Failure to Properly Offer, Obtain Consent for, and Document Pneumococcal and Influenza Vaccinations
Summary
The deficiency involves the facility’s failure to ensure residents were appropriately offered and documented for pneumococcal and influenza vaccinations upon admission, as required by facility policy. The facility’s influenza policy states that all residents are to be offered and encouraged to obtain annual influenza immunization, with consent, education on risks and benefits, and documentation of receipt or refusal on the medication administration record. The pneumococcal vaccine policy states that all residents are encouraged to obtain PPSV23 and PCV vaccines (PCV15 or PCV20). Despite these policies, record review and interviews showed that residents were not consistently offered pneumococcal vaccines upon admission, and there was missing or inaccurate documentation of both pneumococcal and influenza vaccines. One resident admitted in 2017 had documentation of PPSV23 in 2017 and was eligible later for PCV20 or PCV21 and then PCV15, but the medical record at admission did not show that these vaccines were offered. This resident signed a consent form for PPSV23 in March 2026, but the form documented administration of PCV20, and there was no evidence the resident had been offered or consented to PCV20 upon admission. Another resident admitted in 2019 had PPSV23 documented in 2019 and was similarly eligible for PCV20 or PCV21 and then PCV15, yet there was no documentation that these vaccines were offered upon admission. This resident also signed a consent form for PPSV23 in March 2026, but the form documented administration of PCV20, again without documentation that PCV20 or PCV21 had been offered at admission or that the resident consented specifically to PCV20. A third resident’s record contained no documentation of any pneumococcal vaccines and no documentation that the influenza vaccine was offered, despite the stated process of reviewing the Wisconsin Immunization Registry, screening for vaccine history, and obtaining consent with education on risks and benefits. Another resident’s medical record did not document any pneumococcal vaccines; later, a pneumonia vaccine consent form was signed for PPSV23, but the form documented administration of PCV20, and there was no evidence that PCV20 or PCV21 had been offered upon admission or that the resident consented to PCV20. A fifth resident had PPSV23 documented in 2019 and would have been eligible for PCV20 or PCV21 and then PCV15, but there was no documentation these were offered upon admission; this resident also signed a consent for PPSV23, while the form documented PCV20 administration without documented consent for PCV20. Throughout interviews, the ADON stated that admissions are reviewed in the Wisconsin Immunization Registry and residents are screened and offered required vaccines, but also acknowledged that PCV vaccines had not been administered for the last couple of years and that this was the first year PCV had been ordered.
Penalty
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Incomplete pneumococcal vaccine documentation was identified for three residents. The facility policy required admission review of prior immunizations and documentation in the EHR, but records for residents with DM, HTN, CAD, MS, and COPD showed pneumococcal status coded as not up to date and not offered, while the immunization entries listed consent not obtained or status to be determined, with education not checked for two residents and no documented evidence that vaccine status was discussed with the attending physician for one resident. The DON acknowledged the facility failed to provide accurate and timely documentation related to the pneumonia vaccine.
The facility failed to consistently educate, offer, or administer influenza and pneumococcal vaccines for multiple residents. Records for one resident did not clearly show prior vaccine history or eligibility, another resident had no evidence of shared decision making or additional pneumococcal vaccination, and a third resident’s consent was incomplete and lacked documentation of vaccination. The IP nurse stated she handled MIIC review and PCC entry herself and that vaccine review was behind during a period when she was also serving as DON.
Pneumococcal immunization education and offer process deficient: The facility did not provide accurate education about current CDC guidance for PCV20/PCV21 and did not ensure that eligible residents were reoffered pneumococcal vaccine during ongoing stay. One resident’s declination form incorrectly stated no further vaccine was needed after PCV13 and PPSV23, another resident’s son declined based on outdated information, and two other residents had no evidence of a later vaccine offer after becoming eligible.
Failure to Offer Recommended Pneumococcal Vaccinations: The facility did not document offering the recommended pneumococcal vaccine to three residents who had prior pneumococcal immunizations. EMR review showed one resident had received PCV13, another had received PCV13, and a third had received PPV23, but there was no record that any of them were offered, received, or declined the additional recommended vaccine. The RN unit manager/IP acknowledged the residents were not offered the vaccines and had not refused them.
A facility failed to ensure one resident received a pneumococcal vaccine after consent was obtained, with no documentation that it was administered or contraindicated. The facility also failed to document that another resident was offered the influenza vaccine and refused it, despite the MDS indicating the vaccine was not received in the facility. The DON confirmed the missing documentation for both residents.
