Altercare Thornville Inc.
Inspection history, citations, penalties and survey trends for this long-term care facility in Thornville, Ohio.
- Location
- 14100 Zion Road, Thornville, Ohio 43076
- CMS Provider Number
- 366369
- Inspections on file
- 22
- Latest survey
- September 2, 2025
- Citations (last 12 mo.)
- 6 (1 serious)
Citation history
Health deficiencies cited at Altercare Thornville Inc. during CMS and state inspections, most recent first.
Two residents with significant risk factors for pressure ulcers did not receive timely or accurate wound care due to failures in obtaining and transcribing treatment orders, as well as lapses in implementing prevention measures such as repositioning and use of specialized mattresses. These deficiencies led to worsening of pressure ulcers, hospitalization for infection and sepsis, and serious harm.
Surveyors found that the facility did not properly manage and document the treatment of a non-pressure skin wound for a resident, including incomplete assessment and missed treatments, and also failed to obtain daily weights as ordered for three residents with conditions such as heart failure and fluid imbalance. Staff interviews confirmed that these omissions were not due to resident refusals but rather a lack of completion and documentation.
Three residents with wounds and documented pain did not receive appropriate pain management, including lack of as-needed pain medication administration and incomplete pain assessments, despite physician orders and facility policy requiring effective pain monitoring and treatment.
A resident with multiple medical conditions received incorrect medications and dosages due to a nurse administering the wrong forms and amounts, omitting a prescribed supplement, and documenting administration that did not occur. The nurse also left medications and records unsecured and failed to update medication labeling after an order change, resulting in a medication error rate of 16%, which exceeds the acceptable threshold.
The facility did not maintain complete and up-to-date medical records for three residents receiving wound care from an outside consultant group, as wound physician visit notes were missing from their charts. Staff interviews confirmed that these notes were not uploaded as required, and the documentation was only available on the consultant's server, contrary to facility expectations.
A registered nurse failed to perform proper hand hygiene and did not sanitize medical equipment before and after use while administering medications and taking vital signs for two residents. The nurse touched multiple surfaces with gloved hands, did not sanitize hands before or after resident contact, and used the same blood pressure and pulse oximetry machine for both residents without cleaning it, contrary to facility policy.
The facility failed to maintain the ice machine in a sanitary manner, affecting all 49 residents who received iced beverages. Observations revealed a red slimy substance and a white crusty build-up inside the machine, confirmed by the Dietary Director. Despite cleaning efforts, the white crusty build-up remained, violating the facility's policy requiring ice machines to be free of rust, lime, and mildew.
The facility failed to maintain a clean and homelike environment for residents, affecting four individuals. A resident's wheelchair was found with a cushion caked in food debris and frayed duct tape on the brakes. Another resident's room had a strong urine odor, while two other residents had bathrooms with stained floors and discolored caulking. These issues were confirmed by staff and violated the facility's policy for cleanliness.
A resident with heart failure and dysphagia was observed with food stains on her clothing and wheelchair, indicating a lack of dignity in her care. Despite requiring supervision during meals, she was often left with food debris on her person and surroundings. Staff confirmed the resident's condition, and the facility's policy on resident rights was not upheld.
The facility failed to prominently display advanced directives in the medical records of two residents, affecting their treatment preferences' visibility. One resident, admitted with multiple diagnoses, lacked a code status in their records, confirmed by the RN Supervisor and DON. Another resident, with altered mental status and dementia, also had no code status displayed, despite having a Full Code directive. This deficiency violated the facility's policy requiring advanced directives to be documented and prominently placed in medical records.
A resident with dysphagia and tremors was not provided with adaptive equipment for meals as per physician orders, leading to difficulties in eating independently. Despite having orders for a weighted glove and built-up utensils, the resident was observed struggling with meals, resulting in food and drink spills. Staff interviews confirmed the absence of the required equipment, and the resident expressed discomfort with the situation.
The facility failed to ensure alternating air mattresses were functional and correctly set for two residents at risk for pressure ulcers. One resident's mattress was unplugged and set to 210 pounds, while another's was set to 225 pounds, both likely inappropriate for their weights. Staff confirmed the incorrect settings, contrary to the facility's policy on pressure injury prevention.
A facility failed to implement fall prevention measures for a resident with a history of falls and medical conditions, as outlined in their care plan. The resident's care plan included non-skid strips in front of the toilet, but an observation revealed these were not present. This was confirmed by the ADON, who acknowledged the oversight despite the existing order.
A facility failed to store respiratory equipment in a sanitary manner, affecting a resident with Alzheimer's, depression, and hypertension. The resident's nebulizer, used for Ipratropium-Albuterol inhalation, was found on the floor and covered in brown spots. The Lead Receptionist confirmed the unsanitary condition and improper placement, noting the resident sometimes moved it. The facility's policy required proper cleaning and storage of the nebulizer, which was not followed.
Failure to Provide Timely and Accurate Pressure Ulcer Care Resulting in Harm
Penalty
Summary
The facility failed to develop and implement an accurate, comprehensive, and individualized pressure ulcer program for two residents who were at risk for and had existing pressure ulcers. For one resident, who had multiple comorbidities including weakness, cerebral infarction, atrial fibrillation, type 2 diabetes, and chronic kidney disease, the facility did not obtain timely treatment orders for known pressure ulcers upon admission. There were also errors in entering treatment orders, resulting in incorrect wound care being provided. The resident's pressure ulcers worsened, and prevention interventions such as repositioning and offloading were not implemented as required. This led to the resident being hospitalized for infection and sepsis related to pressure ulcers, and ultimately being placed on hospice due to complications from multiple antibiotic use for worsening wounds. Another resident, also requiring maximum assistance with bed mobility and transfers and at risk for pressure ulcer development, experienced a worsening of a right buttock pressure ulcer from stage 3 to stage 4. This occurred because medicated treatments, specifically Leptospermum Honey and Alginate Calcium, were not ordered or administered for several days. The wound increased in size and severity, with significant necrotic and slough tissue developing. The lack of timely and appropriate wound care interventions directly contributed to the deterioration of the resident's condition. Throughout the review period, there were repeated failures to ensure that wound care physician recommendations were accurately transcribed into physician orders and that the correct treatments were administered as prescribed. Documentation was inconsistent or missing, and there were lapses in implementing general pressure ulcer prevention measures such as regular repositioning, use of specialized mattresses, and prompt reporting of skin changes. These deficiencies resulted in serious, life-threatening harm to both residents, including hospitalization for infection, sepsis, and progression of pressure ulcers.
