Unlicensed Social Worker Used in Place of Qualified Full-Time Social Worker
Summary
The facility failed to ensure that it employed a qualified social worker on a full-time basis for one of one social worker positions reviewed. The facility was licensed for 187 beds, and during interview and record review on 07/02/26 at 5:25 p.m., the Administrator stated that the employee list showed Social Worker R as an unlicensed social worker. He said he hired Social Worker R on 04/03/26, when the person was unlicensed, to assist the previously licensed social worker who had resigned on 05/30/26. The Administrator said he was interviewing applicants to hire a licensed social worker as soon as possible. The facility’s Social Services policy stated that the social worker role includes discharge planning to ensure safe transitions of care, regulatory compliance, and coordination with residents, families, and the interdisciplinary team.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Unqualified Social Service Director: The facility failed to ensure the SSD met the minimum qualifications for the role for a census of 135. The SSD stated she had a BA in Communications, while HR confirmed the job description required a BA in Social Work or Human Services plus 2 years of supervised social work experience in a health care setting, and said the degree was not verified.
Failure to Employ a Qualified Full-Time SW: The facility did not have a full-time qualified SW after the SW was suspended and later terminated, leaving only a Social Worker Assistant who was not licensed and did not meet federal qualification requirements. The Assistant handled discharge planning, progress notes, notices, and referrals without SW oversight, while many residents had MH diagnoses and some had SUD diagnoses.
No full-time social worker was maintained at the facility despite having more than 120 beds. Record review showed no social worker on the staff list, and interviews with the ADON, BOM, DON, and Administrator confirmed the facility had relied on a corporate social worker who came weekly or occasionally, with other staff helping cover social work needs.
A facility licensed for 123 beds failed to employ a qualified full-time social worker for about two months. The current SSA was not a licensed social worker and had no social work degree or human services bachelor's degree, yet was completing admissions, discharges, and resident assistance while the Administrator, DON, BOM, management team, and sister facilities provided informal support.
Unlicensed Social Worker Not Employed Full-Time: The facility failed to ensure a qualified social worker was employed full-time for the social services position. The SW was listed as unlicensed, had a passing ASWB master's exam score and preliminary Texas licensure requirements, but did not have a current license. The SW reported working independently after orientation without routine supervision, while the HR Manager and Administrator confirmed the lack of licensure and the absence of routine oversight or a written hiring policy.
Failure to employ a qualified full-time social worker: The facility, licensed for 120 beds, did not maintain a licensed social worker on a full-time basis after the prior social worker’s last day. The new social worker had a master’s degree and was scheduled to take the LMSW exam, but was not yet licensed. He was responsible for discharge planning, social services assessments, care plans, and grievances, and the Administrator stated she was unaware he could not serve in the role before passing the exam.
Unqualified Social Service Director
Penalty
Summary
The facility failed to ensure the Social Service Director met the minimum qualifications for the position for a census of 135 residents. During interview, the Social Service Director stated she had a Bachelor's Degree in Communications. The Human Resources Director confirmed that the job description required a Bachelor's degree in Social Work or a Human Services field and two years of supervised social work experience in a health care setting, and stated he did not verify the Social Service Director's degree as listed on her resume. Record review of the facility's license showed 168 beds, and the cited deficiency was based on the facility's failure to have a qualified full-time social worker for a facility with more than 120 beds.
Failure to Employ a Qualified Full-Time Social Worker
Penalty
Summary
The facility failed to employ a full-time qualified Social Worker in a building licensed for 123 beds that admitted residents with psychosocial care needs related to mental illness, substance use disorder, and behavioral issues. The facility’s policy stated that all residents should receive necessary behavioral health services and that Social Services should serve as the contact person for behavioral services. Review of the census showed 99 occupied beds, and review of the resident analyzer report showed that 5 residents had substance use disorder diagnoses and 81 residents had one or more mental health diagnoses. Social Worker #1 was suspended on 05/28/26 during an abuse investigation and her employment was terminated on 06/03/26. After that, the facility had only a Social Worker Assistant, who worked full-time but was not licensed and did not have a bachelor’s degree in an acceptable field, so she did not meet the qualifications of a full-time qualified social worker. The Social Worker Assistant stated she had been the only social service staff member since the departure of SW #1, had no oversight from a social worker, and the facility had no contract with outside social service providers. The Administrator confirmed that the facility had not employed a full-time qualified social worker since 05/28/26 and had no outside agreement to provide social services during the vacancy.
