Failure to Meet 3.0 PPD and Facility-Defined Staffing Ratios
Summary
The deficiency involves the facility’s failure to provide sufficient nursing staff to meet Connecticut Public Health Code minimum staffing requirements of 3.0 PPD and to follow its own facility assessment staffing ratios. On multiple reviewed days, the facility’s actual worked hours for licensed nurses and nurse aides (NAs) between 7:00 AM and 9:00 PM were below the required combined and licensed PPD hours for the census. For a census of 112 residents on a Saturday, the facility provided 238 combined PPD hours instead of the required 243.04, resulting in a 5.04-hour shortfall. On a Sunday with the same census, the facility provided 232 combined PPD hours instead of 243.04, with an 11.04-hour combined shortfall and a 1.84-hour shortfall in licensed hours alone. On a Monday with a census of 108 residents, the facility provided 216 combined PPD hours instead of the required 234.36, with a 5.56-hour shortfall in licensed hours and an 18.36-hour shortfall in combined hours. The facility also failed to meet its own staffing compliance grid and facility assessment ratios for specific shifts and units. For census ranges of 110–114 and 100–104, the facility’s staffing compliance guidelines required specific numbers of RN/LPNs and NAs on the 7 AM–3 PM and 3 PM–11 PM shifts, but the reviewed schedules showed shortages of NAs and RN/LPNs on several of those shifts. On the secured unit, which had a capacity of 35 and a daily census of 34, only 3 NAs were assigned, whereas the facility assessment’s NA-to-resident ratio (1:8–10 on days, 1:10–15 on evenings, 1:20–25 on nights) would have required 4 NAs for that census, resulting in a shortage of 1 NA on that unit. The facility assessment also called for 1 RN supervisor on each shift and licensed nurse-to-resident ratios of 1:30–35 on days and evenings and 1:40 on nights. Incident and interview data further reflected the staffing concerns and how staffing decisions were made. Accident and incident tracking showed multiple unwitnessed falls or injuries in the months reviewed, including 10 unwitnessed falls in November (with one on the secured unit on the cited Saturday), 20 unwitnessed incidents in January (with 3 before 9 PM on the cited Sunday, including one on the secured unit), and 14 unwitnessed incidents in April (with 1 on the cited Monday). On one of the understaffed days, the ADNS and DNS were pulled from their administrative roles to staff units, but the DNS time sheet still recorded the day as DNS hours rather than RN supervisor hours, and the DNS could not recall her main duties that day. The HR director, responsible for PBJ submissions, acknowledged low weekend staffing in prior months but could not state whether the facility was currently short-staffed and did not provide the updated staffing form. The scheduler reported that she filled schedules based on the administrator’s direction and did not calculate staffing based on PPD requirements or know the required hours per resident. The administrator stated awareness of the 3.0 staffing requirement but was not familiar with the specific hours-per-resident requirements and relied on corporate guidance, and nursing assistants reported that their assignments sometimes exceeded 10 residents per NA and that they could use additional NAs.
Penalty
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