Removal Plan
- Resident #300 was assessed by Wound Care Physician #70 with orders received and followed by a licensed nurse, Assistant Director of Nursing (ADON)/Wound Nurse# 33.
- Resident #800 was assessed by Wound Physician #70 with new orders received and followed by a licensed nurse ADON/Wound Nurse# 33.
- An in-service was completed for ADON/Wound Nurse #33 by DON #40 and Regional Nurse #68 on the policy of Pressure Injuries: assessment, prevention, and treatment and the policy of physician notification.
- An in-service was completed for Minimum Data Set (MDS) Nurse #42, Registered Nurse (RN) #34, RN #27, RN #56, Licensed Practical Nurse (LPN) #44, LPN #25, LPN #65, LPN #30, and 26 Certified Nursing Assistants (CNA) by DON #40 on the policy of pressure Injuries: assessment, prevention, and treatment policy; completing head to toe assessment and documenting on skin sheet, if resident has skin alterations; documenting the initial wound observation; and contacting House Physician #66 to obtain treatment orders if not provided from the hospital.
- Any staff who had not received education will not work until education is completed. All staff had received the education.
- An in-service was completed for MDS Nurse #42, RN #34, RN #27, RN #56, LPN #44, LPN #25, LPN #65, LPN #30 by the DON #40 on notifying physician of any resident change in condition.
- Any staff who have not received education will not work until education is completed. All staff have received the education.
- A whole facility skin sweep was completed for 48 residents to identify any skin alterations by LPN #30 and ADON/Wound Nurse #33.
- Any residents with new skin alterations were reviewed by the DON #40 and House Physician #66 notified.
- No new pressure injuries were identified during whole house skin sweep.
- Treatment orders for 48 residents were reviewed by the Regional Nurse #68 to ensure that treatment orders are appropriate for any skin alterations.
- A list of any residents being followed by the wound care physician will be maintained by DON #40.
- For newly admitted residents, based on the admission skin assessment, the resident will be added to the wound consult as applicable.
- For current residents, any new skin alteration identified will be reviewed and added to the wound consult as applicable.
- An ad hoc Quality Assurance Performance Improvement (QAPI) meeting was held with House Physician/Medical Director #66 and facility leadership DON #40, Administrator #41, MDS/RN #42, ADON/Wound Nurse #33, Regional Administrator #69, and Regional Nurse #68 on pressure ulcer care and plan of correction.
- An audit to ensure pressure ulcer care is being completed per policy will be conducted for five residents three times a week for four weeks and as needed (PRN) by the DON or designee. Any concerns will be forwarded to the QAPI committee for immediate follow up.
- An audit to ensure wound consults are accurate on the consult sheet and orders from wound consults are entered appropriately and assigned to the correct physician will be completed once a week for four weeks and PRN by the DON or designee. Any concerns will be forwarded to the QAPI committee for immediate follow-up.
- An audit to ensure residents being followed by the wound care physician is being maintained by the DON, newly admitted residents are added to the wound consult list as applicable, and current residents with any new skin alterations are added to the wound consult list as applicable will be conducted once per week for four weeks and PRN by the regional nurse consultant or designee. Any concerns will be forwarded to the QAPI committee for immediate follow-up.
- QAPI plan completed.
Failure to Manage Non-Pressure Skin Alteration and Obtain Daily Weights
Penalty
Summary
The facility failed to appropriately manage and document the treatment of a non-pressure skin alteration for one resident and did not obtain daily weights as ordered for three residents. For one resident with multiple comorbidities, including heart failure, diabetes, and chronic kidney disease, there was an incident involving trauma to the right third and fourth toes. The initial wound assessment and documentation were incomplete, as only the third toe was documented and treated, while the fourth toe was not described or treated at the time of discovery. The cause of the trauma was not documented, and subsequent wound care orders did not accurately reflect the areas requiring treatment. Additionally, there were days when prescribed dressing changes were not completed for the affected toes. The same resident, along with two others with diagnoses such as heart failure, dementia, and risk of fluid imbalance, had active physician orders for daily weights due to their medical conditions. However, the facility failed to obtain and document daily weights on multiple occasions for all three residents. There was no documentation to indicate that the missed weights were due to resident refusals or any other justifiable reason; rather, the weights were simply not obtained as required by physician orders. Interviews with facility staff, including the wound nurse and the Director of Nursing, confirmed the lack of documentation and the failure to follow through with both wound care and daily weight monitoring as ordered. The deficiencies were identified through interviews and record reviews, and the facility census at the time was 47 residents.
Failure to Provide Effective Pain Assessment and Management
Penalty
Summary
The facility failed to provide safe and appropriate pain management for three residents who required such services. For one resident with multiple diagnoses including fractures, chronic kidney disease, and a new wound, pain assessments documented pain ratings of 3 to 5 during weekly wound reviews, but no pain medication was administered despite physician orders for as-needed oxycodone-acetaminophen for moderate to severe pain. Another resident with pressure ulcers and intact cognition had no as-needed pain medication ordered, even though weekly wound reviews consistently documented pain ratings of 3 to 4. In both cases, there was no evidence that pain was managed according to the care plan interventions, which included administering pain medication as ordered and monitoring for effectiveness. A third resident with pressure ulcers and a history of chronic conditions had orders for both hydrocodone-acetaminophen for severe pain and acetaminophen for mild pain. Despite regular wound pain assessments showing pain ratings between 5 and 6, no as-needed pain medication was administered during the documented periods. Additionally, weekly wound pain assessments were not consistently completed as required by facility policy, and there was no follow-up after non-pharmacological interventions to determine if further treatment was needed. Interviews with facility staff, including the Assistant Director of Nursing and the wound nurse, confirmed that pain medications were not given prior to wound care treatments and that there was a lack of follow-up after interventions. The facility's policy required assessment, monitoring, treatment, and evaluation of pain to ensure effective management, but these steps were not consistently followed for the residents reviewed.