Failure to document vaccine education and refusals for two residents. One resident with type 2 DM and another resident with respiratory failure both had BIMS scores of 15/15, but their records showed refusal of PCV 20 and refusal of influenza and pneumococcal vaccines without documentation that education on benefits and risks was provided. The IP stated education was provided regardless of refusal, while the DON confirmed the records lacked documentation of vaccine education.
Incomplete Pneumococcal Vaccine Documentation
Penalty
Summary
Failure to develop and implement policies and procedures for flu and pneumonia vaccinations was identified after review of facility policy, clinical records, and staff interview. The facility policy dated 5/4/26 stated that residents or responsible parties would be asked about prior vaccinations at admission, prior doses of influenza, pneumococcal, COVID, and other vaccines would be documented in the immunization portal in the electronic health record, and vaccinations would be administered by provider orders. For Resident R4, who was admitted with diabetes, depression, and multiple sclerosis, the MDS dated 6/19/26 coded pneumococcal vaccine status as not up to date and reason as not offered. The immunization record showed consent was not obtained and the reason was status to be determined, with education to the resident or representative not checked. For Resident R26, admitted with diabetes, high blood pressure, and coronary artery disease, the MDS also coded pneumococcal vaccine status as not up to date and reason as not offered, but the immunization record showed consent was not obtained and the reason was unable to obtain data, with no documented evidence that the vaccine status was discussed with the attending physician. For Resident R72, admitted with high blood pressure, chronic pain, and COPD, the MDS coded pneumococcal vaccine status as not up to date and reason as not offered, and the immunization record showed consent was not obtained and the reason was status to be determined, with education to the resident or representative not checked. The DON stated the facility should have followed up with vaccinations and confirmed the facility failed to provide accurate and timely documentation related to the pneumonia vaccine for these residents.
Failure to Consistently Manage Flu and Pneumococcal Immunizations
Penalty
Summary
The facility failed to consistently educate, offer, or administer influenza and pneumococcal immunizations for 3 of 5 residents reviewed for immunizations. For one resident, the admission record and vaccination consent did not identify whether prior influenza or pneumococcal vaccines had been received or whether the resident wanted or was eligible for the vaccines, and the consent was marked "No!" with a health unit coordinator signature. The resident’s EMR showed prior receipt of Prevnar 13 and influenza vaccine, and the CDC indicated the resident was eligible for shared decision making with the provider regarding PCV20 or PCV21 because more than one year had passed since the Prevnar 13 dose. For another resident, the record did not include evidence of shared decision making or receipt of an additional pneumococcal vaccine. A third resident’s vaccination consent indicated prior pneumococcal vaccines and that the resident would like to receive the vaccine, but the form was not signed by the resident or representative, and the record did not show shared decision making or receipt of vaccination. During interview, the infection prevention and control nurse stated she was responsible for reviewing MIIC reports, uploading them to PCC, and entering immunizations, and that she was the only person doing the vaccine review. She also stated that two of the admissions occurred during a time when she was serving as DON and things were behind. The facility policy required an immunization history on admission, review of MIIC, sharing unknown or noncurrent immunizations with the attending physician, obtaining orders, and documenting immunization history and education in the EMR.
Pneumococcal Immunization Education and Offer Process Deficient
Penalty
Summary
The facility failed to provide accurate education regarding pneumococcal immunization and failed to ensure that each resident was offered a pneumococcal immunization unless medically contraindicated for four of five residents reviewed for immunization concerns. The facility policy stated that residents would be offered pneumococcal vaccines at admission and ongoing as needed, with administration based on current CDC recommendations, but the policy did not specify how often residents would receive education about pneumococcal immunizations or how often they would be offered vaccines during ongoing admission. Resident 157 was admitted with a history of receiving Prevnar 13 and Pneumovax, and based on shared clinical decision-making was eligible for PCV20 or PCV21 at least 5 years after the last pneumococcal vaccine. Although a declination form dated at admission showed the resident declined a pneumococcal vaccine, there was no evidence the facility reoffered the vaccine during the two years since admission. Resident 177 had previously received Pneumovax 23 and Prevnar 13 and was also eligible for PCV20 or PCV21 after 5 years, but her son declined the vaccine at admission because he believed she had already received it, and there was no evidence the facility educated him that current CDC guidance supported PCV20 or PCV21. Resident 11 had received Pneumovax 23 years earlier, and the consent/declination form stated she declined because she already received the vaccine, but the form incorrectly indicated that no further vaccination was warranted if both PCV13 and PPSV23 had been given and did not reflect current CDC guidance for PCV20 or PCV21 after 5 years. Resident 17 had received Prevnar 13 and Pneumovax 23 and was eligible for PCV20 or PCV21 five years after the last dose, but the record contained no evidence that the facility offered the vaccine after that time. The infection control prevention coordinator confirmed the facility’s pneumococcal immunization plan and the findings for these residents.
