Northwestern Healthcare Center
Inspection history, citations, penalties and survey trends for this long-term care facility in Berea, Ohio.
- Location
- 570 North Rocky River Drive, Berea, Ohio 44017
- CMS Provider Number
- 365811
- Inspections on file
- 31
- Latest survey
- August 27, 2025
- Citations (last 12 mo.)
- 30 (1 serious)
Citation history
Health deficiencies cited at Northwestern Healthcare Center during CMS and state inspections, most recent first.
A resident was not protected from abuse or neglect, including physical, mental, or sexual abuse, physical punishment, or neglect by any individual, resulting in a failure to ensure a safe environment as required by regulations.
A deficiency was cited when a facility area was found to contain accident hazards and lacked adequate supervision to prevent accidents, resulting in unsafe conditions for residents.
A resident with a personal trust fund account did not receive required quarterly statements, leaving them unaware of their account balance despite multiple requests. The Business Office Manager confirmed that no statements had been provided to any residents or guardians, in violation of facility policy.
The facility failed to return personal laundry to residents in a timely manner, affecting several residents and potentially impacting all who relied on the service. Staff and residents reported delays of up to two weeks and missing items. The laundry process involved CNAs collecting laundry, but a large backlog of dirty clothing was observed, with limited equipment contributing to the delay. The issue was acknowledged by the Administrator, and multiple complaints were recorded in the facility's grievance log.
A facility failed to provide an escort for a resident with legal blindness and other medical conditions to an outside appointment, despite previous appointments always having an escort. The resident's medical record indicated the need for an escort, but the order for the specific appointment did not mention it. Interviews confirmed that nurses are responsible for arranging escorts, and it was acknowledged that an escort was not sent on the specified date.
A resident with multiple medical conditions experienced a significant delay in receiving prescribed medications due to the facility's failure to timely transcribe hospital discharge orders. The delay ranged from two to nine days, affecting medications for conditions such as hypertension, diabetes, and seizures. Interviews revealed a lack of documentation and clarity regarding the transcription process, and the facility's policies did not adequately address the issue.
An LPN failed to use a barrier under a glucometer during medication administration for a resident with multiple health conditions, breaching infection control protocols. This oversight was confirmed by the DON and had the potential to affect other residents in the facility.
A long-term care facility failed to maintain a medication error rate below five percent, resulting in a 10.34% error rate. Two residents were affected: one received crushed potassium chloride ER against manufacturer's instructions, and another received levothyroxine with simethicone and after breakfast, contrary to guidelines. Staff were unaware of proper administration protocols, leading to these errors.
A resident at risk for pressure ulcers developed two new Stage III ulcers due to the facility's failure to implement care plan interventions such as turning, repositioning, and conducting weekly skin checks. The resident, dependent on staff for mobility and incontinence care, reported increased pain and inadequate care. Observations and staff interviews confirmed the lack of timely assistance and reluctance to provide necessary care.
The facility failed to implement proper infection control practices during care for two residents requiring enhanced barrier precautions. One resident received incontinence care without the STNA wearing a gown, and another was transferred without staff wearing gowns, despite signs indicating the need for such precautions. Staff admitted to not understanding or following the facility's PPE policies.
A resident with hemiplegia and other conditions did not receive timely incontinence care, resulting in prolonged exposure to urine and feces. Despite the facility's policy to maintain skin integrity and provide dignified care, the resident's call light was left unanswered for hours, and staff were reluctant to assist due to the resident's size and dependency.
A resident with a left knee contusion and fracture blisters was not properly evaluated or treated by the facility. Despite hospital discharge instructions for specific care, the facility did not develop a care plan or conduct required skin assessments. The resident's condition worsened, leading to a hospital transfer, where it was noted that the wound had opened. The facility's lack of documentation and adherence to policies contributed to the deficiency.
The facility failed to ensure safe transportation for a resident with mobility issues, leading to a fall incident during a medical appointment. The resident was transported in an inappropriate wheelchair due to her custom wheelchair being broken, resulting in her sliding out and being lowered to the ground upon return. Another resident, at risk for falls, fell and sustained a head injury due to not wearing non-skid footwear, despite care plan interventions. The facility's policies on transportation and fall prevention were not adequately followed.
A facility failed to provide the correct texture food for a resident on a Dysphagia Advanced diet, resulting in the resident choking on a broccoli salad and subsequently passing away. The resident was edentulous and had a history of dysphagia. The incident highlighted the facility's failure to ensure food items were properly prepared and served at an appropriate size, placing other residents at risk.
