Inaccurate Documentation and Reconciliation of Controlled Substances
Penalty
Summary
The deficiency involves the facility’s failure to accurately reconcile and document the administration and destruction of Schedule II, IV, and V controlled substances for multiple residents, contrary to its own policies on controlled substance accountability and medication administration. Facility policy required that all controlled substances be clearly documented on designated usage forms, that doses on the usage forms match the MAR and controlled drug records, and that the controlled drug record serve as the record of both narcotic disposition and resident administration. Policy also required that staff sign the MAR after administration and sign the narcotic book for controlled substances. Surveyors found repeated instances where destruction dates and quantities recorded on Controlled Drug Receipt/Record/Disposition forms did not match typed destruction logs, and where staff documented removal of narcotics from the controlled drug record without corresponding documentation of administration on the MAR. For one resident with an order for hydrocodone/APAP 5/325 mg as needed for pain, the order was discontinued near the end of January, and there was no documentation on the January MAR that the medication had been administered. The Controlled Drug Receipt/Record/Disposition form for hydrocodone/APAP dispensed in June showed that on a January date, the ADON and DON documented destruction of three tablets, yet subsequent entries on the same form showed staff removing tablets on later January dates with no matching MAR entries. A typed destruction log later showed that 14 tablets of the same medication were destroyed via drug buster on a later January date, and this destruction amount did not match the amount documented on the disposition form. The DON acknowledged that staff should document narcotic administration on the MAR when removing medication from the count sheet and should not administer medication after an order is discontinued, and she attributed discrepancies to poor handwriting and being in a hurry. For another resident with multiple tramadol 50 mg orders that were tapered and then discontinued in December, the December MAR showed no tramadol administration after the final discontinuation date, and there was no tramadol order on the January POS or MAR. The Controlled Drug Receipt/Record/Disposition form for tramadol dispensed in early December showed that on a December date the ADON and DON documented destruction of three tablets, while the last entry that same day showed ten tablets remaining. Despite this, subsequent entries on the form documented removal of tramadol tablets on later December and January dates, none of which were documented on the MAR. A typed destruction log showed that 26 tablets were destroyed via drug buster on a December date, which did not match the destruction amount on the disposition form. The DON stated that the destruction date should have been a January date and that the 26-tablet destruction entry was an error based on the delivered quantity. For a third resident with pregabalin 50 mg ordered at bedtime and later changed to pregabalin 75 mg, the 50 mg dose was discontinued in November, and there were no MAR entries for pregabalin 50 mg after the discontinuation date in November, nor any active order for this dose on subsequent POS or MARs. The Controlled Drug Receipt/Record/Disposition form for pregabalin 50 mg dispensed in November showed that on a November date the ADON and DON documented destruction of 19 tablets. However, the same form contained later entries showing staff removing pregabalin 50 mg tablets on multiple dates in November, December, and January, with no corresponding MAR documentation and no active order for this dose. A typed destruction log showed that 19 tablets were destroyed via drug buster on the same November date. The DON later stated that the destruction date should have been a January date. For a fourth resident with an order for oxycodone hcl 5 mg as needed that was discontinued in late September and a later order for oxycodone/acetaminophen 10/325 mg twice daily, the October POS contained no order for oxycodone hcl 5 mg. The Controlled Drug Receipt/Record/Disposition form for oxycodone hcl 5 mg dispensed in August showed that on a September date the ADON and DON documented destruction of five tablets. Despite this, the same form showed entries for removal of one tablet on a September date and two tablets on an October date, with no MAR documentation for these administrations and no active order for that dose in October. A typed destruction log showed that five tablets were destroyed via drug buster on the September date. The DON stated that the destruction date should have been an October date and believed that the removal of two tablets in October reflected staff taking two tablets to administer under the then-current order. Interviews with RN A and the ADON confirmed that when narcotic orders are changed or discontinued, floor nurses pull the medication and log from the cart and give them to the DON or ADON for destruction, that floor staff do not destroy narcotics, and that the ADON’s initials in the destruction box indicate acknowledgment that the medication had been destroyed, though both acknowledged that errors may have occurred in the documentation process.