Failure to Offer Recommended Pneumococcal Vaccinations
Penalty
Summary
The facility failed to minimize the risk of residents acquiring and transmitting pneumococcal disease by not ensuring that three sampled residents were offered the recommended pneumococcal vaccination. Resident 35’s EMR showed admission to the facility and prior receipt of PCV13 on 8/21/20, but there was no documentation that he was offered, received, or declined the additional recommended pneumococcal vaccine. Resident 56’s EMR showed admission to the facility and prior receipt of PCV13 on 11/21/19, with no documentation that he was offered, received, or declined the additional recommended pneumococcal vaccine. Resident 60’s EMR showed admission to the facility and prior receipt of PPV23 on 11/12/10, but there was no documentation that he was offered, received, or declined the additional recommended pneumococcal vaccine. During interview, the RN unit manager/infection preventionist stated that the facility had started using a new computer system on 6/1/26 to monitor immunizations and that residents were offered needed immunizations based on the new system and state immunization records. She agreed that residents 35, 56, and 60 were not offered the recommended pneumococcal vaccines and did not decline or refuse them. The updated 6/19/25 pneumococcal vaccination policy stated that the facility offers pneumococcal vaccination in accordance with CDC recommendations and federal requirements and that each resident’s pneumococcal immunization status is determined upon admission or soon afterward and documented in the EHR.
Failure to Document and Provide Pneumococcal and Influenza Vaccinations
Penalty
Summary
The facility failed to ensure that pneumococcal immunizations were administered for one resident and failed to ensure that influenza vaccination documentation was complete for another resident. The facility’s pneumococcal vaccine policy, dated May 29, 2026, stated that all residents would receive immunizations and/or vaccinations to help prevent infectious disease unless medically contraindicated or refused. A quarterly MDS assessment for Resident 83 dated June 18, 2026, showed the resident was cognitively intact, needed staff assistance with daily care needs, and that the pneumococcal vaccination was not up to date and had not been offered. A Pneumococcal Pneumonia Immunization Consent Form dated March 20, 2026, showed education was provided and authorization to administer the vaccine was obtained, but there was no documented evidence that the vaccine was given or that it was contraindicated. An annual MDS assessment for Resident 6 dated February 13, 2026, showed the resident was cognitively intact, needed staff assistance with daily care needs, and did not receive the influenza vaccine in the facility for that flu season because it was offered and refused. However, there was no documented evidence that the resident was offered the influenza vaccine during the 2025-2026 flu season or that she refused it. The DON confirmed that Resident 83 had signed consent for the pneumococcal vaccine but there was still no documentation that it had been administered, and also confirmed there was no documented evidence that Resident 6 was offered the influenza vaccine and refused it.
Failure to Document Vaccine Education and Refusals
Penalty
Summary
The facility failed to document in the medical record the education and information provided regarding influenza and pneumococcal vaccinations for two residents. Resident 27 was admitted with diagnoses including type 2 diabetes and had an MDS dated 7/3/26 showing a BIMS score of 15/15, indicating cognitive intactness. Resident 27's Immunization Details dated 5/19/26 showed refusal of the PCV 20 vaccine, but there was no documented evidence that education on the benefits of vaccination or the risks of not receiving it was provided before the refusal. Resident 100 was admitted with diagnoses including respiratory failure and had an MDS showing a BIMS score of 15/15, indicating cognitive intactness. Resident 100's Immunization Details dated 7/13/2026 showed that both the influenza and pneumococcal vaccines were declined, and the record indicated that no educational information was provided about either vaccine. During interviews, Resident 100 stated he was never educated on the influenza and pneumococcal vaccines, and Resident 27 stated he was never offered the pneumococcal vaccine and would have taken it had it been offered and education provided. The IP stated education on vaccination was provided regardless of refusal, while the DON confirmed there was no documentation that education was provided to either resident and stated staff were expected to educate residents and document it in the record.
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