Unaccounted Narcotics and Misappropriation of Resident Medications via I-STAT Withdrawals
Penalty
Summary
The deficiency involves the facility’s failure to protect residents from misappropriation of property when staff could not account for 19 missing controlled-substance tablets for 10 residents. Facility policies required controlled substances to be stored under double-lock conditions, counted every shift, and any discrepancies reported immediately to the DON. Policies also required that if a medication with an active order could not be located in the cart, staff should search other areas and, if still not found, obtain it from the I-STAT and document administration on the MAR. The abuse and misappropriation policy required investigation of suspected misappropriation and staff education on prevention and reporting responsibilities. The events leading to the deficiency centered on RN A’s repeated withdrawal of narcotics from the I-STAT automated dispensing cabinet without corresponding documentation of administration on the MAR or in the EHR. On one morning, after receiving shift report, RN B observed RN A in the medication room logging into the I-STAT and withdrawing an oxycodone 10 mg tablet under a resident’s name without a request from the CMT assigned to that hall. RN B then saw RN A coming from the bathroom, and RN A made a comment about feeling alive again. The resident under whose name the oxycodone was withdrawn could not recall exactly when they last received a pain pill and only remembered that a female had given it. Review of I-STAT records showed that on multiple prior occasions over several months, RN A had withdrawn oxycodone, hydrocodone-APAP, and tramadol tablets for various residents without any documentation of administration on the MAR. Ten residents with orders for PRN narcotic analgesics were involved. One resident with multiple sclerosis, COPD, atrial fibrillation, dementia, and frequent, constant pain had an order for oxycodone IR 10 mg every four hours PRN; I-STAT records showed several oxycodone tablets withdrawn by RN A on different dates with no corresponding MAR entries. Another resident with brain cancer, COPD, and diabetes had tramadol 50 mg PRN ordered, and a tramadol tablet was withdrawn by RN A without documentation. Additional residents with diagnoses including rhabdomyolysis, hip pain, Parkinson’s disease, Alzheimer’s disease, dementia, heart failure, atrial fibrillation, obesity, unspecified pain, encopresis, cachexia, stroke, and recent amputation had PRN orders for hydrocodone-APAP or tramadol; for each, I-STAT reports showed narcotic tablets removed by RN A on specific dates and times with no documentation of administration in the EHR or MAR. Staff interviews confirmed that narcotics were supposed to be double-locked, counted each shift, signed out on the narcotic log and MAR, and that missing narcotics were considered misappropriation. The consultant pharmacist explained that the I-STAT system tracks cabinet inventory but does not by itself confirm administration, so withdrawals that are not documented on the MAR would not create an automatic discrepancy in the I-STAT count. The DON stated awareness that RN A had a history of medication diversion and had instructed RN A not to administer narcotics, indicating that CMTs were to administer all medications. Despite this, it was later discovered that RN A had been pulling narcotics from the I-STAT. The DON had been running weekly discrepancy reports on the I-STAT and conducting monthly narcotic counts with the consultant pharmacist, but these processes did not detect RN A’s pattern because the I-STAT counts remained correct. Only when the DON ran a report by nurse name and compared each I-STAT withdrawal to the EHR MAR and narcotic log did it become evident that RN A had repeatedly removed narcotics without documented administration, resulting in 19 missing narcotic tablets for 10 residents and constituting misappropriation of resident medications. Interviews with CMTs and an RN confirmed that they performed narcotic counts with off-going staff each shift, maintained double-lock security, did not give their keys to others, and would notify the DON immediately of any discrepancy. They also stated that they signed out narcotics on both the narcotic log and MAR and that they considered missing narcotics to be misappropriation. The consultant pharmacist confirmed that medications were delivered daily and that the pharmacy ran a daily controlled-medication report, but that the I-STAT system alone would not flag missing doses if the cabinet count remained accurate. The Administrator stated that missing narcotics were considered misappropriation of property and that an investigation was initiated after being notified of potential diversion, ultimately revealing that RN A had been removing narcotics from the I-STAT and not administering them to residents. Overall, the facility failed to prevent misappropriation of resident medications by not detecting that RN A, who had a known history of diversion and had been instructed not to administer narcotics, was repeatedly withdrawing controlled substances from the I-STAT without documentation of administration. This resulted in 19 unaccounted-for narcotic tablets intended for 10 residents with documented pain and PRN orders for oxycodone, hydrocodone-APAP, or tramadol, in violation of the facility’s own policies on controlled substances, medication administration, and prevention of misappropriation of resident property.
