Failure to Ensure Behavioral Health Training and Staff Access to Policies and Procedures
Penalty
Summary
The deficiency involves the facility’s failure to ensure that staff working in the behavioral health Special Treatment Program (STP) had the required behavioral health training, and that clinical and direct care staff could locate and reference facility policies and procedures. A complainant reported that Activity Assistants (AAs) were required to enter the STP to assess residents’ activity needs without having the required behavioral health training. The STP Director stated that all employees who worked in the STP were required to complete behavioral health training to ensure staff and resident safety. Review of the facility’s behavioral health training record with the Director of Staff Development showed that AA 1 and AA 3 were not listed as having completed the training, and AA 2 had only participated in the first day of a two‑day behavioral health training program. AA 1, AA 2, and AA 3 confirmed they were required to enter the STP for activity assessments and care plan revisions; AA 1 and AA 3 reported they had requested behavioral health training due to safety concerns but had not received it, despite having worked at the facility from several months to over two years. Further review of training documentation with the DON and Administrator confirmed that only AA 2 appeared on the training list, and that AA 1 and AA 2 had completed only day one of the behavioral health training, with no evidence of completion of day two. There was no documentation of any behavioral health training for AA 3 or AA 4. The facility’s policy titled “ProACT Training & Certification,” dated 8/28/2025, stated that Generations Healthcare provides Professional Assault Crisis Training (ProACT) to all staff involved in direct patient care within behavioral health units, including program staff, nursing staff (RN, LVN, CNA), STP staff, and ancillary staff responsible for daily job duties on behavioral health units where they may interact with behavioral health residents. The policy required all applicable staff providing direct patient care or completing daily job duties on behavioral health units to complete ProACT de‑escalation and restraint training within 90 days of hire. The deficiency also includes the inability of multiple staff members to locate or identify facility policies and procedures (P&P), including those related to ventilator weaning and resident showers. A Unit Manager stated that P&P could be found on the computer but was unable to locate a ventilator weaning policy. A Respiratory Therapist reported not knowing where facility P&P were kept, stated that P&P used to be in a binder whose location he did not know, and was unable to state the current ventilator weaning policy, relying instead on personal experience. Several CNAs and LVNs reported they did not know where P&P were stored and indicated they would ask a nurse or manager if they had questions. Another Unit Manager stated she could ask medical records for P&P. A professional reference from the American Association of Post‑Acute Care Nursing, cited in the report, described that policies should be reviewed annually, revised as regulations change, and stored with documentation of review dates and revision histories, and that policies ensure regulatory expectations are met, resident rights are protected, and staff actions are guided with clarity and consistency.
