F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
F

Deficiencies in QAPI Program and Notification Compliance

Highpointe On Michigan Health Care FacilityBuffalo, New York Survey Completed on 09-16-2024

Summary

The facility failed to ensure that its Quality Assurance and Performance Improvement (QAPI) program effectively identified, developed, and implemented plans to prevent and protect residents from sexual abuse. Specifically, the program did not address repeated patterns of sexually inappropriate behaviors by a resident. This deficiency was highlighted by an incident where a resident was found in another resident's room with exposed breasts, and the offending resident was observed inappropriately in common areas and other residents' rooms on multiple occasions. Despite these incidents, the QAPI committee did not review or discuss the sexual abuse allegations in a timely manner, as meetings were canceled, and the issue was not added to the agenda when meetings resumed. Additionally, the facility failed to comply with regulations regarding hospital transfer/discharge notifications and bed hold policy notices. The records of two residents who were transferred to the hospital and readmitted multiple times showed no evidence that the required notifications were completed and provided to the residents or their representatives. This oversight was not identified by the facility's QAPI program until it was pointed out during the survey, indicating a systemic failure in the notification process. Interviews with facility staff, including the Director of Nursing and the President of Long-Term Care, revealed that the QAPI committee did not adequately review incidents reported to the Department of Health. The committee's purpose was to assess issues, interventions, and determine if additional actions were needed to ensure resident safety and improve outcomes. However, the failure to address the sexual abuse allegations and the lack of compliance with notification requirements demonstrate significant lapses in the facility's quality assurance processes.

Penalty

Inspection fine: $129,149
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

Below are regulatory guidelines relevant to this citation:

See other F0867 citations
Ineffective QAPI Program Fails to Correct Repeated Medication Storage Deficiencies
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

Surveyors found that the facility’s QAPI/QAA program was ineffective in correcting repeated deficiencies related to improper medication storage (F0761). Despite having a written QAPI policy, holding monthly QAA Committee meetings attended by the administrator, DON, medical director, and other department heads, and reporting that direct care staff were invited to participate, the same medication storage deficiency previously cited during an earlier survey recurred. With 94 residents in care, the facility’s QAPI activities did not produce an effective plan of action to resolve and prevent the ongoing medication storage problem.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Failure Related to Resident Smoking Material Supervision
J
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI Failure Related to Resident Smoking Material Supervision: A resident with dementia, schizophrenia, severe cognitive impairment, and continuous O2 was observed with cigarettes and a lighter in a plastic bag while on the smoking patio. Records showed the resident was supposed to have smoking materials stored by staff, and the Medical Director stated residents were not allowed to keep cigarettes or lighters. The FA stated smoking concerns had been identified earlier, but they were never brought to QAPI and no PIP was in place.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI/QAA Deficiency Review and Corrective Planning
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

QAPI/QAA activities failed to show an effective plan of action to correct repeated deficiencies for F689 and F867. Survey history showed the facility had been cited previously for these tags, and QAA committee records showed monthly meetings with the Administrator, DON, Medical Director, and other department heads. The facility's QAPI policy stated the committee was to review quality indicators, incident reports, cited deficiencies, and grievances and develop plans of action to correct identified quality deficiencies.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Sustain QAPI Actions and Documentation for Pharmacist Medication Reviews
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The facility failed to sustain effective QAPI processes related to pharmacist medication regimen reviews, resulting in repeated noncompliance with F756. Surveyors found that medical records for four residents lacked documentation showing that a pharmacist had reviewed medications, identified potential irregularities, or made recommendations to attending physicians, an issue previously cited. The DON reported she did not have time to maintain this documentation, and the Administrator acknowledged there was no formal performance improvement project in place, though some plans were noted in QAPI minutes, and no supporting documents were produced to demonstrate ongoing compliance.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Maintain Comprehensive QAPI Program and Performance Improvement Projects
F
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The facility lacked a functioning QAPI program and active performance improvement projects for most of the four reviewed quarters, affecting all residents. Surveyors conducting an extended survey for substandard quality of care found no documentation of QAPI activities from the prior administrator and no current performance improvement projects. An assistant administrator reported having no QAPI information before early 2026 and stated that, although the facility was expected to hold monthly Quality Assurance and quarterly QAPI meetings, three of four quarters reviewed contained no QAPI information. Facility leadership, including the administrator, assistant administrator, regional nurse consultant, and DON, were informed of these findings during survey debriefings.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
QAPI Committee Failed to Address Staffing and Supervision as Causes of Resident Falls
D
F0867 F867: Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.
Short Summary

The facility’s QAPI committee did not effectively identify or address lack of supervision and inadequate nurse staffing as contributing factors to multiple resident falls, most of which were unwitnessed. A UM assigned as the QA nurse for falls tracking recognized a pattern of falls related to insufficient supervision, including for two residents, but reported that staffing was only discussed generally and was not treated as a QAPI action item or performance improvement project. Although an undated QAPI plan referenced CNA and LVN staffing instability and its impact on short staffing and resident care, the interim DON and administrator acknowledged that falls, supervision, and staffing were not made a focused part of QAPI, and that supervision needs were not met when many residents were left near nurses’ stations while staff were occupied with other tasks.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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