No Full-Time Social Worker
Penalty
Summary
Failure to maintain a full-time social worker in a facility with more than 120 beds was identified based on record review and staff interviews. Review of the current staff list showed no social worker employed at the facility. The Assistant DON stated the facility had not had a full-time social worker since roughly January 2026, and that a corporate social worker came into the building occasionally while other staff, including nurse management, assisted with social work needs. The BOM reported there was no social worker except a corporate worker who came weekly, and that the BOM and other staff members helped with social work activities. The DON stated the facility previously had a social worker who came on weekends but was terminated roughly ten days before the interview, and that the facility currently had a corporate social worker who came once per week. The Administrator confirmed the facility had not had a full-time social worker since joining the facility in January 2026.
No Qualified Full-Time Social Worker
Penalty
Summary
The facility failed to ensure a qualified social worker was employed on a full-time basis for approximately two months in a building licensed for 123 beds and serving 94 residents. During observation of the facility license and review of the Facility Assessment, the facility was confirmed to be licensed and certified for 123 beds. Review of the Social Services/Social Worker Assistant job description showed the role was intended to support the overall operation of the Social Services Department, but the employee in the position was a Social Services Assistant rather than a licensed social worker. Interviews and personnel record review showed the Social Services Assistant had been hired on 04/22/26 and did not have a social worker degree, certification, or bachelor's degree in a human services field. The SSA stated she had been working as the assistant social worker since mid-April 2026, had been completing admissions, discharges, and assisting residents, and that there had been no licensed social worker in the building since that time. The Administrator and DON stated the previous social worker left in late May or early April 2026, that the current person in the role was the SSA and was not a certified social worker, and that the facility had been relying on the BOM, management team, sister facilities, and borrowed help while trying to hire a social worker.
Unlicensed Social Worker Not Employed Full-Time
Penalty
Summary
The facility failed to ensure that it employed a qualified social worker on a full-time basis for one of one social worker positions reviewed. The facility was licensed for 154 beds, and the social worker position was identified as unlicensed on the employee roster provided by the DON. Record review showed a job offer letter dated 02/09/2026 with an official start date of 02/23/2026, and criminal history verification listed a hire date of 02/05/2026 with a first day of service on 02/23/2026. Record review of an email from the Association of Social Work Boards showed that the social worker had a passing score on the ASWB master's examination and had received preliminary requirements for licensure in Texas. During interview, the social worker stated she had worked at the facility since February 2026, had been told she needed to obtain her license within six months, and had worked independently after a 30-day orientation without routine supervision or review. The HR Manager stated the social worker had an offer letter requiring licensure within six months, but the facility did not have documentation verifying the letter or completion of licensure, and confirmed the social worker did not possess a current license and was not permitted to practice independently. The Administrator stated he was aware the social worker did not have a license, and the HR Manager stated the facility did not have a written policy regarding the hiring process for anyone at the facility, including the social worker.
Failure to Employ a Qualified Full-Time Social Worker
Penalty
Summary
The facility failed to ensure that it employed a qualified social worker on a full-time basis for one of one social worker positions reviewed. The facility was licensed for 120 beds, and the census report dated 05/20/2026 showed a capacity of 120 beds with a census of 95 residents. The deficiency began when the previous licensed social worker’s last day was 05/20/2026, and the facility did not have a qualified full-time social worker in place after that date. During a telephone interview on 05/22/26, the current Social Worker J stated he was hired on 05/19/26, had a master’s degree in social services, and was scheduled to take his licensing exam on 06/06/26 for Licensed Master Social Worker. He said he was responsible for discharge planning, social services assessments, care plans, and grievances/concerns, but he was not familiar with Resident #1. The Administrator stated the facility had to have a licensed social worker full time, was not aware that Social Worker J could not work as the social worker prior to taking the licensing exam, and said the previous social worker was licensed. The Administrator did not provide the requested social worker job description prior to exit.
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