Locked-unit placement lacked criteria, documentation, and resident access
Summary
The facility failed to ensure residents placed on secured or locked units had established criteria for that placement, documentation of the clinical basis for the placement, resident or representative involvement in the decision, and ongoing assessment of whether the placement remained appropriate. Surveyors observed the first-floor secured dementia unit required a numeric code for entry and exit, and the facility assessment did not identify that the unit was locked. The facility also failed to ensure residents and visitors had access to the code for independent egress from the second-floor unit, where doors to the elevators and stairwells were coded and no code was posted or available to residents or guests. For one resident on the first-floor secured unit, the clinical record showed diagnoses including adjustment disorder with anxiety, chronic embolism, and depression, but admission assessment, MDS, care plan, and social work documentation did not identify that the resident lived on a secure unit or the criteria for that placement. The resident was described as well adjusted, cheerful, cooperative, alert and oriented, ambulatory, not at risk for wandering or elopement, and not expressing a desire to leave. The resident and conservator reported feeling stuck in the room and stated the family had not signed consent for the locked placement. Staff interviews indicated the unit placement was based on a dementia diagnosis, but they also stated there was no policy or criteria for the secured unit and that placement discussions were not documented in the clinical record. For another resident on the secured unit, the record showed diagnoses including vascular dementia, depression, insomnia, and anxiety disorder, but the admission MDS identified intact cognition and no wandering or rejection of care. The care plan did not identify placement on a secured unit or any behaviors, and the social work note only documented that the family was agreeable to moving the resident to the secured unit after a competency evaluation showed lack of capacity to weigh risks and benefits. During observation, the resident exited the room, approached another resident, grabbed and threw a rolling walker, and threatened to kill the other resident, requiring removal from the area and one-to-one observation. Staff later stated the resident was not an appropriate fit for the secured unit, but the medical director said he did not document anything regarding secured-unit placement and would continue placing residents there because he did not want a resident wandering off and being harmed. For a third resident, the record showed diagnoses including alcohol dependence with alcohol-induced persisting dementia and mood disorder, with orders to monitor wandering and exit seeking. The resident was later moved to the locked unit after repeated wandering and attempts to go upstairs, but the care plan did not identify wandering prior to placement or other interventions attempted before the move. The resident stated there was no choice of where to live and that the facility told him or her the placement would continue until a significant other could take the resident home. On the second floor, several sampled residents had intact cognition or no wandering risk, yet their records did not include orders, consent, or care plan documentation supporting locked-unit placement, and staff stated the code was not given to residents because it could create a safety issue.
Penalty
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