Unauthorized Use and Poor Accounting of Resident Trust Funds
Summary
The deficiency involves the facility’s failure to properly manage resident personal funds, including making unauthorized purchases from resident trust accounts and failing to provide required quarterly account statements. For multiple residents, surveyors identified debits to online retailers that were not signed or authorized by the residents or their representatives, despite facility policy requiring such authorization via vouchers or check request forms. The facility also did not document that quarterly resident fund statements were sent to the residents or their representatives for the fourth quarter of 2025 and the first quarter of 2026. One affected resident had congestive heart failure, Alzheimer’s disease, and aphasia, was severely cognitively impaired, and required staff assistance with ADLs. This resident’s fund statement showed debits for online retailer purchases in specific amounts on two dates, and the resident’s representative had not authorized these transactions. The Administrator verified that these purchases were made from the resident’s funds without authorization and confirmed that quarterly statements for the relevant quarters had not been provided to the resident or representative. Another resident, cognitively intact with type 2 diabetes mellitus, PTSD, and osteoarthritis, had a substantial increase in account balance over a quarter, yet there was no documentation that quarterly statements were sent, which the Administrator also confirmed. Additional residents with varying levels of cognitive impairment and medical conditions, including type 2 diabetes mellitus, pulmonary hypertension, generalized anxiety disorder, epilepsy, end stage renal disease, aphasia following cerebral infarction, anxiety disorder, cerebral infarction, and Alzheimer’s disease, were similarly affected. Their quarterly fund statements showed multiple debits to an online retailer on various dates and in specific amounts, none of which were signed or authorized by the residents or their representatives. For each of these residents, record review showed no documentation that quarterly statements for the fourth quarter of 2025 or the first quarter of 2026 were sent, and in interviews, the Administrator consistently verified both the unauthorized nature of the purchases and the failure to provide the required quarterly statements. Review of the facility’s undated Resident Trust Funds policy showed that resident fund withdrawals were supposed to be supported by signed vouchers or check request forms and invoices, which was not followed in these cases. Across all six residents reviewed for this issue, the survey findings demonstrated that the facility did not maintain resident fund accounts using basic accounting principles as required by its own policy. Unauthorized online purchases were repeatedly charged to resident accounts without the required signatures or documented consent, and there was a systemic lack of documentation that quarterly fund statements were provided to residents or their representatives for two consecutive quarters. These actions and omissions formed the basis of the cited deficiency related to the management and safeguarding of resident personal funds.
Penalty
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The facility failed to provide required quarterly trust account statements to multiple residents and a responsible party whose personal funds were managed in facility-held trust accounts. Several alert and oriented residents reported not receiving any quarterly statements despite having active trust accounts, including residents with documented capacity to make decisions and one with a BIMS score indicating intact cognition. Another resident’s responsible party reported never receiving statements for her family member’s trust account, even though the resident had severe cognitive impairment and the RP was designated to manage finances. The BOM stated that statements were only provided upon request and that none had been issued since his employment began, while the ADM stated statements were supposed to be automatically mailed but acknowledged there was no procedure to ensure they were sent or received, and no relevant policies were produced when requested.
The facility did not provide required quarterly financial statements to multiple residents who maintained personal fund accounts. Several residents reported having resident accounts but stated they were unaware of their account activity or balances because they had not received statements for the prior three months or upon request. The Administrator confirmed that quarterly statements were not being issued to these residents, resulting in noncompliance with state requirements for management of residents’ personal funds.
The facility failed to maintain complete and accurate accounting records for multiple residents’ personal funds held in a commingled trust account. Resident trust statements only showed balances without itemized deposits or withdrawals, and did not reflect any allocation of interest earned. Bank statements for the checking and savings accounts listed deposits under a single resident’s name and did not document other residents’ debits or credits, despite several residents having funds managed by the facility. An activity director reported managing several residents’ funds, paying for items like haircuts by check, but did not know how to record deposits and withdrawals in the electronic system, resulting in records that did not match bank statements. The Administrator confirmed that a sister facility’s business office handled deposits and transfers and acknowledged that the facility lacked proper tracking and individual ledgers for resident expenditures.