Failure to Protect Residents from Abuse and Neglect
Penalty
Summary
The facility failed to protect residents from all forms of abuse, including physical, mental, and sexual abuse, as well as physical punishment and neglect by any individual. This deficiency indicates that at least one resident was not safeguarded from abuse or neglect, as required by regulations. The report identifies a lapse in the facility's responsibility to ensure a safe environment free from abuse and neglect for its residents.
Failure to Maintain Accident-Free Environment and Adequate Supervision
Penalty
Summary
A deficiency was identified due to the failure to ensure that a specific area within the facility was free from accident hazards and that adequate supervision was provided to prevent accidents. The report notes that the environment did not meet safety standards, which resulted in the presence of accident hazards and insufficient oversight to protect residents from potential harm. No additional details regarding the specific hazards, the number of residents affected, or their medical conditions at the time of the deficiency are provided in the report.
Failure to Provide Quarterly Resident Trust Fund Statements
Penalty
Summary
The facility failed to provide quarterly statements to residents with personal trust fund accounts, as required by both facility policy and the signed Resident Fund Management Service Authorization Agreement. Record review showed that a resident who had authorized the facility to manage their funds did not receive any quarterly statements for their account, despite the agreement specifying that statements would be provided at least quarterly. The resident's account had a balance, but the resident reported not receiving statements and being unaware of the account balance, even after making multiple requests for this information. An interview with the Business Office Manager confirmed that no quarterly statements had been distributed to residents or their guardians. The facility's policy requires accurate and timely information to be provided to residents regarding their personal funds, but this was not followed. The deficiency was identified through record review, resident and staff interviews, and policy review, affecting at least one resident directly, with the potential to impact others with similar accounts.
Delayed Laundry Service Affects Residents
Penalty
Summary
The facility failed to complete personal laundry and return it to residents in a timely manner, affecting three residents and potentially impacting all 81 residents who relied on the facility for laundry services. Interviews with staff, including LPNs and CNAs, revealed complaints from residents and families about missing clothes or delayed returns from the laundry. Residents reported waiting up to two weeks for their clothing, with some items never returned. The issue was also raised in a resident council meeting, where multiple residents complained about the poor laundry service. The facility's laundry process involved CNAs collecting laundry and placing it in bins in the soiled room, from where laundry aides would pick it up. However, observations showed a large backlog of dirty personal clothing, with a pile over five feet tall. The facility had limited laundry equipment, with only two medium washers and two dryers, which contributed to the delay. The Administrator acknowledged the problem, stating that a two-week turnaround was unacceptable. The facility's grievance log recorded 16 complaints about missing clothing over a period of several months.
Failure to Provide Escort for Resident's Appointment
Penalty
Summary
The facility failed to arrange for an escort for Resident #80 to an outside appointment on 11/05/24, despite previous appointments always having an escort. Resident #80, who has diagnoses including Parkinson's disease, legal blindness, glaucoma, and schizophrenia, was admitted on an unspecified date and has intact cognition but highly-impaired vision, using a wheelchair for mobility. The medical record and nurse's notes indicated that an escort was needed for appointments on 09/24/24, 09/27/24, and 10/01/24, but the order for 11/05/24 did not mention the need for an escort. Interviews with LPNs and the Director of Nursing confirmed that nurses are responsible for arranging escorts when needed, and it was acknowledged that an escort was not sent with Resident #80 on 11/05/24. This deficiency was investigated under Complaint Number OH00159778.
Medication Transcription Delay Leads to Deficiency
Penalty
Summary
The facility failed to ensure that a resident was free from significant medication errors due to a delay in transcribing and administering the resident's medication orders upon admission. The resident, who had multiple medical diagnoses including paraplegia, fractures, seizures, diabetes, gout, depression, and hypertension, was admitted to the facility but did not receive several of his prescribed medications in a timely manner. The delay in transcription and administration of medications ranged from two to nine days after admission. Upon review, it was found that the hospital discharge orders for the resident included a comprehensive list of medications for various conditions, but these were not transcribed into the facility's electronic medical record on the day of admission. The only medication order transcribed on the admission date was for oxycodone, while other critical medications for conditions such as hypertension, diabetes, and seizures were not administered until several days later. Interviews with facility staff revealed a lack of clarity and documentation regarding the failure to transcribe these orders, and the former Assistant Director of Nursing, who was responsible for transcribing the orders, was no longer available for comment. The facility's policies on medication administration and physician orders did not provide specific guidance on the transcription of admission orders, contributing to the oversight. The Director of Nursing, who was new to the facility, confirmed the deficiency and noted the absence of documentation explaining the delay. The deficiency was investigated under a complaint, highlighting a significant lapse in the facility's medication management process.