Medication Administration Error Rate Exceeds Acceptable Threshold
Penalty
Summary
The facility failed to maintain a medication administration error rate below five percent, as evidenced by four errors out of 25 opportunities during observation, resulting in a 16% error rate. A resident with multiple diagnoses, including thoracic vertebra fractures, depression, anxiety, heart disease, and constipation, was observed during medication administration. The registered nurse (RN) administered incorrect medications and dosages, including giving enteric coated aspirin instead of chewable aspirin, buspirone 5 mg instead of the ordered 10 mg, and senna 8.5 mg instead of the ordered 8.6-50 mg. Additionally, the I-vite supplement was not administered, though it was documented as given. Further observations revealed lapses in medication security and documentation. The RN left the medication administration record open and out of sight, left a sealed lidocaine patch unattended on top of the medication cart, and failed to lock the medication cart when leaving it unsupervised. The RN also did not label the medication bubble pack to indicate a change in the buspirone order, as required by facility policy. These actions were inconsistent with the facility's medication administration and storage procedures, contributing to the identified deficiency.
Failure to Maintain Complete Medical Records for Wound Care Visits
Penalty
Summary
The facility failed to maintain up-to-date and complete medical records for three residents who were receiving wound care from an outside wound consultant group. For each of these residents, documentation of wound physician visits was missing from their medical records, despite evidence that such visits had occurred. Specifically, one resident with multiple diagnoses, including a recent open wound and sepsis, had no wound physician visit notes in her closed record, and the DON confirmed that these notes were not present and would need to be obtained from the facility wound nurse. Another resident admitted with a skin alteration also had no wound physician visit documentation in the record, which was verified by the facility wound nurse, who acknowledged that the notes should have been uploaded after each visit. A third resident with several chronic conditions and a skin alteration on admission similarly lacked wound physician consultant notes in the medical record, with the regional nurse confirming that the notes were only accessible on the consultant's server and had not been uploaded as expected. These deficiencies were identified through interviews and record reviews, which revealed that the facility did not ensure that wound care documentation from external consultants was consistently incorporated into the residents' medical records. The expectation, as stated by facility staff, was that the wound nurse would upload these notes after each visit to keep the records current and complete for ongoing care. The absence of these records was discovered incidentally during a complaint investigation.
Failure to Perform Hand Hygiene and Sanitize Equipment Between Residents
Penalty
Summary
The facility failed to ensure proper hand hygiene and sanitation of medical equipment before and after resident use, as observed with two residents. A registered nurse was seen preparing medications while wearing a glove on one hand, touching the medication cart, medications, and computer with the same glove, and then removing the glove without sanitizing her hands. She entered the residents' rooms, took their blood pressure and pulse oximetry readings with the same machine, administered medications, and left the rooms without performing hand hygiene or cleaning the equipment. These actions were repeated for both residents observed. During an interview, the nurse confirmed she did not change gloves after touching surfaces other than the residents' medications, did not sanitize her hands before and after entering the residents' rooms, and did not clean the blood pressure and pulse oximetry equipment before or after use. Facility policies reviewed indicated that proper hand hygiene and equipment cleaning are required to prevent and control infection, but these procedures were not followed during the observed medication administration process.
Ice Machine Sanitation Deficiency
Penalty
Summary
The facility failed to maintain the ice machine in the main kitchen in a sanitary manner, which had the potential to affect all 49 residents who received iced beverages from this source. During an observation, a red slimy substance was found next to the prepared ice, and a white crusty build-up was noted on the inside of the ice machine near the cooling mechanism. These findings were confirmed by the Dietary Director during an interview. The Assistant Director of Dietary Services later confirmed that the ice machine was deep cleaned by an outside company, and bagged ice was obtained for resident use. However, a subsequent observation revealed that while the red slimy substance had been removed, the white crusty build-up remained. The facility's policy, dated October 2020, requires ice machines to be free of rust, lime, and mildew at all times, indicating a failure to adhere to this standard.
Failure to Maintain a Clean and Homelike Environment
Penalty
Summary
The facility failed to provide a homelike environment and ensure resident equipment was clean and well maintained, affecting four residents. Resident #3, who had diagnoses including heart failure and bipolar disorder, was observed sitting in a wheelchair with a cushion caked in food debris and extended brakes covered in frayed duct tape. Interviews with the Regional Nurse Consultant and Physical Therapy Assistant confirmed these observations, noting the tape was used as a visual cue and needed replacement. The facility's policy required maintenance in a clean and sanitary manner, which was not adhered to in this case. Resident #13's room was noted to have a strong urine odor, confirmed by the MDS Nurse. Resident #37's bathroom had a dark gray stain on the floor and discolored caulking, which the Lead Receptionist confirmed could not be cleaned despite attempts. Resident #42's bathroom floor was dirty and stained, with debris and discolored caulking, as confirmed by the Activity Director. These observations indicate a failure to maintain a clean and sanitary environment as per the facility's policy.
Failure to Maintain Resident Dignity During Meals
Penalty
Summary
The facility failed to ensure a resident was treated with dignity during and after dining, affecting one resident. The resident, who had diagnoses including heart failure, dysphagia, and bipolar disorder, required supervision during meals and assistance with personal care. Observations revealed the resident was often left with food stains on her clothing, wheelchair, and the floor, and was not always provided with a clothing protector. The resident expressed discomfort with being seen in such a state, indicating a lack of dignity in her care. Interviews with staff confirmed the resident's condition during meals, with food debris often left on her clothes and wheelchair. The resident struggled with eating due to tremors, which caused spills and stains, and staff intervention was delayed. The facility's policy on resident rights emphasized treating residents with kindness, respect, and dignity, which was not upheld in this case. The observations and interviews highlighted a failure to maintain the resident's dignity, as she was left in soiled clothing and surroundings after meals.
Failure to Prominently Display Advanced Directives
Penalty
Summary
The facility failed to ensure that advanced directives were prominently placed in the medical records of two residents, affecting their ability to have their treatment preferences clearly communicated. Resident #100, who was admitted with multiple diagnoses including surgical aftercare of the digestive system and malignant neoplasm of the prostate, did not have a code status prominently displayed in either the electronic or physical medical records. Interviews with the RN Supervisor and the Director of Nursing confirmed the absence of advanced directives in Resident #100's chart, which contradicted the facility's policy requiring such documentation to be included and prominently displayed. Similarly, Resident #149, admitted with diagnoses including altered mental status and dementia, also lacked a prominently displayed code status in their medical records. The Director of Nursing confirmed the omission and noted that Resident #149 had a Full Code status, which was not initially documented in the medical records. The facility's policy mandates that staff should inquire about and document any existing advanced directives upon admission, ensuring they are included in the resident's medical record. The failure to adhere to this policy resulted in the deficiency noted by the surveyors.
