QAPI Failed to Recognize Repeated Sexual Abuse Patterns
Summary
The facility failed to maintain effective QAPI and QAA oversight for repeated resident-to-resident sexual abuse and sexually inappropriate behaviors on the secured memory care unit. Facility policies reviewed stated that abuse must be identified, prevented, reported, and coordinated through the QAPI program, including analysis of why abuse occurred, review of risk factors, and tracking of similar occurrences. Despite those policies, the QAA committee continued the same approach to each interaction and did not identify the resident’s behavior as sexual abuse activity, even though the behavior was repeatedly documented and observed. Resident #49 had diagnoses including Alzheimer’s disease, traumatic brain injury, and delusional disorder, and MDS assessments showed severe cognitive impairment with inability to complete BIMS and behaviors including sexually abusing others, public sexual acts, and disrobing in public. Nurse progress notes documented public sexual acts repeatedly from 11/11/2025 through 3/24/2026, including 3 occurrences in 11/2025, 3 in 12/2025, 1 in 1/2026, 4 in 2/2026, and 17 in 3/2026. The report states the QAA committee failed to recognize the pattern and extent of these incidents and failed to implement interventions in response to each occurrence. Resident #88 had vascular dementia, severe agitation, delusional disorders, and adjustment disorder with mixed anxiety and depressed mood, and a quarterly MDS showed a BIMS score of 0 indicating severe cognitive impairment. Resident #15 had vascular dementia, adjustment disorder with mixed anxiety and depressed mood, and delusional disorder, and a significant change MDS showed severe impairment in cognitive skills for daily decision making. During the survey, staff and surveyors observed and confirmed repeated inappropriate sexual contact involving Resident #49 and these cognitively impaired residents, including kissing, touching of the chest and buttocks, and exposure of breasts. Staff also reported Resident #49 touched staff members and surveyors inappropriately. The DON stated she viewed the resident as a "Huggy, Touchy, and Feely person" and did not consider the acts sexually inappropriate or sexual abuse, while the Administrator stated the IDT had not formally discussed the residents’ specific sexually inappropriate or abusive behaviors and the facility had not identified sexual abuse on the memory care unit as an area needing to be addressed.
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