Infection Control Breach During Medication Administration
Penalty
Summary
The facility failed to maintain proper infection control practices during medication administration, specifically affecting Resident #39. The resident, who had a history of schizoaffective disorder, bipolar type, type 2 diabetes mellitus, chronic obstructive pulmonary disease, vascular dementia, and repeated falls, was observed during a medication administration session. The LPN responsible for administering medications placed a glucometer directly on the resident's bed without using a barrier, which is against the facility's policy for blood glucose point of care testing. The incident was confirmed through interviews with the LPN and the Director of Nursing (DON). The LPN admitted to forgetting to place a barrier under the glucometer, and the DON confirmed that a barrier should have been used. This oversight in infection control practices had the potential to affect other residents residing on the Back North Hall, as the facility census was 87. The deficiency was identified during an investigation of a separate complaint.
Medication Administration Errors in LTC Facility
Penalty
Summary
The facility failed to maintain a medication error rate of less than five percent, resulting in a calculated error rate of 10.34 percent. This deficiency was identified during an observation of medication pass, staff interviews, and review of medical records, manufacturer's instructions, and facility policy. The errors affected two residents out of four observed during the medication pass. Resident #58, who has a history of cerebral infarction, dementia, and other conditions, was administered crushed potassium chloride ER by an LPN, despite the manufacturer's instructions indicating that the medication should not be crushed, chewed, or sucked. The LPN incorrectly believed the medication could be crushed based on previous advice from a pharmacy. Resident #75, with diagnoses including chronic kidney disease and heart failure, received levothyroxine and simethicone along with other medications after having breakfast, contrary to the manufacturer's instructions that levothyroxine should be administered on an empty stomach and not with simethicone. The medication technician was unaware of these specific administration requirements and administered the medications based on the resident's preference. The facility's policy on medication administration was found to be lacking in adherence to manufacturer's recommendations, contributing to the medication errors.
Failure to Prevent and Treat Pressure Ulcers
Penalty
Summary
The facility failed to provide appropriate pressure ulcer care and prevent new ulcers from developing for Resident #46, who was at risk due to conditions such as hemiparesis, type two diabetes mellitus, and morbid obesity. Despite being dependent on staff for bed mobility and incontinence care, the resident developed two new Stage III pressure ulcers on the right posterior thigh, which were not timely identified or properly treated. The resident reported increased pain and expressed concerns about the lack of timely incontinence care and assistance with turning and repositioning. The care plan for Resident #46 included interventions such as weekly skin checks and assistance with turning and repositioning, but these were not consistently implemented. The resident's medical record did not show evidence of being turned and repositioned, nor were there any weekly skin checks completed from 08/01/24 through 08/22/24. Observations confirmed that the resident was not repositioned during specific times, and interviews with staff revealed a lack of timely care and reluctance to assist the resident due to her size and dependency. The facility's policy required evaluation of each resident's skin condition upon admission and weekly thereafter, along with the implementation of prevention strategies for pressure ulcers. However, the facility did not adhere to these guidelines, as evidenced by the absence of weekly skin checks and the delayed response to the resident's skin condition. The deficiency was further highlighted by the lack of documentation and communication regarding the resident's risk factors and necessary interventions.
Infection Control Deficiencies in Resident Care
Penalty
Summary
The facility failed to implement proper infection control practices during incontinence care and high-risk care activities, affecting two residents and potentially impacting others requiring enhanced barrier precautions. Resident #31, who had severe cognitive impairment and was frequently incontinent, was observed receiving incontinence care from a State Tested Nursing Assistant (STNA) who did not wear a gown as required by the Enhanced Barrier Precautions. The STNA also failed to change gloves after handling soiled items and improperly used washcloths to soak up urine in the resident's heel protectors, which should have been replaced. Resident #12, who required enhanced barrier precautions due to an indwelling catheter, was transferred by two STNAs and an LPN without wearing gowns, despite the presence of a sign indicating the need for such precautions. The LPN admitted to not understanding the sign's meaning, and the STNAs acknowledged their failure to wear gowns during the transfer. This oversight occurred despite the facility's policy requiring PPE during high-contact care activities. The facility's policies on standard and enhanced barrier precautions were not adhered to, as evidenced by the staff's failure to use appropriate PPE during high-contact activities. The Director of Nursing and other staff members recognized the need for further education on enhanced barrier precautions, indicating a gap in staff training and awareness regarding infection control protocols.