Failure to Provide Adaptive Equipment for Resident Meals
Penalty
Summary
The facility failed to provide a resident with adaptive equipment for meals as per physician orders, affecting the resident's ability to perform activities of daily living independently. The resident, who had diagnoses including heart failure, dysphagia, and tremors, was observed multiple times without the prescribed adaptive equipment, such as a left-handed weighted glove and built-up curved utensils. Despite having physician orders for these items, the resident was seen struggling to eat, resulting in food and drink spilling onto her clothes, wheelchair, and the floor. Interviews with staff confirmed the absence of the adaptive equipment during meals, and the Assistant Director of Dietary Services was unaware of the weighted glove requirement. The resident expressed discomfort with the situation, as she was often left with food stains on her clothing and wheelchair, which she found embarrassing. The facility's policy on adaptive equipment, which mandates the provision of assistive devices to residents requiring them, was not followed. The policy also requires therapy evaluation and physician orders for such equipment, which were in place but not implemented. This oversight led to the resident's difficulty in eating independently and maintaining personal dignity during meals.
Improper Settings on Air Mattresses for Pressure Ulcer Prevention
Penalty
Summary
The facility failed to ensure that alternating air mattresses were functional and set correctly for pressure ulcer prevention, affecting two residents. Resident #12, who was admitted with diagnoses including senile degeneration of the brain, dysphagia, dementia, and chronic obstructive pulmonary disease, was at risk for pressure ulcers due to various health conditions. Despite having an order for an alternating air mattress, observations revealed that the mattress was unplugged and set to 210 pounds, which was likely inappropriate given the resident's weight of 114.5 pounds. Interviews with staff confirmed the incorrect settings and the unplugged status of the mattress. Similarly, Resident #13, who was admitted with diagnoses including senile degeneration of the brain and dementia, was also at risk for skin breakdown. The resident's care plan included the use of an air mattress, but observations showed the mattress was set to static, normal pressure at 225 pounds, which was likely too high for the resident's weight. Staff interviews confirmed the incorrect settings. The facility's policy on pressure injury prevention emphasized the use of pressure redistribution mattresses, but the implementation was inadequate, as evidenced by the incorrect settings and functionality of the mattresses.
Failure to Implement Fall Prevention Measures
Penalty
Summary
The facility failed to implement fall prevention interventions for a resident, as outlined in their care plan. The resident, who has a history of falls and medical conditions including senile degeneration of the brain, dementia, depression, and a traumatic brain injury, was admitted with a care plan that included the use of non-skid strips in front of the toilet to prevent falls. However, during an observation, it was noted that these non-skid strips were not present in the resident's bathroom. This oversight was confirmed by the Assistant Director of Nursing, who acknowledged the absence of the strips despite the existing order in the medical record.
Unsanitary Storage of Respiratory Equipment
Penalty
Summary
The facility failed to store respiratory equipment in a sanitary manner, affecting a resident who was admitted with diagnoses including Alzheimer's disease, depression, and hypertension. The resident had a physician's order for Ipratropium-Albuterol solution for nebulization due to wheezing, cough, and congestion. During an observation, the resident's nebulizer was found on the floor, plugged into the wall, and covered in small, brown spots. An interview with the Lead Receptionist confirmed the nebulizer's unsanitary condition and improper placement on the floor, noting that the resident sometimes moved it. The facility's policy on respiratory therapy infection prevention required the nebulizer to be cleaned and stored properly after use, which was not adhered to in this instance.
Latest citations in Ohio
A resident with intact cognition receiving Medicare Part A skilled services for metabolic encephalopathy had services discontinued while benefit days remained, but the facility did not issue the required Skilled Nursing Facility Advance Beneficiary Notice (SNF ABN). The Social Services Director later confirmed that no SNF ABN was provided and reported she believed only a Notice of Medicare Non-Coverage (NOMNC) was needed when all skilled services were stopped. This practice conflicted with the facility’s written policy, which required SNF ABNs to be issued when extended care items or services were initiated, reduced, or terminated due to expected non-coverage by Medicare.
Surveyors identified that the facility exceeded the acceptable medication error rate when two residents with type 2 DM received insulin doses that were not administered according to orders or manufacturer instructions. In two separate observations, an LPN administered Novolog and another LPN administered insulin glargine and insulin lispro without priming the insulin pens, and the insulin lispro and Novolog were given after the residents had already consumed a significant portion of their breakfast meals, despite orders for administration before meals. Manufacturer information for both insulin products required priming before each injection to ensure accurate dosing, and facility policy required medications, including insulin, to be administered safely, timely, and in accordance with prescriber orders and specified time frames.
Surveyors found that the facility failed to document tray line food temperatures for multiple meals served from two dining room kitchenettes, despite having a “Trayline Taste & Temperature Log” and a policy requiring food to be stored, prepared, distributed, and served according to professional food safety standards. Review of logs showed repeated missing entries for breakfast, lunch, and dinner services in both the Harrison and McClellan dining areas, and the Senior Director of Culinary Services confirmed that temperatures had not been recorded for those meals, potentially affecting all residents receiving meals from those kitchenettes.
The facility failed to conduct and document required periodic care conferences for two residents, despite multiple comprehensive, quarterly, and significant change MDS assessments and a policy requiring periodic care conferences with resident and/or family participation. One resident with Parkinson’s disease, post-stroke hemiplegia, TIA, DMII, and depression had only two documented care conferences over a year, while another resident with aphasia, cerebrovascular disease, DMII, gait difficulty, coagulation defect, depression, and muscle weakness had no documented care conferences in the past year, aside from a declined invitation to the representative. The UCC confirmed that care conferences were expected to occur quarterly and that no additional documentation existed for either resident.
A resident with Alzheimer's disease and type II DM, who required extensive assistance with ADLs and was receiving scheduled Lantus and sliding-scale Humalog, experienced a severely elevated blood glucose level. The on-call provider was notified and ordered an additional dose of lispro insulin with a directive to recheck the blood glucose after administration. Nursing staff administered the extra insulin but did not document any follow-up blood glucose check, and the DON confirmed that this reevaluation was required by the facility's abnormal blood glucose policy and was not completed or documented.
