Failure to Initiate CPR for Full Code Resident and Inadequate Staff Adherence to CPR Policy
Summary
The deficiency involves the facility’s failure to initiate cardiopulmonary resuscitation (CPR) in accordance with a resident’s advance directives, physician orders, facility policy, and American Heart Association (AHA) guidelines. The facility’s CPR policy required that when an individual is found unresponsive and not breathing normally, licensed or certified staff must initiate CPR unless there is a known Do Not Resuscitate (DNR) order specifically prohibiting CPR or obvious signs of irreversible death, such as rigor mortis. The policy also stated that if a resident’s DNR status is unclear, CPR must be started and continued until a DNR or physician order to withhold CPR is confirmed. AHA guidelines referenced in the policy distinguish presumptive signs of death (such as unresponsiveness, absence of respirations and pulse, fixed and dilated pupils, cool skin, and cyanosis) from conclusive, irreversible signs of death (such as livor mortis, decomposition, decapitation, and rigor mortis). Resident CR1 was admitted with diagnoses including chronic obstructive pulmonary disease, hyperlipidemia, and hypertension. A face sheet from the referring facility, scanned into the electronic medical record prior to admission, documented the resident’s code status as Full Code, indicating a preference to receive CPR in the event of cardiac or respiratory arrest. A nursing note at admission documented baseline confusion, oxygen therapy, and dyspnea, and also noted that attempts to complete admission documentation were unsuccessful because family could not be reached to confirm code status and obtain the resident’s CPAP machine. Despite the presence of the referring facility’s face sheet indicating Full Code status, the resident’s code status was not documented in the facility’s system at the time of the incident. At approximately 2:30 AM, two nurse aides entered the resident’s room and found the resident unresponsive. One aide, who was not CPR/AED certified, did not initiate CPR and instead summoned a registered nurse (RN). The RN’s progress note documented that the resident was unresponsive to verbal commands and sternal rub, had no apical pulse, no obtainable blood pressure or oxygen saturation, one observed respiration, fixed and dilated pupils, and warm, dry skin. The RN did not initiate CPR and directed one aide to check the resident’s code status in the electronic record; the aide reported that no code status was documented. The RN then directed staff to call the RN supervisor. When the RN supervisor arrived, she documented that the resident was unresponsive, pale, with no blood pressure, no pulse oximetry reading, no apical or carotid pulse, no respirations, and no response to sternal rub, and that no DNR or POLST was located in the chart or electronic system. The physician was contacted regarding the resident’s death, and no CPR was initiated at any point, despite the absence of documented irreversible signs of death and the lack of any DNR order. Witness statements provided by staff were consistent in describing the resident as unresponsive with absent vital signs and fixed, dilated pupils, and confirmed that neither the RN nor the RN supervisor initiated CPR. The facility was unable to provide justification for the failure of these licensed nurses to initiate CPR for a resident who did not exhibit documented irreversible signs of death and who was later identified in the closed record as Full Code. Additionally, interviews with multiple LPNs revealed they were unaware of the facility’s policy provisions regarding a designated CPR team and could not identify signs of irreversible death, indicating that staff had not effectively received or understood the CPR policy requirements. Review of other residents’ records showed that 47 additional residents had current physician orders to receive CPR, and the facility’s failures placed these residents, along with Resident CR1, in Immediate Jeopardy to their health and safety.
Removal Plan
- Employee 1 (RN) and Employee 4 (Agency RN Supervisor) were educated on the Emergency Procedure - Cardiopulmonary Resuscitation policy and the need to initiate CPR immediately in accordance with resident wishes and were immediately suspended.
- The facility educated licensed clinical staff on revisions of the CPR policy, including how to respond when someone is unresponsive and when not to initiate CPR (obvious signs of irreversible death) and that if no code status is documented the resident is treated as full code.
- The facility used the payroll system to send the updated CPR policy to staff for electronic review and acknowledgment.
- Nursing education on the updated CPR policy and irreversible signs of death will continue to be completed with licensed staff prior to their next shift starting, beginning with 11pm to 7am shift staff.
- Licensed staff education will be completed regarding the need to initiate CPR immediately in accordance with resident wishes and where to locate code status for each resident in Point Click Care (PCC), on the resident face sheet, and in the orders.
- The facility will ensure each licensed staff member is educated on irreversible signs of death so staff know when it is acceptable not to initiate CPR.
- Education will continue prior to each licensed staff member's next shift.
- Residents’ code statuses were confirmed as reflected in PCC on the resident’s face sheet and in the resident’s orders.
- The Director of Nursing (DON) or designee will audit EMR code status to validate consistency of records for staff reference.