Failure to Provide Timely Incontinence Care
Penalty
Summary
The facility failed to provide timely incontinence care for Resident #46, who was affected by hemiplegia, hemiparesis, type two diabetes mellitus, and morbid obesity. The resident's care plan indicated a need for assistance with activities of daily living due to these conditions, including the use of a mechanical lift with two-person support and regular checks for incontinence to prevent skin breakdown. Despite these requirements, the resident was found to have been left in a soaked incontinence brief with urine and feces for an extended period, as observed on the morning of 08/20/24. The resident reported that she often did not receive timely changes, and her call light was left unanswered for several hours during the night. Interviews with staff revealed that the resident's call light was activated, and she was calling for assistance, but her aide did not respond promptly. Another STNA eventually attended to her, finding her bed, gown, and incontinence brief saturated. The STNA reported that many aides were reluctant to care for the resident due to her size and dependency. The facility's policy on routine resident care emphasized the importance of providing care for incontinence with dignity and maintaining skin integrity, which was not adhered to in this instance. This deficiency was investigated under Complaint Numbers OH00156946 and OH00156175.
Failure to Monitor and Treat Knee Injury
Penalty
Summary
The facility failed to ensure timely evaluation, monitoring, and treatment of a resident's left knee contusion with fracture blisters, hematoma, and effusion. The resident was admitted to the facility with a history of a fall resulting in a left knee injury, and the hospital discharge instructions included specific care for the knee, such as no weight bearing, use of a knee immobilizer, and regular skin checks. However, the facility did not develop a care plan for the resident's knee condition, and there was no evidence of skin assessments or documentation regarding the knee's condition during the resident's stay. The resident's medical records revealed a lack of documented skin assessments and treatment orders for the knee condition from the time of admission until a week later. The facility's policy required weekly skin assessments and evaluations upon admission, but these were not conducted. Interviews with facility staff indicated that the resident's dressing was not changed or assessed until a week after admission, and there was no documentation to support claims that the resident refused care or that verbal orders were received to leave the dressing in place. The resident expressed dissatisfaction with the care received and was eventually transferred to the hospital, where it was noted that the knee wound had worsened. The hospital staff expressed concern that the wound was open upon the resident's return, whereas it had not been open previously. The facility's failure to adhere to its own policies and the lack of proper documentation and care planning contributed to the deficiency identified in the report.
Deficiencies in Resident Transportation and Fall Prevention
Penalty
Summary
The facility failed to ensure the safe transfer and transportation of a resident to a medical appointment, resulting in a fall incident. The resident, who had multiple medical conditions including hemiplegia, hemiparesis, and morbid obesity, required a mechanical lift with two-person support for transfers. On the day of the appointment, the resident was transported in an inappropriate wheelchair due to her custom wheelchair being broken. During the return trip, the resident slid out of the wheelchair, and upon arrival at the facility, staff had to lower her to the ground to reposition her, causing distress and embarrassment to the resident. Another resident, who had a history of falls and was at risk for further falls, experienced a fall resulting in a head injury. The resident was found on his knees with a laceration on his head and a pool of blood next to him. The resident was not wearing any footwear at the time of the fall, despite care plan interventions that included ensuring the resident wore non-skid footwear. The fall report lacked documentation of events leading up to the fall, and the resident was transferred to the emergency department for further evaluation. The facility's policies on resident transportation and fall prevention were not adequately followed, contributing to the incidents. The transportation policy required collaboration between social services and nursing for transportation needs, which was not evident in the decision to use an inappropriate wheelchair. Additionally, the fall prevention policy required a thorough investigation and documentation of falls, which was not fully completed in the case of the second resident.
Failure to Provide Correct Texture Food Results in Resident Death
Penalty
Summary
The facility failed to ensure that residents with physician orders for mechanically altered diets were provided the correct texture food items to prevent choking and meet their individual needs. This deficiency resulted in Immediate Jeopardy and actual harm/death when Resident #91, who was ordered a Dysphagia Advanced diet and was edentulous, was served a broccoli salad. The resident was subsequently found unconscious, required cardiopulmonary resuscitation (CPR), and when Emergency Medical Services (EMS) arrived, intubation was initially unsuccessful due to a piece of broccoli being found in the resident's airway. Resident #91 was pronounced deceased as a result of the incident. This affected one resident and had the potential to affect 15 additional residents who were identified as being on a Dysphagia Advanced diet ordered by their physician or other delegated provider. The facility census was 90. Review of the closed medical record for Resident #91 revealed that the resident had diagnoses including memory deficit following cerebral infarction, diabetes, peripheral vascular disease, hypertensive heart disease, hepatitis C, and hyperlipidemia. The resident was severely cognitively impaired and was independent with eating. The resident's care plan included providing a mechanically altered diet due to being edentulous and not wearing dentures. The resident was referred to Speech Therapy (ST) due to exacerbation of decreased safety awareness during oral intake, increased signs and symptoms of dysphagia, and risk for aspiration. The recommended discharge diet order was mechanical soft textures (Dysphagia Advanced). On the day of the incident, Resident #91 was served a meal tray with a broccoli salad cut into bite-size pieces while sitting on the edge of his bed. The broccoli salad was not properly chopped to meet the Dysphagia Advanced diet requirements. The resident was found unconscious and not breathing, slumped over with his face on his dinner tray. CPR was started by facility staff, and EMS was notified. EMS arrived and initially, intubation was unsuccessful until a piece of broccoli was removed from the resident's airway. The resident expired at the facility. The facility's investigation concluded that Resident #91 had choked on the improperly prepared broccoli salad.