A resident with Parkinson’s disease, dementia, and hypothyroidism was prescribed levothyroxine once daily along with other medications. A consultant pharmacist’s monthly drug regimen review recommended that levothyroxine be given in the morning on an empty stomach, 30–60 minutes before food, per manufacturer instructions. The medical record contained no documented physician response to this recommendation, and the MAR showed the drug scheduled for morning administration while the resident was observed eating breakfast and receiving the medication at the same time. An LPN confirmed administering levothyroxine during the meal, and the DON verified there was no documentation explaining whether or why the pharmacist’s recommendation was or was not followed, resulting in a failure to act on and document the identified irregularity.
A resident with severe cognitive impairment, multiple comorbidities, documented gait and balance abnormalities, and a high fall risk was care planned and assessed by therapy to require contact guard assistance and use of a gait belt for transfers and ambulation. While being assisted by a CNA from a recliner to the bathroom with a walker, the CNA did not apply a gait belt, even though the resident had a known tendency to lean backward when standing. As the CNA reached to open the bathroom door, the resident lost balance and fell backward, striking the back of the head, and was later found by an LPN without a gait belt in place, contrary to the facility’s gait belt policy and the resident’s assessed needs.
A resident with CKD stage five requiring peritoneal dialysis (PD) was admitted with pre-admission physician orders for three daily PD exchanges and monitoring for peritonitis (fever, abdominal pain, cloudy effluent), but these monitoring orders were not entered into the facility’s physician orders. The care plan referenced PD and general monitoring but did not specifically address peritonitis monitoring. Paper PD flowsheets showed incomplete and inconsistent documentation of exchanges and resident condition, including missing condition/comments for individual treatments and no record of one ordered PD exchange. The PD cycler flowsheet lacked effluent descriptions on multiple days. The PD nurse reported facility staff were expected to monitor effluent and symptoms, and the DON confirmed the absence of specific peritonitis monitoring orders, lack of an order for the PD cycler, and documentation gaps, despite a facility policy requiring ongoing assessment and monitoring for complications before, during, and after dialysis treatments.
A nurse was observed preparing multiple oral medications for a resident with depression, traumatic brain injury, anxiety, and impaired cognition by pushing tablets and capsules from unit-dose cards directly into her ungloved hand and then using her fingers to place them into a medication cup. In a follow-up interview, the RN confirmed this practice and acknowledged that the correct procedure is to dispense medications directly from the card into the cup, contrary to the facility’s medication administration policy requiring adherence to good nursing principles and practices.
A resident with Alzheimer’s disease, diabetes, anxiety, significant ADL dependence, and behavioral symptoms was observed seated in a chair positioned against the nursing station with a locked wheelchair placed directly in front, also against the nursing station, effectively restricting movement. An LPN confirmed both wheelchair wheels were locked and that it should not have been placed there, while a CNA stated she had positioned the wheelchair to prepare for lunch, was unable to complete the transfer, and left it in place, acknowledging this was wrong. This arrangement conflicted with the facility’s restraint policy, which prohibits physical restraints except when alternatives are ineffective for treating a medical symptom and defines restraints as devices adjacent to the body that cannot be easily removed and that restrict freedom of movement or access to the body.
Failure to Issue Required SNF ABN When Discontinuing Medicare Part A Services
Penalty
Summary
The deficiency involves the facility’s failure to issue a Skilled Nursing Facility Advance Beneficiary Notice (SNF ABN) when Medicare Part A services were discontinued for a resident who still had available benefit days. The resident was admitted with a diagnosis of metabolic encephalopathy and had intact cognition per the Minimum Data Set assessment. The facility’s own SNF Beneficiary Notification Review documented that Medicare Part A skilled services began on 02/11/26 and the last covered day was 03/11/26, and that the facility initiated discharge from Medicare Part A services before the resident’s benefit days were exhausted. Despite this, no SNF ABN was provided to the resident or the resident’s representative. During interviews, the Social Services Director stated that the SNF ABN was issued hours prior to the last covered day but, upon reviewing her files, confirmed that no SNF ABN had actually been issued for this resident. She further explained that she believed an SNF ABN was only required if one skilled service remained and that if all skilled services were being discontinued, only the Notice of Medicare Non-Coverage (NOMNC) needed to be issued. The Administrator, however, stated that a resident should always receive both a SNF ABN and a NOMNC when Medicare Part A services are discontinued and benefit days remain. Review of the facility’s written policy dated 03/28/23 showed that the facility was required to issue SNF ABNs for initiation, reduction, or termination of extended care items or services when Medicare payment was not expected, which did not occur in this case.
Plan Of Correction
This Plan of Correction is submitted as required under State and Federal law. This Plan of Correction does not constitute an admission on the part of the Facility that the findings cited are accurate, that the findings constitute a deficiency or that the scope and severity regarding the deficiency cited are correctly applied. Any changes to the Facility's policies and procedures should be inadmissible in any proceeding on that basis. Without admitting or denying the validity or the existence of the alleged noncompliance, the Facility submits this Plan of Correction with the intention that it be inadmissible by any third party in any civil or other action against the facility or any employee, agent, officer, director or shareholder of the Facility. The Facility is utilizing this Plan of Correction as its allegation of substantial compliance as of 05/29/2026 F-0582 Corrective action for resident/s: On 5/14/26 Resident #34 was informed of rights and responsibilities related to Advanced Beneficiary Notice and voiced understanding of information for future reference by administrator. Identification of other residents who may be affected: Any resident receiving skilled services from nursing or therapy services. The Administrator audited all residents who were discharged from skilled services in the past 30 days to ensure they were issued a Notice of Non-Coverage and Advanced Beneficiary Notice on 5/29/26. No non-compliance was noted. Measures for systemic change: On 5/14/2026 Business Office Manager, Director of Rehab, Minimum Data Set nurse, Director of Nursing and Social Services Director were educated on proper procedure of issuing of Notice Of Medicare Non Coverage and Advanced Beneficiary Notice by administrator. All upcoming discharges from skilled services will be reviewed weekly at Utilization Review meeting to ensure notices will be delivered timely. How Corrective Action will be monitored: Administrator or designee to complete audits of all residents being discharged from skilled services to ensure they were issued a Notice of Non-Coverage and Advanced Beneficiary. This audit will be completed weekly x 4 weeks, then monthly x 2 months. Corrective action will be initiated for any noted non-compliance. Audit findings will be reviewed as part of the monthly quality assurance process to determine the need for further monitoring. Date of Compliance 5/29/26
Insulin Administration Errors and Failure to Prime Insulin Pens
Penalty
Summary
The deficiency involves the facility’s failure to maintain a medication error rate below 5%, with surveyors identifying 3 errors out of 28 medication administration opportunities, resulting in a 10.71% error rate. For one resident with type 2 diabetes mellitus and moderate cognitive impairment, the physician’s order directed Novolog insulin 10 units via subcutaneous pen-injector to be given before meals. During an observed medication pass, the LPN administered 10 units of Novolog insulin without priming the pen and did so after the resident had already consumed approximately 50% of the breakfast meal. The LPN later confirmed she did not prime the pen and acknowledged that the insulin was ordered to be administered prior to meals. Manufacturer instructions for the Novolog FlexPen specified that an air shot (priming) must be performed before each injection to ensure proper dosing. Another resident, also diagnosed with type 2 diabetes mellitus and with intact cognition, had orders for insulin glargine 35 units subcutaneously twice daily and insulin lispro 20 units subcutaneously before meals, plus 12 units subcutaneously if blood glucose was between 251 mg/dL and 300 mg/dL. During an observed medication administration, an LPN administered 35 units of insulin glargine and 32 units of insulin lispro without priming the insulin pens and after the resident had consumed approximately 90% of the breakfast meal, despite orders for insulin lispro to be given before meals. The LPN later stated she could not remember if she had primed the pen and acknowledged that the insulin was ordered to be administered prior to meals. Manufacturer information for insulin lispro stated that the pen must be primed before each injection to confirm insulin delivery and remove air, and that failure to prime could result in too much or too little insulin. The DON confirmed the expectation that insulin be administered as ordered, including priming each pen with two units before dialing the prescribed dose, and facility policy required medications, including insulin, to be administered safely, timely, and in accordance with prescriber orders and required time frames.