The facility failed to provide required quarterly written statements and maintain accurate records for resident trust fund accounts. A resident with intact cognition and mental health diagnoses reported never receiving a balance statement, not knowing her account balance, and only receiving partial funds when requesting money for bills, with no access to funds on weekends. Two other residents with cognitive communication deficits and cognitive impairment stated they were supposed to receive $75 monthly but were not given the full amount when requested, limiting their ability to purchase food. The ADM and a director confirmed the facility had not been keeping records of personal funds, including quarterly statements and withdrawals, and could not produce accurate trust fund statements or documentation of disbursements, despite a policy requiring documentation of all transactions and quarterly statements.
Quarterly resident trust account statements were not verified for two residents. Both residents stated they had not received statements showing their account balances, and the BOA could not provide verification after the former BOM left the position. Only a letter showing the quarter ending balance for one quarter was later produced for each resident, with no additional statement proof available.
Failure to Provide Resident Trust Account Statements A resident with HF, HTN, renal insufficiency, DM, and schizophrenia was responsible for having the facility manage personal funds, but stated they had no idea what was happening with the account and that the facility received the statements. The BOM said monthly statements were received at the resident’s request and then explained and provided, but there was no documentation confirming the conversations or explanations, and the record lacked evidence that statements were provided or agreed to.
Failure to Provide Quarterly Trust Account Statements to Residents and Representatives
Penalty
Summary
The deficiency involves the facility’s failure to provide required quarterly trust account statements to residents or their responsible parties (RPs) for resident funds managed by the facility. Surveyors interviewed multiple residents and an RP and reviewed medical and financial records. One resident, who was alert and oriented at the time of interview, stated he did not have a bank account or receive mail at the facility, but record review showed his trust account with the facility was opened on November 26, 2025, and his BIMS score indicated severe cognitive impairment. Another resident, alert and oriented, reported that her Social Security checks were sent directly to the facility and that she had a share-of-cost obligation, but she did not receive quarterly statements to track deposits and withdrawals; records showed her trust account was opened on August 1, 2024, and she had capacity to make decisions. A third resident, cognitively intact with a BIMS score of 14, stated he had not received quarterly statements for his trust account, which records showed was opened on November 30, 2018. A fourth resident, who had capacity to make decisions per the history and physical, stated he was unaware if he had a trust account and had not received a quarterly trust account statement, despite records indicating his trust account was opened on September 15, 2025. A fifth resident was alert but nonresponsive and could not be interviewed; her medical record showed severe cognitive impairment with a BIMS score of 0, and that her daughter was the RP. In a phone interview, the RP stated she had never received quarterly statements for this resident’s trust account, which had been opened on September 1, 2024. During a concurrent interview and record review, the Business Office Manager (BOM) stated that the facility’s process was to provide quarterly trust account statements only upon demand request by the resident or RP, and further stated that since his employment began on February 17, 2026, the business office had never provided quarterly trust account statements to residents or RPs. The Administrator later stated that quarterly statements were supposed to be automatically mailed from the business office, but acknowledged there was no procedure in place to ensure residents or RPs actually received the statements and confirmed with the corporate Director of Accounts Receivable that residents or RPs should have been receiving quarterly trust account statements. When policies related to resident trust accounts and quarterly statements were requested, the facility did not provide them.
Failure to Provide Required Quarterly Resident Account Statements
Penalty
Summary
The facility failed to properly manage residents’ personal funds by not providing required financial statements to residents with active accounts. During interviews conducted on April 23, 2026, between 11:00 a.m. and 3:00 p.m., five of eleven sampled residents (Residents 2, 3, 5, 7, and 11) reported that they had resident trust accounts but were unaware of their account activity or total balances because they had not received quarterly statements reflecting the last three months of transactions. These residents also had not received statements upon request. In a subsequent interview on April 23, 2026, at 3:30 p.m., the Administrator confirmed that quarterly financial statements were not being provided to these residents, constituting noncompliance with 28 Pa. Code 201.18(b)(2)(3) regarding management of residents’ personal funds. No additional medical history or clinical conditions for the involved residents were described in the report.
