Failure to Protect Resident From Misappropriation of Funds
Penalty
Summary
The deficiency involves the facility’s failure to protect a resident from misappropriation of property, specifically unauthorized transfers of money from the resident’s bank account to a CNA’s money transfer application. The facility’s ANEMMI policy defines misappropriation as the deliberate misplacement, exploitation, or wrongful use of a resident’s belongings or money without consent. During November 2025, the facility initiated an investigation into an allegation that funds had been transferred from Resident #1’s bank account to CNA Staff A via a mobile money transfer application. Documentation from local law enforcement, reviewed as part of the facility’s investigation, showed that between 10/6/25 and 10/31/25, transactions totaling $13,250.00 were transferred from the resident’s bank account to CNA Staff A’s money transfer account. The Business Office Manager reported that during her rounds on 11/13/25, the resident questioned why he was being charged $14,000 per month for his stay, and she informed him that the Veterans Administration paid for his stay and that the facility did not receive any funds from him. At the resident’s request, she reviewed his bank statements and observed transfers made to CNA Staff A through the money transfer application, after which the resident asked for help and requested that the police be called. The DON interviewed the resident the same day; with the resident’s permission, he reviewed the resident’s cell phone and bedside computer and confirmed that the money transfer application used for the transactions was not linked to either device. The resident stated he kept his debit card in his bedside dresser, did not give anyone permission to use it, and could only recall possibly giving the card to CNA Staff A once to purchase items, though he was unsure. Bank statements from October 2025 provided by the facility showed multiple transfers to CNA Staff A through the application, supporting the allegation of misappropriation.
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