QAPI Committee Failed to Document Data Analysis, Measurable Goals, and Action Plans
Summary
The facility failed to ensure data submitted to the QAPI committee was analyzed and documented with measurable goals, benchmarks, and a plan of action. Review of quarterly QAPI meeting minutes from June 2025 through April 2026 showed departments were submitting data, but the minutes did not show meaningful discussion of the information, resident-specific review, or documentation of how the facility intended to achieve its stated goals. The facility’s QAPI plan identified the administrator and DON as responsible for leading the program and stated that evidence-based practices and data were to be used to define goals and implement plans of action. At the June 18, 2025 QAPI meeting, falls were reported as 13 falls with 4 residents having repeated falls, but the minutes did not identify the residents, whether interventions were being monitored, whether interventions needed to change, or whether common factors such as time of day or shift were reviewed. Alarms were noted to have decreased, but no goal, benchmark, or implementation plan was documented. Skin concerns were discussed with 2 residents having pressure ulcers, but the minutes did not identify a benchmark or goal. Weight charting was discussed as improved, but there was no resident-specific discussion about whether the weights reflected high-risk issues such as severe weight loss. Antipsychotic use was also reviewed, with 9 residents noted to be on antipsychotics and 2 on hospice, but there was no documentation that specific residents were reviewed for appropriateness, monitoring, or non-pharmacological interventions. The July 25, 2025, September 17, 2025, December 2025, March 2026, and April 2026 QAPI minutes showed similar patterns of department data being presented without documented analysis, measurable goals, benchmarks, or evidence that prior actions were evaluated for effectiveness. Infection control data listed the number of infections, but there was no documented evaluation of commonalities, surveillance, or goals. Skin and antipsychotic topics continued to be reviewed in the same limited manner. The 2026 PIP on moderate to severe pain in long stay residents also lacked documentation of the need for the project, rationale for selection, measurable goals, or a plan of action. During interview, the administrator and DON stated that department heads provided data for the meetings, but there was no documented discussion, measurable goal setting, or action plan in the minutes, and the administrator acknowledged the 2026 PIP had no documented discussion, analysis, action plan, or measurable goal in the first five months of the year.
Penalty
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The facility failed to maintain an effective QAPI program to address multiple quality deficiencies before survey. Staff did not obtain informed consent for bedrails for several residents, did not properly train CNAs on safe Hoyer lift use during a transfer, and did not ensure a planned fall-prevention intervention was in place for a resident whose care plan called for a bed overlay to define the bed edges. The QAPI team was reportedly meeting regularly and tracking several improvement areas, including UTI/ABX stewardship, hand hygiene, hydration, and CNA documentation.
QAPI committee failed to identify and address resident call light wait time concerns, despite meeting minutes noting call lights were the #1 issue. The concern was not documented in subsequent QAPI meetings, and the administrator stated there was no documentation showing follow-up, audit results, or staff feedback related to the issue. The VPO said the facility’s QAPI process should include data analysis, root cause review, action planning, and monitoring, but the administrator acknowledged the issue had not been on her radar and staff had not been informed or asked for input.
Failure to Conduct QA Activities for Identified Facility-Wide Concerns: The facility did not carry out QA activities to obtain feedback, use data, or analyze underlying causes for facility-wide issues affecting quality of care, quality of life, and resident safety. The QAPI policy called for a systematic, interdisciplinary, data-driven approach, but staff did not discuss resident personal funds or activities in QA. A PIP for the dementia unit noted inactivity, wandering, falls, and inconsistent participation in structured activities, yet the records lacked further evaluation of the PIP and lacked documentation of QA activities related to resident access to personal funds.
The facility failed to use its QAPI process to review a medication diversion incident involving an LPN who entered unauthorized med orders for two residents and took one medication for personal use. The event was investigated and discussed with corporate leadership, but it was not brought to the QAPI committee to review system failures, develop corrective actions, or monitor the effectiveness of interventions.
QAPI Program Failed to Correct Prior Deficiencies: The facility's QAPI program did not correct previously cited deficiencies after prior survey findings and plans of correction were reviewed. The POC for food safety issues included staff education, removal of items stored on the floor, and ongoing monitoring of dietary practices, but the DON later confirmed the facility failed to correct the quality deficiencies and did not ensure plans to improve care and services effectively addressed the identified concerns.
QAPI failed to correct 3 repeat areas of concern identified on the current recertification survey that matched prior complaint and recertification citations: Infection Prevention and Control, Reporting of Alleged Violations, and Investigate/Prevent/Correct Alleged Violation. The facility's QAPI policy required data review, root cause analysis, system improvement, benchmarks, and communication of QAPI activities, and the Administrator acknowledged the repeat concerns and stated the QAPI committee needed more extensive audits to address them.
QAPI Program Failed to Address Consent, Transfer, and Fall-Prevention Deficiencies
Penalty
Summary
The facility failed to maintain an effective quality assessment and assurance program to address quality deficiencies before survey. The report states that the facility did not obtain informed consent from residents or their legal representatives for the installation of bedrails for four residents. It also states that the facility failed to properly train staff on the use of the Hoyer total body mechanical lift for safe resident transfer, and that one resident was transferred while suspended in the air after both staff members removed their hands from the lift and the resident during the move. The report further states that the facility failed to ensure interventions were being used to prevent resident injury and falls. One resident did not have an overlay on the bed to define the edges as directed by the plan of care. Administrative staff said the QAPI team met at least quarterly and usually monthly, and that current improvement plans included UTI and antibiotic stewardship, staff engagement communication breakout sessions, room-to-room activities, handwashing, snacks and hydration, and CNA documentation. The next QAPI meeting was to include discussion and implementation of an improvement plan for accident and fall prevention.