- The DON or designee will audit CPR certification for licensed facility staff.
- The facility conducted a CPR class for employees who were unable to produce up-to-date CPR certification information.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
The facility failed to maintain documentation that 14 of 41 licensed nurses had current CPR certification for Healthcare Providers. CPR cards were not available for several RNs and LPNs, and the NHA and DON confirmed the facility did not ensure these nurses maintained current CPR certification in accordance with accepted national standards.
An agency CNA found a full code resident unresponsive, but an agency RN did not check for a pulse or vital signs and did not start CPR before leaving to call EMS and look for help. Staff present were not CPR certified, and EMS arrived to find the resident pulseless and apneic with no CPR started by the facility. The resident later died at the hospital.
Facility staff failed to ensure that an LPN and a CNA maintained current CPR certification while working scheduled shifts. Interviews with the Administrator, DON, and HR Director confirmed that RNs, LPNs, and CNAs were expected to hold active CPR cards, and record review showed the LPN’s CPR had expired before renewal while the CNA could not produce a valid CPR card for the employee file. Staffing schedules showed both employees worked multiple shifts despite the lapse, and the job descriptions for both roles required current CPR certification.
A full-code resident with atrial fibrillation, liver cirrhosis, and osteomyelitis was found unresponsive after a family member alerted staff to breathing trouble. Staff entered the room without emergency equipment, and CPR was not started promptly; records and interviews showed delays in recognizing the emergency, calling Code Blue/911, and bringing in the AED, AMBU bag, and crash cart. The resident later expired, and the death certificate listed myocardial infarction as the cause of death.
LPNs and RNs did not maintain current CPR certification for Healthcare Providers with a required hands-on component. Facility policy required active CPR certification for licensed nurses, but review of certification cards showed that 16 of 33 licensed nurses had only online-only CPR training for non-healthcare providers. The HR Director, NHA, and DON confirmed the deficiency.
A resident with CHF was found unresponsive and CPR was performed even though the chart contained an active DNR order, an MDS indicating DNR, and a POLST choosing DNR and allowing natural death. LN stated she reviewed the physician order at the time and confirmed the resident was DNR, and the DON confirmed the resident's orders and POLST indicated DNR.
Missing Current CPR Certification for Licensed Nurses
Penalty
Summary
The facility failed to maintain documentation that its nursing personnel had current education and certification to provide basic life support, including CPR, prior to the arrival of emergency medical personnel and subject to physician orders and residents’ advance directives. A review of the facility’s CPR policy showed it was intended to ensure timely and appropriate initiation of CPR by licensed nursing staff in accordance with facility policy, resident rights, and federal and state regulations. During the survey, the facility provided a list of 41 currently employed licensed nurses and copies of CPR certification cards for review. CPR certification cards were not available for RN Employees E3, E4, E5, E6, and E7 and LPN Employees E8 through E16, totaling 14 of 41 licensed nurses. In an interview, the Nursing Home Administrator and the DON confirmed that the facility failed to ensure these nursing personnel maintained current CPR certification for Healthcare Providers through a CPR provider whose training included a hands-on session in a physical or virtual instructor-led setting in accordance with accepted national standards.
Failure to Start CPR for Full Code Resident
Penalty
Summary
The facility failed to assess a resident for a pulse or vital signs and failed to immediately start CPR for a resident who was a full code and was found unresponsive. Resident #60 had diagnoses including multiple fractured ribs on the left side, acute respiratory failure with hypoxia and hypercapnia, type 2 diabetes mellitus with diabetic peripheral angiopathy, CHF, PVD, osteoarthritis of the left knee, and atherosclerotic heart disease of the native coronary artery. The resident’s code status was documented as full code, and the care plan stated CPR should be started and EMS called if needed. According to the CCTV timeline and staff statements, an agency CNA found the resident unresponsive during rounds and summoned nursing staff. An agency RN arrived at the room, briefly entered, and then left without taking vital signs, checking for a pulse, or starting CPR. The RN then went to the nurses’ station and made calls while the resident remained without CPR. Other agency CNAs were present, but they were not CPR certified. EMS arrived several minutes later and found the resident unresponsive, pulseless, and apneic, with no evidence that facility staff had started CPR before EMS arrival. The 911 audio, CAD log, EMS report, police report, and witness statements all reflected that the resident was found unresponsive and that the facility did not initiate CPR. The police officer reported staff were standing in the room and did not know what to do, and EMS reported the facility staff did not start CPR and did not know the approximate down time. The hospital record stated the resident had been found unresponsive by nursing facility staff, no CPR had been performed by the facility for over ten minutes, and EMS initiated CPR and ACLS during transport. The resident was later pronounced dead at the hospital.
