Failure to Implement Non-Pharmacological Interventions Before Ordering Antipsychotic for Insomnia
Summary
The deficiency involves the facility’s failure to ensure a resident’s drug regimen was free from unnecessary drugs by not developing and implementing non-pharmacological interventions prior to ordering an antipsychotic medication for insomnia. The resident had diagnoses including PTSD, bipolar disorder, anxiety disorder, and depression, and was cognitively intact on both admission and significant change MDS assessments. These assessments documented that the resident reported trouble falling or staying asleep for 7–11 days in the look-back periods, frequent moderate pain that occasionally affected sleep, and receipt of multiple medications including antidepressants, opioids, and other high-risk drugs. The care plan for insomnia, initiated shortly after admission, listed only general interventions such as administering medications per order and monitoring for causes of insomnia like medications, caffeine, overstimulation, depression, and anxiety, without individualized identification of the resident’s insomnia symptoms related to bipolar disorder or specific non-pharmacological strategies. The resident’s medication regimen included amitriptyline and trazodone for depression and insomnia, and quetiapine, an antipsychotic, ordered as needed for insomnia. Hospital discharge orders on one occasion included quetiapine 25 mg at bedtime daily for insomnia, and on readmission the NP continued quetiapine 25 mg every 24 hours PRN for insomnia for 14 days, in addition to trazodone 50 mg at bedtime for insomnia. The clinical record did not document behaviors related to bipolar disorder that would support antipsychotic use, nor did it show that non-pharmacological interventions were attempted or implemented before adding or continuing quetiapine for insomnia. The care plan for mood fluctuation focused on administering medications and monitoring for side effects and signs of mania or hypomania, but did not address specific behavioral or environmental approaches to manage insomnia. Staff interviews further showed a lack of documented insomnia or behavioral issues that would justify the PRN antipsychotic for sleep. Nursing and QMA staff reported they had not observed the resident having difficulty sleeping or significant behaviors; one LPN described the resident as becoming antsy when medications or call light responses were not immediate, but also noted the resident calmed with listening and conversation. Another CNA reported that prior to a hospital stay the resident occasionally had difficulty sleeping and woke up angry, but since returning had no sleep problems. The medication administration records for the relevant months showed the resident did not receive any doses of the PRN quetiapine. Despite this, the NP and DON discussed and chose to keep the quetiapine order in place after hospital discharge because it had been used in the hospital for insomnia, even though the FDA-approved indications for quetiapine do not include insomnia and the facility’s psychotropic medication policy requires that such drugs only be used when necessary to treat a specific or suspected condition per current standards of practice.
Penalty
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A resident with COPD, anxiety, and PTSD had a PRN morphine order for severe pain related to COPD, but the CNO stated she did not know what the appropriate indication for the order should be. The facility failed to ensure the medication was administered with an appropriate clinical indication.
A resident with osteomyelitis, a clavicle fracture, and a history of addiction received changing orders for Suboxone and oxycodone, including concurrent use for pain and OUD. The DON stated she questioned why Suboxone and oxycodone were being given together because Suboxone can block oxycodone’s effects, and the MD stated a 10 mg oxycodone dose would provide only a placebo effect for a resident taking Suboxone.
A resident’s chlorhexidine mouthwash remained at the bedside after the order had expired, despite no current order being in place. Facility policy stated nursing staff would remove expired or discontinued meds from bedside stock, but observation found the prescription mouthwash on the bedside table with no lock box or locked drawer. An LPN was unsure why it had not been removed, and the DON confirmed the last order had ended and no new order had been obtained.
A resident with dementia, schizoaffective disorder, and anxiety disorder had a donepezil HCL order listed for “cognitive impairment” instead of dementia. RN and RNS both verified the order and stated the diagnosis used as the indication was incorrect, and the facility policy required a diagnosis to justify medication use.
A resident with overactive bladder was given Macrobid for a presumed UTI after staff reported dysuria, confusion, and increased urination, but the urine culture grew only 10,000-50,000 CFU/ml of E. coli, below the threshold used to define a symptomatic UTI. The record showed no clear evidence of urinary symptoms in the surrounding progress notes, and facility leadership confirmed the culture did not meet the amount of growth required to justify antibiotic use.
Failure to monitor anticoagulant therapy: A resident with quadriplegia, seizures, and HTN was prescribed apixaban 5 mg BID, but the EMR did not include an order for anticoagulant monitoring and nursing documentation did not show daily monitoring for side effects with administration. The care plan called for monitoring, documenting, and reporting signs of anticoagulant complications, and the DON and ADM acknowledged the missing monitoring order in the EMR.
Unclear Clinical Indication for PRN Morphine Order
Penalty
Summary
The facility failed to ensure medications were administered with an appropriate clinical indication for one resident reviewed for unnecessary medications. Resident #23 was admitted with multiple diagnoses including COPD, anxiety, and PTSD. The resident’s care plan, revised 3/2/26, stated to give medications as ordered by the physician. The physician orders included Morphine Sulfate 20 mg/mL, 0.25 mL by mouth every 6 hours as needed for severe pain related to COPD, initiated on 7/7/26. During interview on 7/9/26 at 2:45 PM, the CNO stated she did not know what the appropriate indication for the morphine order should be.
