Unclear designation of full-time DON
Summary
The facility failed to clearly designate one RN to serve as the full-time Director of Nursing for the LTC unit. Record review, staff interviews, and observation showed conflicting leadership roles for the Director of Clinical Services (DCS), the LTC Manager, and a newly hired DON, and the facility could not demonstrate that one RN was consistently assigned to provide LTC nursing leadership and oversight. Facility documents identified the DCS in different ways. The Key Contacts list identified the DCS as the LTC DON, RN/MDS, while the LTC Contact Resources list identified her as the LTC Manager. During interview, an LN stated the DCS was the LTC Manager and had always been the LTC Manager, and that another person would soon transition into the DON role. Observation showed the DCS wore a badge identifying her as Manager Long Term Care, while her office door title and business card identified her as Director of Clinical Services. The LTC Quality Committee list showed the DCS attending in the DCS role, while another staff member attended as the RN LTC DON. HR, payroll, and job description records also showed conflicting role assignments. The DCS was designated in HR as DCS effective 4/6/26, but the CAO stated she continued performing DON duties because the newly hired DON was still transitioning and had not fully assumed responsibilities. The DCS stated she was officially in payroll as DCS but was still doing DON and LTC Manager work, and the CAO acknowledged there was no documentation separating hours or duties between the DON and DCS roles. The DCS's offer letter stated she would assume the DCS role effective 4/6/26, while the newly hired DON's offer letter stated he would assume the DON role effective 4/5/26. Payroll records showed the DCS worked 40 hours per week with no time specifically designated to the LTC DON role, and the new DON's payroll was coded as Acute RN on several dates rather than LTC DON. The DCS's annual evaluation still reflected her LTC Manager role, and the job descriptions described separate responsibilities for DCS, LTC Manager RN, and Director LTC RN.
Penalty
Resources
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