F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
F

Failure to Maintain a Full-Time, Dedicated DON While DON Also Covered Multiple Clinical Roles

Amethyst Health Of Brown DeerMilwaukee, Wisconsin Survey Completed on 02-17-2026

Summary

The deficiency involves the facility’s failure to maintain a full-time, dedicated Director of Nursing (DON) as required, particularly when the census exceeded 60 residents. Interviews and record reviews showed that from late July to late October and again from late November to the survey date, the facility did not have a full-time DON. Instead, the individual designated as DON was functioning in multiple roles, including Interim DON, Clinical Manager/floor nurse on the ventilator/trach unit, Infection Preventionist (IP), wound care supervisor, and lead educator. The facility assessment documented that the facility staffs a full-time DON and a full-time ventilator unit lead nurse, but in practice, one person was performing both of these roles along with additional responsibilities. During interviews, the Interim DON reported working only part of the week on DON duties and the remainder as Clinical Manager/floor nurse on the vent/trach unit, including every other weekend on the unit. The Interim DON estimated dedicating approximately 30–32 hours per week to DON responsibilities and confirmed also serving as the facility IP, spending Mondays on infection prevention while multitasking with DON or floor nurse duties. The Assistant DON stated that coverage for the DON role on days when the Interim DON worked the floor was handled informally through verbal communication and that the Assistant DON was not formally scheduled as acting DON. The Nursing Home Administrator acknowledged that the requirement is to have a full-time DON and confirmed that the Interim DON was splitting time between DON duties, floor nursing, and IP responsibilities. Payroll-Based Journal (PBJ) data provided by the facility showed that while weekly reported DON hours often exceeded 40 hours, they were spread across long individual days and weekends rather than reflecting a consistent, full-time, Monday–Friday DON presence. The PBJ hours also did not align with the schedule pattern described by the Administrator and Interim DON, raising concerns about the accuracy of the reported DON hours. The surveyor noted that the lack of a full-time, dedicated DON, combined with the Interim DON’s multiple concurrent roles (DON, vent unit lead nurse, IP, wound supervisor, and educator), meant that these roles could not be adequately performed within the hours worked and created a reasonable likelihood that this contributed to various clinical issues identified during the survey in areas such as care planning, infection control, wound care, staffing, tube feeding, catheter care, and staff competencies. The deficiency was cited as a Class B State citation related to failure to meet required DON staffing. The Medical Director and a nurse practitioner involved with the ventilator unit both confirmed that they understood the Interim DON to be the DON but were not aware of the extent to which the DON was also working on the floor and serving as IP. The nurse practitioner stated that the DON position is typically full time plus more and acknowledged understanding a concern if the DON had that many responsibilities. The Administrator provided a timeline showing that after the prior DON resigned, the Interim DON assumed the DON role while continuing other duties, a new DON was briefly hired and then went on leave and was terminated, and the Interim DON again resumed the DON role while still functioning as Clinical Manager/floor nurse, IP, and wound supervisor. Throughout this period, the facility’s average daily census was in the high 50s to mid-60s, exceeding the threshold at which the surveyor stated a full-time, dedicated DON is required.

Penalty

No penalty information released
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

Below are regulatory guidelines relevant to this citation:

See other F0727 citations
Failure to Maintain Required RN Coverage
F
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

Failure to Maintain Required RN Coverage: The facility did not have an RN in the building for at least 8 consecutive hours a day, 7 days a week on multiple dates. Administrative Nurse D verified that no RN was present for the required coverage or serving as charge nurse on those dates, despite the facility policy requiring daily RN coverage and a full-time DON.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Maintain Required RN Coverage
E
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

Failure to Maintain Required RN Coverage: The facility failed to ensure an RN was on duty for at least 8 consecutive hours a day, 7 days a week on multiple reviewed days. Daily HR reports showed zero RN hours worked on several dates, and both the DON and ADM stated they could not explain why RN coverage was absent, while acknowledging the requirement for daily RN coverage and the administrator's responsibility for staffing.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
RN and DON Coverage Not Maintained
F
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

RN and DON Coverage Not Maintained: The facility failed to ensure an RN served as DON on a full-time basis and failed to maintain RN coverage for at least eight consecutive hours each day. Staffing schedules, timecards, and staff interviews showed no RN worked on two days and no DON was present for several days. Interviews also confirmed the DON coverage was intermittent, with one RN serving only on limited days and another stating she had no documentation showing she worked in the facility after the prior DON left.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Lack of Documented Daily RN Coverage
F
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

Lack of Documented Daily RN Coverage: Surveyors found that the facility did not have documented RN coverage scheduled for at least 8 consecutive hours per day, 7 days a week. Review of staffing postings showed multiple days without the required RN coverage, and the ANHA stated there were no other documents available to verify RN coverage. No policy was provided by the end of the survey.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
RN Coverage Not Maintained
F
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

RN Coverage Not Maintained: The facility failed to ensure RN services for at least 8 consecutive hours per day, 7 days a week. Time records showed missing RN coverage on multiple days, and the DON and ADM acknowledged that RN staffing hours were absent at times. The facility policy required RN coverage and allowed DON hours to count toward the requirement.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
RN Coverage Not Maintained as Required
F
F0727 F727: Have a registered nurse on duty 8 hours a day; and select a registered nurse to be the director of nurses on a full time basis.
Short Summary

RN Coverage Not Maintained as Required: The facility failed to maintain RN coverage for at least 8 consecutive hours per day. Record review showed multiple days with no RN in the building within a 24-hour period and other days with less than 8 consecutive hours of RN coverage. Interviews confirmed the Staffing Coordinator and DON leadership understood the coverage expectation differently, and the facility sometimes relied on an on-call RN to come in if issues arose.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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