10 out of 10 at 5:26 AM, and 10 out of 10 at 6:50 AM. A late-entry progress note at 9:00 AM documented left ankle pain with bruising, swelling, difficulty walking, and orders for an X-ray, therapy as needed, orthopedic follow-up as needed, acetaminophen, baclofen, and continued monitoring. The X-ray was performed at 4:51 PM and later reported an acute nondisplaced fracture of the left ankle/fibula. The resident remained in pain rated 8 out of 10 when transferred to the emergency department at 11:46 PM, and she stated during interview that she remained in severe pain until hospital transfer. The nursing supervisor stated she contacted the radiology provider around 11:00 PM to obtain the delayed X-ray results, then notified the on-call physician and initiated transfer after the fracture was confirmed. The NHA was unable to provide documented evidence of ongoing pain assessments or additional pain interventions between the injury and the transfer to the emergency department.
Improper Pain Assessment for Cognitively Impaired Resident
Penalty
Summary
The facility failed to ensure safe, appropriate pain management for one resident who required pain services and had severe cognitive impairment. The resident was admitted with traumatic subarachnoid hemorrhage, difficulty walking, lack of coordination, muscle weakness, and Alzheimer’s disease. Her quarterly MDS reflected a BIMS of 3, and her care plan identified her as at risk for pain and as rarely or never understanding in her ability to express ideas and wants. The order summary directed staff to assess pain every shift using non-verbal/noncognitive signs of pain because her pain intensity score could not be verbalized and she had a cognizant deficit. Review of the pain summary showed that on several dates staff assessed the resident’s pain using a numerical pain scale, while the remainder of the assessments from the same period were completed using PAINAD. During interview, the resident’s RP stated the resident had severe dementia, severe cognitive impairment, and diminished mental capacity, and was unable to verbalize or express pain levels. During observation, the resident was sitting in a wheelchair at the memory care unit nurse’s station and had a dark red laceration on the left side of her forehead with stitches; she was unable to answer questions when the surveyor attempted to interview her. The NP, DON, ADM, and nursing staff all stated they expected PAINAD or another nonverbal pain assessment tool to be used for this resident because she could not reliably report a numerical pain score. The DON and ADM were not aware that staff had used a numerical pain scale instead of PAINAD. The facility’s pain management policy stated that staff would observe for nonverbal indicators of pain and use a pain assessment tool appropriate for the resident’s cognitive status.
Incomplete Pain Assessment and PRN Pain Management
Penalty
Summary
The facility failed to comprehensively and accurately assess and manage pain for one resident with severe cognitive impairment who was dependent on all ADLs and had diagnoses including CVA, Alzheimer's disease, seizure disorder, and osteoporosis. The facility's pain management policy required observation for physiologic and behavioral signs of pain and evaluation of pain intensity, description, pattern, location, and frequency/timing/duration, with documentation of the results of any medication intervention. The facility used the PAINAD tool for residents with advanced dementia, but the pain assessments documented for this resident did not include pain intensity or location. On one occasion, a licensed nurse documented that the resident had left hip pain, flinched when the left knee was touched, and had slight edema to the left knee; the physician was notified and ordered an ace wrap and elevation, but the assessment did not record a pain score. The resident had an existing PRN order for Tramadol 50 mg every six hours as needed for pain, yet the MAR showed no Tramadol was given for the left leg pain that day. On another occasion, Tramadol was administered for a pain level of 3, but the pain assessment did not identify the pain location. During interview, one nurse stated the resident was not in pain and admitted not touching or moving the resident during the assessment, despite the companion reporting pain when the resident was moved and repositioned.
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