QAPI Committee Failed to Address Call Light Response Time Concerns
Penalty
Summary
The facility’s QAPI committee failed to identify resident call light wait time concerns before survey and did not make a good faith attempt to correct the deficiency. QAPI meeting minutes dated 3/31/25 stated that call lights tended to be the #1 issue, but call light response times were not included or mentioned again in the next six QAPI meeting minutes. The deficiency had the potential to affect all 42 residents residing in the facility. During interviews, the administrator stated she assumed the QAPI committee had followed up on call light wait time concerns, completed an audit, and determined it was not an issue, but there was no documentation to support that. The vice president of operations stated the organization uses a standardized QAPI meeting format and that facilities are expected to analyze data, discuss findings, review audit results, perform root cause analyses, develop action plans, and monitor the effectiveness of interventions. The administrator later stated the long call light response times found during survey had not been on her radar and admitted there had been no staff meetings where QAPI activities were communicated to employees or where employees were asked for feedback about resident care concerns.
Failure to Conduct QA Activities for Identified Facility-Wide Concerns
Penalty
Summary
The facility failed to carry out Quality Assurance (QA) activities to obtain feedback, use data, and take action to conduct structured, systematic investigations and analysis of underlying causes or contributing factors of problems affecting facility-wide processes that impact quality of care, quality of life, and resident safety. The Quality Assurance and Performance Improvement (QAPI) policy dated April 2025 directed staff to continually assess facility performance using a systematic, interdisciplinary, comprehensive, and data-driven approach to maintain and improve safety and quality. The CMS Form 2567 dated 6/26/25 identified concerns related to residents having access to personal funds and activity provision. During record review and interviews from 7/13/26 to 7/16/26, the same concerns were identified. On 7/16/26, the Administrator stated staff did not discuss personal funds or activities in QA. A Performance Improvement Plan dated 5/26/26, sent by the Administrator on 7/17/26, identified increasing activities in the dementia unit and documented unit observations of inactivity, increased wandering behaviors, increased falls, and inconsistent participation in structured activities. The facility records lacked further evaluation of the activity PIP and lacked documentation of QA activities related to resident access to personal funds.
Failure to Use QAPI to Review Medication Diversion Incident
Penalty
Summary
The facility failed to implement its QAPI program to address a medication diversion event involving unauthorized medication orders and misappropriation of resident medications. The facility had a policy requiring an ongoing, facility-wide, data-driven QAPI program focused on indicators of outcomes of care and quality of life, but there was no documented evidence that the incident was presented to the QAPI committee for review, system failures were identified, corrective actions were developed, or the effectiveness of interventions was monitored. Through staff reporting and investigation, the facility learned that an LPN admitted to entering unauthorized medication orders into the electronic medical record under one resident's record, discontinuing those orders, and taking the medication for personal use in December 2025. The same LPN also admitted to entering another unauthorized medication order for a second resident with the intent to obtain that medication, although the medication was removed from the medication cart before it could be taken. The Administrator stated the incident was discussed with corporate leadership and that the LPN was placed on probation with weekly audits, but the matter was not brought to the QAPI Committee because of concerns regarding employee rights and personnel matters.
QAPI Program Failed to Correct Prior Deficiencies
Penalty
Summary
The facility's QAPI program failed to correct previously cited deficiencies after prior State Survey and Certification surveys and the related plans of correction were reviewed. The facility policy for QAPI, dated 1/6/26, stated that the program is a proactive, systematic approach to improving quality of care, quality of life, and services, and that the facility would take action based on findings, measure success, and track performance to ensure improvements are sustained. However, review of the facility's deficiencies and plans of correction for surveys ending 4/15/26 and 4/24/26 showed that the facility had developed quality assurance systems to maintain compliance with cited nursing home regulations, yet the deficiencies were not corrected. The plan of correction for the survey ending 4/24/26 included education for dietary staff on food handling, food safety, and food storage; immediate removal of items stored on the floor during truck delivery; education of a staff member on food safety and cross contamination; and monitoring of cooks and dietary storage by the dietary manager or designee. It also stated that education, audit, and monitoring would be reported during the next QAPI meeting. During an interview on 7/9/26 at approximately 7:00 p.m., the DON confirmed that the facility failed to correct quality deficiencies and did not ensure that plans to improve the delivery of care and services effectively addressed the identified concerns.
QAPI Program Failed to Correct Repeat Deficiencies
Penalty
Summary
The facility failed to correct its own deficiencies for 3 of 3 areas of concern identified during the current recertification survey. The concerns matched citations from the previous complaint survey and the previous recertification survey and involved Infection Prevention and Control, Reporting of Alleged Violations, and Investigate/Prevent/Correct Alleged Violation. The facility had a census of 39 residents at the time of the survey. The facility's QAPI Program policy, revised March 2020, directed the QAPI committee to collect and analyze performance indicator data, identify and monitor facility systems and processes, use root cause analysis, help departments implement systems to correct issues in quality of care, establish benchmarks and goals, coordinate performance improvement projects, and communicate QAPI activities to the Administrator and governing body. On 7/9/26 at 2:30 PM, the Administrator stated the QAPI committee reviews prior surveys and prior deficiencies to determine root cause and develop a plan to address and correct repeat deficiencies, and acknowledged the repeat concerns identified during this survey and prior surveys. The Administrator stated the QAPI committee must complete more extensive audits to address them.
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