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

Deficiencies in Pressure Ulcer and Nail Care Management

Midtown Center For Health And RehabilitationMemphis, Tennessee Survey Completed on 09-05-2024

Summary

The Quality Assurance Performance Improvement (QAPI) committee at the facility failed to effectively identify and address issues related to pressure ulcers and nail care for several residents. The committee did not implement appropriate actions or monitor the effectiveness of these actions, leading to deficiencies in care. Specifically, the facility's QAPI program did not adequately address the needs of residents with pressure ulcers, as evidenced by the presence of Stage 3 pressure wounds, which should have been identified and treated earlier. The facility's policy required regular assessments and monitoring, but these were not effectively carried out, resulting in the progression of pressure ulcers to more severe stages. The facility's administration and nursing leadership were not fully informed or involved in the management of pressure ulcers. The Administrator did not attend weekly wound meetings and relied on the Director of Nursing (DON) for updates, which led to a lack of awareness about the severity of the pressure wounds. The DON was aware of the presence of Stage 3 pressure wounds but did not ensure that the wound nurses were properly certified to stage these wounds. Additionally, the Medical Director was not informed about the severity of the pressure wounds, indicating a breakdown in communication and oversight within the facility's leadership. The facility also failed to provide adequate nail care for a vulnerable resident, resulting in actual harm when the resident's toenails adhered to the skin, causing pain. This incident highlights the facility's failure to provide care consistent with professional standards of practice. The lack of proper assessments, documentation, and communication contributed to the deficiencies in care, as the facility did not ensure that staff were adequately trained and informed about the residents' needs and the facility's policies.

Removal Plan

  • Identification of residents affected or likely to be affected
  • All residents had an updated Braden Assessment completed
  • Ensure initial skin assessments were completed
  • Facility policies and procedures related to skin care, wound care, and pressure injury prevention were reviewed and revised
  • Provided education to all licensed nurses on the completion of the Braden Score Assessment policy, and completed treatments on all new admissions
  • Daily audit of the Treatment Administration Record to ensure accurate and complete documentation of skin related treatments as ordered
  • Daily audits of skin related treatments including documentation, Braden Assessments, and orders
  • PIP initiated to report on above monitoring and will continue

Penalty

Inspection fine: $183,92416 days payment denial
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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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