Plan Of Correction
This Plan of Correction is submitted as required under State and Federal law. This Plan of Correction does not constitute an admission on the part of the Facility that the findings cited are accurate, that the findings constitute a deficiency or that the scope and severity regarding the deficiency cited are correctly applied. Any changes to the Facility's policies and procedures should be inadmissible in any proceeding on that basis. Without admitting or denying the validity or the existence of the alleged noncompliance, the Facility submits this Plan of Correction with the intention that it be inadmissible by any third party in any civil or other action against the facility or any employee, agent, officer, director or shareholder of the Facility. The Facility is utilizing this Plan of Correction as an allegation of substantial compliance as of 5/29/2026. F-0759 Corrective action for resident/s: Residents #21 and #22 were assessed and evaluated by nurse and Director of Nursing 5/14/26. Resident #21 and #22 both denied any adverse effects and none were noted upon assessment by the Director of Nursing on 5/14/2026. Notification made to physician on 5/14/2026. LPN # 2 competency Eval on insulin administration with the Director of Nursing completed 5/14/2026. Identification of other residents who may be affected: Diabetic residents on assignment of LPN #2/station 2 have the potential to be affected and were assessed by the DON/Designee on 5/14/26 and found to be within normal limits. Measures for systemic change: All Nurses were educated by the Director of Nursing on the steps for Insulin administration per competency, diabetes clinical protocol policy, Medication and treatment orders policy, administering medications policy, and Obtaining fingerstick Glucose Level policy On 5/14/2026. How Corrective Action will be monitored: Director of Nursing and Assistant Director of Nursing will complete insulin administration audits on 5 nurses. This audit will be completed weekly x 4 weeks, then monthly x 2 months. Corrective action will be initiated for any noted non-compliance. Audit findings will be reviewed as part of the monthly quality assurance process to determine the need for further monitoring. Date of Compliance: 5/29/2026
Failure to Document Tray Line Food Temperatures in Dining Room Kitchenettes
Penalty
Summary
The deficiency involves the facility’s failure to document tray line food temperatures for meals served from the Harrison and McClellan Dining Room kitchenettes, as required by professional standards for food service safety and the facility’s own policy. Review of the “Trayline Taste & Temperature Log” (revised September 2018) showed missing temperature documentation for multiple meals from the Harrison Dining Room kitchenette, including dinner on 03/30/26 and 03/31/26, lunch and dinner on 04/01/26 and 04/02/26, dinner on 04/07/26, and lunch and dinner on 04/08/26 and 04/10/26. The Senior Director of Culinary Services confirmed during interview that tray line food temperatures were not documented on the log for these meals. Similarly, review of the same log for the McClellan Dining Room kitchenette revealed that tray line food temperatures were not documented for dinner on 04/01/26, breakfast and lunch on 04/02/26, and lunch and dinner on 04/07/26. The Senior Director of Culinary Services also verified these omissions during interview. The facility census at the time was 27 residents, and the governing “Food and Nutrition” policy, approved on 09/07/21, stated that the facility must store, prepare, distribute, and serve food in accordance with professional standards for food service safety.
Plan Of Correction
F812 The facility will continue to ensure food temperatures are completed before meals are served for all residents. To ensure compliance with this standard the following measures have been taken: 1. Immediately 4/15/26 culinary supervisor #224 was re-educated by Dietary Manager to this standard and policy "Food and Nutrition" which includes documentation of food temperatures. 2. All dietary staff have been re-educated to the standard and policy "Food and Nutrition" during the month of April 2026. 3. Audits of food temperature documentation to be completed by Dietary Manager 4 x per week for 4 weeks then weekly for 4 weeks. 4. Administrator to validate audits/compliance and provide additional training as needed. Administrator will present to QAPI committee for ongoing monitoring and further direction.
Failure to Conduct and Document Required Care Conferences
Penalty
Summary
The deficiency involves the facility’s failure to complete and document comprehensive care conferences at required intervals in accordance with care plan regulations and facility policy. For one resident with Parkinson’s disease with dyskinesia, cognitive communication deficit, hemiplegia and hemiparesis following cerebral infarction, transient cerebral ischemic attack, type II diabetes mellitus, and major depressive disorder, the record showed multiple MDS assessments over a one-year period, including annual, quarterly, and significant change assessments. However, only two care conferences were documented during the last 12 months, despite the expectation that care conferences be conducted quarterly with the resident and family when possible. The Unit Care Coordinator confirmed that no additional care conference documentation existed for this resident beyond the notes dated 04/21/25 and 01/02/26. A second resident, with diagnoses including aphasia following cerebrovascular disease, cerebral infarction, type II diabetes mellitus, unsteadiness on feet, difficulty in walking, coagulation defect, depression, and muscle weakness, also had multiple MDS assessments completed over the review period, including quarterly and annual assessments. The record contained a note that a care conference was offered to the resident’s representative, who declined to attend, but there was no documentation of any care conferences for the most recent 12 months. The Unit Care Coordinator confirmed that no other care conference documentation was available for this resident. Facility policy stated that periodic care conferences involving the resident, family, and the interdisciplinary team are part of the care planning process, but the required periodic care conferences and corresponding documentation were not completed for these two residents.
