Failure to Ensure Nursing Competency in Respiratory Care and Safe Narcotic Management
Summary
The deficiency involves the facility’s failure to ensure that licensed nursing staff, including nursing leadership, possessed the competencies and skills necessary to provide specialized respiratory care and safe medication practices, as required by facility policy. The facility’s competency policy required managers to ensure job-specific training and competency validation on hire, annually, upon changes in duties or processes, and when performance concerns were identified, with documentation of training and validation. Despite this, surveyors found that staff providing tracheostomy and respiratory care lacked documented competencies in these areas, and that the Director of Nursing did not carry out required oversight functions related to investigation of incidents, physician notification, and corrective actions. For one resident with throat cancer, a tracheostomy, and HIV, the Minimum Data Set documented that the resident was cognitively intact, required substantial to maximal assistance with activities of daily living, and received suctioning and tracheostomy care. Physician orders required tracheostomy care every shift and as needed. During observations on two separate dates, the resident’s tracheostomy setup included an uncovered suction catheter lying on top of a suction canister containing cloudy fluid, with no dates on tubing or equipment, and later the same setup was seen unchanged with a used urinal directly below and an undated water bottle connected to the tracheostomy collar. The care plan called for an Ambu bag at bedside, but no Ambu bag was present. The resident reported that tracheostomy care and suctioning were not being performed, that staff were not skilled to perform it, and that they did not offer the care. When interviewed, an LPN stated they had performed tracheostomy care for this resident on a specific date, but the supplies in the room appeared unchanged from prior observations. The LPN was unable to locate necessary supplies, could not describe full tracheostomy care, and stated they had required additional training to be competent in proper tracheostomy care. Review of the Treatment Administration Record showed inconsistent documentation of ordered tracheostomy care across shifts, with multiple staff initials and variability in completion, and included directions to encourage the resident to allow staff or self-clean, which was inconsistent with the resident’s documented need for skilled nursing interventions. The LPN’s competency records showed validation for infection control, medication administration, and blood glucose monitoring, but no documented competency validation for tracheostomy care or respiratory equipment management. For another resident with head and neck cancer, an artificial laryngectomy tube, and cirrhosis, the care plan identified pain management needs and respiratory needs related to the artificial airway, including monitoring respiratory status, observing for signs of respiratory distress or changes in secretions, and providing suctioning as ordered. The Medication Administration Record documented that a narcotic pain medication had been administered by an RN and that pain was reassessed and evaluated as effective, with no incident documented in the medical record. However, an incident statement later documented that the RN had placed a crushed narcotic in a medication cup in the resident’s room, left it unattended, and upon return found the medication missing. The RN assumed the resident had taken the medication, confronted the resident, and the resident denied taking it, yet the MAR for the surrounding dates documented the narcotic as administered by the RN. The facility’s narcotic management policy required that all narcotics be secured, accounted for, and discrepancies immediately reported to the Director of Nursing, and the notifications and accident/incident policies required prompt reporting, investigation, and physician notification of incidents and adverse events. The Medical Director stated they were not notified of the narcotic discrepancy and that the medication should not have been documented as administered if the facts were unclear. A law officer reported that they had deferred further action based on the DON’s assurance that the facility would conduct an internal investigation. The DON acknowledged responsibility for oversight of clinical care and investigations but did not provide evidence that a complete investigation was conducted, and there was no documentation of staff interviews, fact-finding, determination of cause, or corrective actions. There was also no evidence that the resident’s physician was notified of the missing narcotic or the allegation that the resident consumed the medication, no documentation of disciplinary or performance action for the nurse involved, and no evidence that performance concerns led to competency evaluation or retraining. Additionally, although the care plan identified airway management and monitoring needs for this resident, physician orders did not reflect airway management needs or emergency equipment. These findings collectively demonstrated that the facility failed to ensure nursing staff competency in respiratory care, safe medication practices, and appropriate investigation and physician notification, as required by policy and regulation.
Penalty
Resources
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