Removal Plan
- Physician #17 was notified of Resident #91's death by Registered Nurse (RN) #9.
- Resident #91's daughter was notified of Resident #91's death by Licensed Practical Nurse (LPN) #10.
- LPN/Unit Manager #2 interviewed all residents with Dysphagia Advanced diet orders about their meal consistency for the dinner meal with no additional concerns identified.
- The DON and LPN/Unit Manager #2 initiated a house audit to identify any residents on Dysphagia Advanced diet. In addition, Regional Director of Operations Registered Dietitian (RDORD) #13 and RN #1 audited validation diet orders in the electronic medical record to ensure the meal tickets matched.
- The DON began conducting interviews and obtained witness statements from nursing staff working the time of the event involving Resident #91. All the interviews/witness statements were completed.
- The DON initiated education with facility staff on Dysphagia Advanced diet, the difference between diets/food textures/thickened liquids/obstructed airway care and meal service policy. Education included dietary staff to serve food consistencies as ordered and nursing staff to validate meal being served to resident matches meal ticket prior to serving to residents. The education was completed.
- The DON audited the breakfast meal to ensure Dysphagia Advanced diets were prepared appropriately with no concerns identified.
- The Administrator and DON reviewed all notes from Speech Language Pathologist (SLP) #15 and interviewed SLP #15 with no concerns identified.
- RDORD #13 reviewed Resident #91's meal ticket and dietary profile.
- RDORD #13 audited all diets in the electronic medical record and from the dietary meal tracker master list. Three (Residents #31, #20 and #12) residents' diet orders were fixed due to duplicate orders in the electronic medical record.
- The Administrator gave a verbal warning and suspended Cook #5 pending investigation in an effort to investigate the event prior to Cook #5 returning to work.
- The DON requested the EMS run report from the City Fire Department.
- RN #18 educated all residents/responsible parties with Dysphagia Advanced diets that refused to eat in dining room for potential risks of unsupervised dining. Education record assessment completed, and care plans were updated.
- Dietary Manager (DM) #4 educated Cook #5 on preparing a Dysphagia Advanced diet with a return demonstration completed successfully.
- The DON conducted an audit of all residents in house to identify residents ordered Dysphagia Advanced diet. The DON assessed all residents ordered a Dysphagia Advanced diet with no concerns identified.
- RDORD #19 in collaboration with Regional Speech Therapy Director #20 updated the Dysphagia Advanced diet policy/manual to define the appropriate size of chopped vegetables to be approximately 0.5 inches. There were no food exclusions outside what was listed on the Dysphagia Advanced policy as long as the food items met the size requirement.
- The DON conducted education with facility staff related to the updated Dysphagia Advanced policy/manual with the adjusted size of chopped vegetables to be approximately 0.5 inches via electronic communication. Any staff not able to be educated by that time would be educated prior to the start of their next scheduled shift.
- DM #4 initiated education with all Cooks related to preparing Dysphagia Advanced diet, including a return demonstration. All additional Cooks would be trained prior to the start of their next scheduled shift.
- The Administrator/DON/Designee with support of interdisciplinary team began audits which will be scheduled to be conducted on meal trays at different mealtimes to ensure correct meal consistencies were being served as ordered. Auditing would occur five times a week for two weeks, then three times a week for two weeks. Results of the audits will be reviewed with the Quality Assurance Performance Improvement (QAPI) committee with additional recommendations as warranted.
- Director of Therapy #21 conducted an audit of residents ordered a Dysphagia Advanced diet to identify date of last therapy screen. For any resident not screened in the last 90 days or that have not received speech therapy in the last 90 days, a screen would be completed.
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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