Failure to Maintain Complete Controlled Substance Records for Hospice Residents on PRN Morphine
Summary
The deficiency involves the facility’s failure to maintain complete and accurate medical records and controlled substance documentation for two hospice residents receiving PRN morphine for pain and shortness of breath. For Resident #2, a female with diagnoses including nontraumatic intracerebral hemorrhage, depression, adult failure to thrive, altered mental status, and functional quadriplegia, the clinical record showed she was on hospice services with a terminal prognosis and had an active PRN order for morphine sulfate concentrate 20 mg/mL, 0.25 mL by mouth every 4 hours as needed for pain. Her quarterly MDS documented intact cognition (BIMS 12), pain management, and receipt of a scheduled pain regimen. Her care plan included interventions to administer medications as ordered and to work with hospice to provide maximum comfort. Despite this, surveyor review and staff interviews revealed that there was no hardcopy Individual Narcotic Record or medication administration/destruction record for her ordered PRN morphine. During an observation and interview, an RN checked medication cart #1, the narcotic binder, and the electronic medical record for Resident #2 and confirmed there was one active PRN morphine order but no PRN morphine stored in the cart for her and no Individual Narcotic Record. The DON later stated that the PRN morphine order for Resident #2 had not been discontinued by the provider, yet she could not locate the Individual Narcotic Record, the medication administration record, the destruction record, or the morphine itself. She reported believing that the pharmacy may have made an error and that the medication was never received, and indicated she would contact the pharmacy for delivery receipts. These findings showed that the facility did not maintain the required controlled substance accountability records or complete documentation for this resident’s ordered narcotic medication. For Resident #3, a male with diagnoses including COPD, cognitive communication deficit, rheumatoid arthritis, adult failure to thrive, and muscle wasting and atrophy, the record showed he was also on hospice services with a terminal prognosis. His quarterly MDS documented intact cognition (BIMS 12), pain management, a scheduled pain regimen, shortness of breath, and a condition that could result in life expectancy of less than six months. His care plan directed staff to administer pain medication as ordered and to work cooperatively with hospice. His active orders included morphine sulfate concentrate oral solution 100 mg/5 mL, 0.25 mL sublingually every 3 hours as needed for pain/shortness of breath (5 mg), and a separate order for morphine sulfate concentrate 20 mg/mL, 10 mg by mouth every 3 hours as needed for pain (0.5 mL = 10 mg). When LVN A reviewed medication cart #2, the narcotic binder, and the electronic medical record, she found no hardcopy Individual Narcotic Record for either of Resident #3’s PRN morphine orders. She recalled that the resident’s spouse did not want him on morphine and wanted it discontinued sometime in January, but she was not aware of any documentation supporting that conversation. The DON confirmed that the PRN morphine orders for Resident #3 had not been discontinued by the provider and that she could not locate the Individual Narcotic Record. These findings, together with facility policies requiring accurate, complete medical records and specific controlled substance accountability documentation, demonstrate that the facility failed to maintain proper medication administration and controlled substance records for both residents’ ordered narcotics. The facility’s own policies titled “Medication Administration,” “Documentation in Medical Record,” and “Medication Storage and Disposal” required that medications be administered as ordered, that controlled substances be signed out in the narcotic book, that discrepancies be corrected and reported to the nurse manager, and that each resident’s medical record contain accurate, complete, and timely documentation sufficient to depict the resident’s care and responses. The controlled substance policy further required that all controlled substances be subject to special handling, storage, disposal, and recordkeeping, and that any disposition or destruction be documented on the individual controlled substance accountability record with specific details and witness signatures. In the cases of Resident #2 and Resident #3, the absence of Individual Narcotic Records, medication administration/destruction records, and, for Resident #2, the inability to locate the morphine itself, showed that these policies and accepted professional standards for medical recordkeeping and controlled substance accountability were not followed.
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