Failure to Maintain Accurate Accounting Records for Resident Trust Funds
Penalty
Summary
The facility failed to properly maintain complete and accurate accounting records for resident personal funds held in a commingled trust account for ten residents. Trust statements provided for these residents only showed a single balance figure without any itemized accounting of deposits (credits) or withdrawals (debits), and did not identify or allocate any interest earned on the funds. Individual balances ranged from small positive amounts to a negative balance for one resident, but there was no supporting transaction detail. Review of the facility checking account statements over several months showed deposits recorded only under one resident’s name, with no documentation of other residents’ debits or credits, despite multiple residents having funds managed by the facility. The related business savings account showed minimal interest earnings, but there was no evidence that this interest was tracked or attributed to individual residents’ accounts. During interviews, the activity director reported managing funds for seven residents but stated she did not have access to the bank account and believed it was a non–interest-bearing account. She described paying for resident items such as haircuts by check and then giving the checks to the Administrator, and acknowledged that although the electronic record system had an area to record deposits and withdrawals, she did not know how to use it, resulting in records that did not match the bank statements. She also stated she printed and mailed balance-only statements to families every three months. The Administrator reported that a business office staff member at a sister facility handled deposits into savings and transfers to checking, and acknowledged that the bank statements only reflected one resident’s name and that the facility lacked appropriate education and systems to track and deposit resident funds with individual ledgers showing each resident’s expenditures.
Failure to Provide Quarterly Trust Fund Statements and Maintain Accurate Personal Funds Records
Penalty
Summary
The deficiency involves the facility’s failure to properly manage and document residents’ personal trust funds, including not providing required quarterly written statements for three residents with accounts held by the facility. One cognitively intact resident with major depressive disorder and generalized anxiety disorder reported having a trust fund but stated she never received a balance statement and did not know how much money she had, suggesting this had been occurring since the prior year. She reported having to ask the facility for money to pay her phone bill and only receiving whatever amount staff said was available, without being able to obtain the full amount requested, and stated she could not request money on weekends. Two other residents with cognitive communication deficits and varying levels of cognitive impairment reported they were supposed to receive $75 per month but were not given the full amount when requested. One resident stated he did not receive the full $75 at once despite asking, which affected his ability to buy outside food. Another resident stated she was supposed to get $75 per month, but the facility would not give her the full amount because the facility would “run out,” and she used extra money to pay for food. In an interview, the Administrator and Director of Special Projects acknowledged the facility had not been keeping records of residents’ personal funds, including quarterly statements and withdrawals, and that they could not print accurate trust fund statements or provide evidence of money disbursements because trust fund transactions were not being accurately recorded, contrary to the facility’s written policy requiring documentation of all withdrawals and provision of quarterly written statements.
Quarterly resident trust account statements not verified
Penalty
Summary
Properly hold, secure, and manage each resident's personal money deposited with the nursing home was not ensured for two residents because quarterly statements were not provided or could not be verified. Resident #41 and the resident's daughter stated they had not received a quarterly statement showing the amount in the resident's account. The Business Office Advisor said the former Business Office Manager had left and she did not think she could verify that quarterly statements had been provided. A letter dated 07/23/25 was later provided showing a quarterly statement for the quarter ending June 2025, but no additional statements could be produced. Resident #24 also stated she had not received a quarterly statement showing the amount of money in her account. The Business Office Advisor again stated she could not provide any quarterly statement verifications because the former Business Office Manager had recently left the position. A letter dated 07/23/25 was later provided showing that Resident #24 had received a letter indicating the account balance for the quarter ending June 2025, but no additional statement verifications were available before the end of the survey.
Failure to Provide Resident Trust Account Statements
Penalty
Summary
The facility failed to provide quarterly statements to 1 of 1 resident reviewed for personal funds, R36. R36’s MDS dated [DATE] showed the resident was admitted [DATE], cognitively intact, and had diagnoses including heart failure, hypertension, renal insufficiency, diabetes, and schizophrenia. During an interview on 3/23/26, R36 stated the facility was responsible for managing their money, but they had no idea what was going on with the account and the facility received their statements. On 3/26/26, the BOM stated the facility received monthly statements at the resident’s request and then met with the resident to explain and provide the documents, but there was no documentation to confirm those conversations or explanations occurred. R36’s medical record lacked evidence of agreement or that statements were provided or explained to the resident. The facility’s Resident Trust Account Policy stated the facility, as fiduciary of resident funds, must hold, safeguard, manage, and account for the funds in accordance with state and federal regulation.
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