Unnecessary Concurrent Use of Suboxone and Oxycodone
Penalty
Summary
The facility failed to ensure that one resident’s drug regimen was free from unnecessary medications. The resident was admitted with diagnoses of acute osteomyelitis of the right ankle and a fracture of the left clavicle, and the care plan identified a history of addiction with risk for substance use. The hospital discharge medication summary listed buprenorphine-naloxone 4 mg every 4 hours, lidocaine patches for pain, and methocarbamol 750 mg three times daily. Physician orders later showed multiple changes to the resident’s pain and OUD-related medications, including buprenorphine-naloxone for opioid use disorder, oxycodone ER 10 mg every 12 hours for moderate to severe pain, discontinuation and reordering of buprenorphine-naloxone, and then buprenorphine-naloxone every 4 hours for pain for three days followed by oxycodone ER 10 mg every 12 hours. During interviews, the DON stated Suboxone prescriptions were reviewed by Physician #1 and that she questioned why some residents were receiving Suboxone and oxycodone together because Suboxone can block oxycodone’s intended effects. The MD stated he worked closely with Physician #1, did not prescribe Suboxone or oxycodone, and said residents taking Suboxone would need high amounts of oxycodone to receive pain relief; he stated a 10 mg dose would provide only a placebo effect.
Unremoved Discontinued Mouthwash at Bedside
Penalty
Summary
The facility failed to ensure a resident’s drug regimen was free from unnecessary drugs when chlorhexidine mouthwash was not discontinued from the resident’s bedside after the physician-ordered end date. Review of the facility policy for self-administration of medications stated nursing staff would rotate bedside stock and remove expired, discontinued, or recalled medications. Review of the resident’s active orders showed no current order for chlorhexidine mouthwash, and the MAR showed three past orders for chlorhexidine gluconate 0.12% mouthwash, each with an end date that had passed. The resident’s quarterly MDS showed a BIMS score of 15 out of 15, indicating no cognitive deficits, and her diagnoses included dental caries, right-sided hemiplegia, visual loss in the right eye, cognitive communication deficit, and a history of traumatic brain injury. During observation, a bottle of prescription chlorhexidine mouthwash was found on the resident’s bedside table while the resident was not in the building, and no lock box or lock on the bedside drawer was observed. An LPN stated the resident kept the mouthwash at her bedside and was unsure why it had not been removed when the order ended. The DON confirmed there was no current order for the mouthwash and that the last order had ended, and the Administrator stated there should have been an order to continue the mouthwash or it should have been removed from the bedside. The DON later confirmed no new order had been obtained and the medication should have been removed when the last order expired.
Incorrect indication documented for donepezil order
Penalty
Summary
The facility failed to ensure that one sampled resident was free from an unnecessary drug because the resident’s donepezil hydrochloride order did not list an accurate indication for use. Resident 57 was admitted with diagnoses including dementia, schizoaffective disorder, and anxiety disorder, and the MDS indicated severely impaired cognitive skills for daily decision making, along with extensive assistance needs for activities of daily living. The order summary showed donepezil hydrochloride 5 mg at bedtime ordered for “cognitive impairment.” During record review and interviews, RN 2 and RNS 1 both verified the order and stated that the indication was incorrect and should have been dementia rather than cognitive impairment. The facility policy on unnecessary drugs stated that medications should be carried out with dosage, route, frequency, and diagnosis to justify medication use.
Unnecessary antibiotic given for unsupported UTI
Penalty
Summary
The facility failed to ensure that a resident’s drug regimen was free from unnecessary drugs when it administered Macrobid for a urinary tract infection that was not supported by the documented culture results. Resident 42 had a diagnosis of overactive bladder and had been seen for urinary frequency and urgency, with the Myrbetriq dose increased from 25 mg to 50 mg. Later, the provider documented frequency and burning sensations and ordered a urinalysis with reflex culture for dysuria, even though progress notes from the surrounding period did not show evidence of urinary frequency, urgency, or painful urination. The urinalysis was obtained and the facility was notified that it was positive for infection, after which Macrobid 100 mg twice daily for 7 days was ordered for a diagnosis of UTI. However, the urine culture final result showed 10,000-50,000 CFU/ml of Escherichia coli, which was below the 100,000 CFU/ml threshold referenced in the CDC NHSN LTC UTI criteria for defining a non-catheter associated symptomatic UTI. The facility administrator and infection preventionist confirmed that the culture did not meet the required amount of bacterial growth to constitute an infection necessitating antibiotic use. Progress notes after the antibiotic was started documented mixed urinary symptoms, including denial of burning or painful urination and reports that frequency had improved or subsided. Observations of the resident on subsequent days showed repeated trips to the bathroom and use of the toilet, including episodes of very frequent bathroom use within minutes of each other. During interview, facility leadership stated staff had reported the resident was more confused, had dysuria, and had increased urination before the provider visit, and that this information was relayed to the provider, leading to the urinalysis order.
Failure to Monitor Anticoagulant Therapy
Penalty
Summary
The facility failed to ensure that one resident's drug regimen was free from unnecessary medication by not monitoring the resident for side effects of apixaban. Resident #10 was a male admitted with diagnoses including quadriplegia, seizures, and hypertension, and his quarterly MDS showed a BIMS score of 15, indicating intact cognition. Physician orders dated 06/24/2026 showed he was prescribed apixaban 5 mg by mouth twice daily, and the orders did not address monitoring of the anticoagulant. The MAR showed the medication was administered as ordered from 06/01/2026 through 06/23/2026. The resident's care plan, dated 01/07/2026, identified that he was on anticoagulant therapy and included interventions to monitor, document, and report signs or symptoms of anticoagulant complications. However, review of the electronic medical record did not show nursing documentation of daily monitoring for side effects of the anticoagulant with medication administration. During interview, the DON stated the purpose of monitoring anticoagulation was to ensure there was no uncontrolled bleeding and acknowledged there was no order for monitoring in the EMR. The ADM also stated the resident did not have an anticoagulant monitoring order and that the DON was responsible for ensuring orders were entered into the EMR. The facility policy titled, Anticoagulation - Clinical Protocol, stated staff and physician would monitor for possible complications in individuals being anticoagulated.
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