Plan Of Correction
THIS PLAN OF CORRECTION SERVES AS BERKELEY SQUARE'S CREDIBLE ALLEGATION OF SUBSTANTIAL COMPLIANCE AS OF June 1, 2026. Without admitting or denying the validity or existence of the alleged deficiencies, Berkeley Square provides the following Plan of Correction: F657 The facility will continue to document completion of care conferences at the required intervals for all residents, including residents #04 & #15. To ensure compliance with this standard the following measures have be taken: 1. The social service designee and the inter- disciplinary team were re-educated by the administrator to the facility policy "Care Conference" on 4/29/26 and verbalized understanding. 2. Care conferences for resident #04 and resident #15 were conducted on or before 4/29/2026 by the interdisciplinary team. 3. Review of all other residents was conducted by the social service designee to validate and ensure that care conference schedule is up to date with timely care conferences scheduled for them on 4/15/2026. Audits of care conferences to be completed weekly for four weeks and then monthly after that by the social service designee. Documentation of the care conference including any identified concerns in the medical record. Administrator to validate audits/compliance and provide additional training as needed. Administrator will present results of these audits to QAPI committee for ongoing monitoring and further direction.
Failure to Reevaluate Blood Glucose After Treatment for Hyperglycemia
Penalty
Summary
The facility failed to ensure that a resident with diabetes received treatment in accordance with professional standards of practice when nursing staff did not reevaluate the resident's blood glucose after treatment for severe hyperglycemia. The resident, admitted with diagnoses including Alzheimer's disease, type II diabetes mellitus, and depression, had physician orders for Humalog insulin on a sliding scale before meals, Lantus insulin 25 units daily, and lisinopril 5 mg daily. The resident required extensive assistance with activities of daily living, including transfers, toileting hygiene, eating, and bathing. On the evening in question, the resident's blood glucose was documented as 532 mg/dL, and the on-call provider was notified. The provider gave a new order to administer an additional 8 units of lispro (Humalog) and to recheck the blood glucose in 30 minutes. The electronic medication administration record showed that the blood glucose of 532 mg/dL was obtained at 9:00 p.m. and that the additional 8 units of lispro were administered at 9:21 p.m. However, there was no documentation in the resident's chart that the blood glucose was rechecked after the additional insulin was given. In an interview, the DON confirmed there was no evidence of reevaluation and verified that, according to the facility's "Abnormal Blood Glucose Procedure" policy, the resident should have been reevaluated and that the evaluation step should have been included in the progress note documentation.
Plan Of Correction
F684 The facility will continue to ensure all residents, including #03, receive treatment in accordance with professional standards of practice and reevaluated for hyperglycemia. To ensure compliance with this standard the following measures have been taken: 1. The director of nursing assessed resident #03, reviewed documentation and orders and found no ill effects immediately 4/16/26. 2. All licensed nurses were re-educated to facility policy "Blood Glucose Monitoring" by the Director of Nursing/designee in April 2026. 3. Audits of like-residents that require blood sugar checks to be completed by the director of nursing/designee two times a week for 4 weeks and then monthly after that to validate correct follow through when there is abnormally high blood glucose result. The Administrator will bring results of these audits to the QAPI committee for ongoing monitoring and further direction.
Failure to Act on Pharmacist Drug Regimen Recommendation for Thyroid Medication
Penalty
Summary
The deficiency involves the facility’s failure to ensure that pharmacy recommendations from the monthly drug regimen review were acted upon and documented for a resident. The resident was admitted with diagnoses including Parkinson’s disease, dementia, and hypothyroidism, and had current physician orders for levothyroxine 150 mcg once daily, buspirone 50 mg twice daily, and losartan 100 mg once daily. A medication regimen review dated 11/25/2025 included a consultant pharmacist recommendation that levothyroxine be administered consistently in the morning on an empty stomach, at least 30–60 minutes before food, per manufacturer instructions. There was no specific physician response in the medical record to this recommendation, and the facility’s policy stated that consulting pharmacist reviews are sent to nursing and addressed with the primary care provider or consulting specialist for review and follow-up. Review of the resident’s medication administration record for April 2026 showed levothyroxine scheduled for 9:00 a.m. On observation, the resident was seen eating breakfast in the dining area at 8:03 a.m., and an LPN reported administering the levothyroxine 150 mcg to the resident while the resident was in the dining area eating breakfast. The DON confirmed there was no evidence in the resident’s medical record explaining why the consultant pharmacist’s recommendation from 11/25/2025 was or was not acted upon. This lack of documented physician review and action on the pharmacist’s identified irregularity constituted noncompliance with the drug regimen review requirements.
Plan Of Correction
F756 The facility will continue to ensure the pharmacy recommendations from the monthly drug regimen review by a licensed pharmacist are acted upon for all residents, including #08. To ensure compliance with this standard the following measures have been taken: 1. Resident #08 was assessed by the registered nurse and med review completed by 4/28/26. After review of resident's drug regime's, it was discovered that resident #8 had 2 separate medication recommendations on the same form, to be reviewed by two separate practitioners, pharmacy has been instructed and agreed to separate meds on individual forms. 2. Licensed nurses re-educated to facility policy "Drug Regimen Review" by Director of nursing/designee in April 2026 and no later than 5/8/26. Licensed nurses are responsible for ensuring the reviews and recommendations are given to the physician for timely review. 3. Review of all other current residents Drug Regimen orders completed by Director of nursing/designee on 4/16/26 to ensure recommendations were followed up on/reviewed by the physician and address concerns if needed. 4. Audit of drug regime recommendations, pharmacy recommendations, and physician follow up to be completed weekly for four weeks by the Director of nursing/designee. Administrator will present results of these audits to the QAPI committee for ongoing monitoring and further direction.