Failure to Maintain Current CPR Certification for Nursing Staff
Penalty
Summary
The facility failed to ensure that a nurse and a CNA maintained current CPR certification while working in the facility. Surveyor interviews and record review showed that facility leadership and HR stated that RNs, LPNs, and CNAs were required to have active CPR certification, and that CPR was needed because staff would respond during a code until EMS arrived. Despite this, the surveyor was unable to obtain a current CPR certification card for a CNA after multiple requests to the Administrator, Assistant Administrator, and DON, and the HR Director stated that the CNA had not produced a valid CPR certification for the employee file. Record review also showed that an LPN had worked multiple night shifts while her CPR certification had expired. The LPN confirmed receiving an HR email about the expiration and stated she renewed her CPR certification on the day of the interview. The expired CPR certificate showed the prior certification had lapsed before the renewal date. The HR Director stated she had sent an email about the upcoming expiration but did not follow up after returning from medical leave. Daily staffing schedules showed that the LPN and CNA worked multiple shifts during the review period despite not having active CPR certification. The facility’s job descriptions for both LPNs and CNAs stated that current CPR certification was required. The facility census report showed 149 residents in the facility at the time of the survey.
Delayed CPR Initiation for Full-Code Resident
Penalty
Summary
The facility failed to initiate CPR in a timely manner for a resident who was full code and found unresponsive. The resident had diagnoses including atrial fibrillation, liver cirrhosis, and osteomyelitis of the right ankle and foot, and the MDS documented moderately impaired cognition. The medical orders, MOLST, and care plan all documented full code/CPR status. Surveillance video showed that after a family member alerted staff that the resident was unresponsive, RN #11 and PCT #5 entered the room without emergency equipment. RN #12, the Assistant DON, later entered the room without equipment, and no medical equipment was observed being brought to the room for several minutes. The video also showed multiple staff entering and exiting the room over time, with the AED, AMBU bag, cardiac board, and crash cart not brought in until much later. The Code Blue/CPR worksheet documented CPR as initiated at 7:01 PM, while other records and staff statements reflected delays and inconsistent times for when the resident was found, when CPR began, and when EMS was called. Staff interviews described that the resident was breathing slowly at first, then became unresponsive, with inability to obtain a pulse or blood pressure. PCTs stated they notified RN #11 after the family member reported trouble breathing, and one PCT stated RN #12 said the resident had already passed away before CPR began. RN #14 stated they responded to an overhead Code Blue and saw RN #12 performing CPR, while the DON later stated the facility’s investigation found CPR was not initiated until RN #13 entered the room. The resident expired at 7:22 PM, and the death certificate listed myocardial infarction as the cause of death.
LPNs and RNs Lacked Acceptable CPR Certification
Penalty
Summary
Facility nursing personnel did not maintain current CPR certification for Healthcare Providers through a CPR provider whose training included a hands-on session either in a physical or virtual instructor-led setting in accordance with accepted national standards for 16 of 33 licensed nurses. The affected staff included LPNs E1 through E12 and RNs E13 through E16. The facility policy titled Cardiopulmonary Resuscitation CPR stated that licensed nurses, respiratory therapists, and van drivers must hold active CPR certification for healthcare providers, and that online-only courses were not acceptable. Review of the CPR certification cards for the 16 licensed nurses showed that their certification was from an online-only CPR class for non-healthcare providers and did not include a hands-on session. During an interview, the Human Resources Director confirmed that these employees did not have the appropriate CPR certification for licensed nurses. The Nursing Home Administrator and the DON also confirmed that the facility failed to ensure that facility nursing personnel maintained current CPR certification for Healthcare Providers through a CPR provider whose training included a hands-on session either in a physical or virtual instructor-led setting.
CPR Performed Despite Active DNR Order
Penalty
Summary
The facility failed to confirm the code status of Resident 96 during an emergency when LN 3 performed CPR after the resident was found unresponsive. Resident 96 had been readmitted with a diagnosis of congestive heart failure, and the record showed an active physician order for DNR, along with an MDS assessment and POLST indicating DNR and allowing natural death to occur. During interview, LN 3 stated CPR was performed after Resident 96 was found unresponsive and that she reviewed the physician order at that time and confirmed the resident's code status was DNR. The MDS Coordinator confirmed the POLST and MDS assessment indicated DNR, and the DON confirmed the OSR showed an active DNR order and stated the physician's order and POLST were expected to be carried out correctly; otherwise, the resident's wishes were not honored.
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