Inaccurate Controlled Substance Count for Liquid Lacosamide
Summary
The facility failed to ensure that pharmaceutical services and controls for a liquid controlled medication were accurate and consistent for one resident. The resident was an adult male with diabetes mellitus, hypertension, and cerebral infarction, with moderately impaired cognition (BIMS score 10/15) and requiring extensive to total assistance with ADLs. His physician’s order and April 2026 order summary showed Lacosamide oral solution 10 mg/mL, 5 mL twice daily for epilepsy, ordered on 03/17/26. The controlled substance count sheet for this Lacosamide listed 45 mL on hand, and the MAR showed the last documented administration as the morning of 04/02/26 by an LVN. On 04/02/26, during inspection of the medication cart with the ADON and the LVN, surveyors observed that the Lacosamide bottle contained approximately 65 mL, while the control count sheet reflected only 45 mL. The ADON stated that this medication usually came overfilled and acknowledged that the facility did not correct the count to match the actual volume in the bottle. She reported she could not determine how much the bottle was overfilled compared to the 180 mL listed on the label and the amount on the count sheet, and she did not verify the discrepancy using the measurement lines on the bottle when prompted. She also stated that a mismatch between the liquid medication and the count sheet could be considered drug diversion and that none of the nurses had informed her of the discrepancy. The LVN who administered the medication stated that the bottle had more medication than what was documented on the count sheet and acknowledged that, as a nurse, she should have reported such a discrepancy to the DON and ADON but did not do so, assuming another nurse had reported it. She indicated that nurse management had told staff that liquid medications sometimes came with more medication than written on the bottle and that the DON and ADON were supposed to verify counts of liquid controlled medications, though she was unsure of their exact responsibilities. The DON later stated that the Lacosamide may have come overfilled and that nurses would continue to administer the medication until the labeled quantity was given and then destroy any overage, and she acknowledged that a discrepancy between the control count sheet and the actual medication could be drug diversion. The facility’s drug diversion prevention policy required incoming and outgoing nurses to count all controlled substances and reconcile the number of doses on hand with the controlled substance count sheet and the MAR, which was not done in this case.
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