Failure to Use Required Gait Belt During Ambulation Resulting in Resident Fall
Penalty
Summary
The deficiency involves the facility’s failure to ensure that a required gait belt was used while assisting a high fall‑risk resident with ambulation, resulting in a fall with head injury. The resident had multiple diagnoses including metabolic encephalopathy, hypertension, osteoarthritis, muscle weakness, gait and mobility abnormalities, major depressive disorder, anxiety, and visual hallucinations. Admission and subsequent MDS and fall risk assessments documented that the resident was severely cognitively impaired, required moderate to maximal assistance with transfers and ambulation, could not independently come to a standing position, exhibited loss of balance while standing, used an assistive device, and had decreased muscle coordination. The resident had a history of falls prior to admission and was assessed as being at high, later moderate, risk for falls. The resident’s fall care plan identified her as at risk for falls and included interventions such as providing maximum to moderate assistance with transfers and walking short distances, use of a walker and wheelchair, and following the facility’s fall protocol. Therapy notes and care conference documentation indicated that the resident leaned backwards when standing, required contact guard to minimal assistance for bed mobility and transfers, and needed constant verbal cueing for safe sequencing during toilet transfers. The physical therapist confirmed that the resident was to use a gait belt with staff when ambulating, and the DON verified that therapy had assessed the resident as requiring contact guard assistance and a gait belt for ambulation and transfers. On the day of the incident, a CNA was assisting the resident from her recliner to the bathroom using a walker. The CNA walked beside the resident, providing guidance and support, and reported having a hand on the resident while assisting her. As they approached the bathroom door, the CNA reached for the doorknob to open it, and at that moment the resident began to lose her balance and fell backwards to the floor, striking the back of her head. The nurse who responded found the resident on her back at the foot of the bed with her feet near the bathroom, noted a red raised area on the back of the head, and documented that the resident was not wearing a gait belt and that the gait belt was on the dresser. In the facility’s investigative summary and in interviews, the CNA acknowledged that she did not have a gait belt on the resident while ambulating her, despite the resident’s assessed need for hands‑on assistance and gait belt use per facility policy and the resident’s care and therapy plans.
Failure to Implement PD Orders and Monitor Resident Receiving Peritoneal Dialysis
Penalty
Summary
The deficiency involves the facility’s failure to implement pre-admission physician orders for peritoneal dialysis (PD) and to provide ongoing monitoring for a resident with chronic kidney disease (CKD) stage five who required PD. Pre-admission orders dated 11/14/25 specified three daily PD exchanges at 6:00 A.M., 2:00 P.M., and 10:00 P.M., and directed staff to monitor for signs and symptoms of peritonitis, including fever, abdominal pain, and cloudy effluent. These monitoring orders were not entered into the facility’s physician orders. The resident’s care plan noted the need for PD and included general monitoring interventions (labs, signs of bleeding, bacteremia, septic shock, and significant vital sign changes), but did not specifically address the ordered monitoring for peritonitis. Review of PD documentation showed incomplete and inconsistent charting of treatments and resident condition. The paper peritoneal flowsheet had columns for time of PD and condition/comments, including instructions to call the nurse immediately for cloudy fluid, abdominal pain, or fever. However, the first entry on 11/15/26 at 2:00 P.M. only noted that the PD nurse completed the exchange, and the 10:00 P.M. entry that day had no condition/comment documentation. Subsequent days (11/16/25, 11/17/25, and 11/18/25) contained only one condition/comment entry per day rather than for each exchange, and there was no documentation that the 6:00 A.M. PD on 11/18/25 was completed. The PD cycler flowsheet starting 11/19/25 lacked any description of the effluent on multiple days. The PD nurse from the dialysis company stated facility staff were expected to monitor effluent for cloudiness and assess for abdominal pain and fever, and the DON confirmed there was no electronic physician order for peritonitis monitoring or for use of the PD cycler, that the paper charting did not allow for effluent description or symptom documentation for each treatment, and that PD was not documented at one ordered time. The facility’s dialysis policy required ongoing assessment and monitoring for complications before, during, and after treatments, which was not reflected in the documentation for this resident.
Improper Infection Control During Medication Administration
Penalty
Summary
Surveyors identified a deficiency in infection prevention and control related to medication administration for Resident #29. The resident was admitted on 02/28/14 with diagnoses including depression, traumatic brain injury, and anxiety, and had impaired cognition per a quarterly MDS assessment. During an observation on 03/25/26 at 6:58 A.M., RN #281 prepared the resident’s medications by removing an Amoxicillin-Pot Clavulanate tablet from the medication card and pushing it directly into her ungloved hand, then using her fingers to place the pill into a medication cup. The same process was observed for multiple other medications, including Escitalopram Oxalate, Furosemide, Sennosides, Lyrica, and Vitamin D, each being pushed from the card into the RN’s ungloved hand and then transferred by her fingers into the medication cup before administration to Resident #29. In a subsequent interview at 7:27 A.M. the same day, RN #281 confirmed she had placed each medication into her ungloved hands prior to administration and acknowledged that the proper procedure was to push the pills directly from the card into the medication cup. Review of the facility’s “Medication Administration – General guidelines” policy, revised 10/08/25, stated that medications are to be administered in accordance with good nursing principles and practices. This practice failure was cited as a deficiency under Complaint Number 2681777.
Improper Use of Wheelchair as a Physical Restraint
Penalty
Summary
Surveyors identified a deficiency related to the facility’s failure to ensure a resident was free from physical restraints. Resident #7, admitted with diagnoses including Alzheimer’s disease, diabetes mellitus, and anxiety disorder, was documented on a recent MDS as rarely understood and dependent for ADLs except eating. The resident ambulated independently on the unit without an assistive device and had documented verbal and other behaviors occurring one to three days during the look-back period. The care plan noted the resident had potential to be physically aggressive, chase staff, throw objects, and be combative with care, with interventions such as offering choices, administering medications as ordered, and intervening early when agitation occurred. During an observation and interview, Resident #7 was found sitting in a chair with the right arm of the chair positioned against the nursing station and a wheelchair placed directly in front of him. The left arm of the wheelchair was also against the nursing station, and both wheelchair wheels were locked, creating a barrier that appeared to restrain the resident, who was sleeping with his knees touching the locked wheelchair. An LPN confirmed both wheelchair wheels were locked and that the wheelchair should not have been placed in front of the resident. A CNA reported she had placed the wheelchair there in preparation to get the resident up for lunch, was unable to transfer him, and left the wheelchair in that position, acknowledging it was wrong to keep it there. The facility’s physical restraint policy stated that physical restraints are not used except when alternatives are not appropriate or effective for treating a medical symptom and defined physical restraints as any device attached or adjacent to the body that the individual cannot easily remove and that restricts freedom of movement or access to the body.
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