Deficiency in Staff Training Program
Summary
The facility failed to implement and maintain an effective training program for its staff, as required by §483.95. This deficiency was identified through a review of facility policy, personnel in-service training records, and staff interviews. Specifically, the facility's policy on 'Training Requirements,' last reviewed on October 20, 2024, mandates the development and maintenance of an effective training program for all staff. However, the facility did not adhere to this policy for four nurse aides, identified as Employees E1, E3, E4, and E5. The training records for these employees were either incomplete or missing, indicating a lack of documented training within the specified timeframe. Employee E1, hired on October 9, 2022, had no documented dates or times of training in their education file. Employee E3, hired on October 11, 2004, had no education file or documentation of completed education from October 11, 2023, through October 11, 2024. Employee E4, hired on October 11, 2005, had a '12-hour in-service packet' in their file, but no dates confirmed the training occurred within the required period. Similarly, Employee E5, hired on November 12, 2013, had a '12-hour in-service packet' without dates confirming the training occurred between November 12, 2023, and November 12, 2024. During an interview, the Nursing Home Administrator confirmed the facility's failure to provide training on infection prevention and control for six of nine staff members.
Plan Of Correction
No residents were affected by this deficiency. All residents have the potential to be affected by this deficiency. VP of Clinical Services, Administrator and Director of Nursing developed a facility Training Plan to include: - Effective communication for direct care staff. - Resident rights and facility responsibilities for caring of residents. - Elements and goals of the facility's QAPI program. - Written standards, policies, and procedures for the facility's infection prevention and control program. - Written standards, policies, and procedures for the facility's compliance and ethics program. - Behavioral health. - Dementia management and care of the cognitively impaired. - Abuse, neglect, and exploitation prevention. - Safety and emergency procedures. All staff will receive education in these areas, provided by the Administrator and Director of Nursing or designee. Completed training will be signed and dated by staff after receiving the training. Moving forward, staff will receive this training upon hire (during orientation) and annually. Human Resources Director will complete a weekly audit for 4 weeks on all new hires to ensure they have received the required trainings in the training plan and will complete a monthly audit that all staff have completed the assigned monthly trainings to ensure continued annual training. Audit results will be reviewed by the Quality Assurance Committee until such a time consistent substantial compliance has been achieved as determined by the committee.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
Lack of PICC Line Training and Competency Validation: The facility failed to maintain an effective staff development program to ensure LPNs had documented education and competency for PICC line care. Two residents had PICC lines for antibiotic therapy, and agency LPNs accessed the lines to provide NS flushes and IV antibiotics. Records showed no PICC-specific training or competency validation for the LPNs, and the RA confirmed no structured PICC line training program existed for agency licensed nurses.
The facility failed to implement and complete its nurse orientation and competency validation process for new LPNs, resulting in two separate medication errors. One LPN, new to LTC and unfamiliar with the facility’s computer system, was left alone on the med cart after only partial observation-based training and without a completed competency checklist, and a resident received another resident’s medications. Another new LPN, also without documented competency sign-offs, was in joint med-pass with an untrained preceptor when a resident requesting pain medication was given sleeping pills after the preceptor pulled the wrong controlled medication and the trainee administered it. Preceptors were selected informally from floor nurses without preceptor training, and leadership interviews confirmed that required competency checklists and the facility’s own med-pass orientation policy were not consistently followed or documented.
The facility did not maintain an effective training program for new and existing staff, as confirmed by record review and interviews with the Administrator and a regional clinical leader. Available in-service records showed training only on QAPI, infection control, resident rights, and abuse, with no documented training on communication, behavioral health, compliance and ethics, or required annual nurse aide education. The Administrator acknowledged that staff had not been trained on these topics, that CNAs had not received their required annual training hours, and that there was no facility policy governing staff training. This deficiency had the potential to affect all 67 residents in the facility.
Inadequate Training and Inaccurate MDS Assessments: The facility failed to ensure staff assisting with the MDS process were adequately trained and competent to complete assigned duties. MDS reviews for several residents contained inaccurate Section GG Functional Abilities data that did not match the clinical record or the level of assistance documented during the look-back period. The RNAC confirmed the errors, and an LPN assisting with data collection stated she had not received sufficient training for her role; the DON and NHA could not provide documentation of training in MDS policies and procedures.
Staff training requirements were not fully completed for 2 employees reviewed, including an Activity Director and a Dietary Manager. Record review showed missing on-hire training in areas such as effective communication, HIV, dementia, infection control, restraint reduction, falls, and behavioral health. HR said she was new to the role and was not aware the required new hire training had not been completed, while the Administrator and DON stated they were responsible for ensuring required orientation and annual training were completed.
Incomplete staff training records showed multiple employees lacked required education in Infection Control, Abuse & Neglect, Fall Prevention, HIV, and Restraint Reduction. Record review found that several leaders and direct care staff, including the ADMIN, DON, ADON, LVN, CNA, and others, had missing training entries, while interviews showed staff believed their training was current and that education oversight had been inconsistent.
Lack of PICC Line Training and Competency Validation
Penalty
Summary
The facility failed to develop, implement, and maintain an effective training program for licensed nursing staff to ensure they had the knowledge and competencies needed to safely manage PICC lines for two residents. The report states that federal requirements call for staff training based on the facility assessment, and Pennsylvania nursing regulations require nurses performing IV therapy, including PICC line care, to complete appropriate education, supervised clinical instruction, and ongoing competency validation. The facility policy on administration of medication or flush through a central venous line also stated that the procedure is complex and requires necessary education, training, and experience. One resident was admitted with a PICC line for antibiotic administration, and physician orders required routine flushing of the line with 10 mL of normal saline. The eMAR showed two agency LPNs repeatedly accessed the PICC line to administer normal saline flushes on multiple occasions in February 2026. Another resident was admitted with a PICC line for antibiotic therapy related to chronic multifocal osteomyelitis, and physician orders required the line to be flushed with 10 mL of normal saline before and after medication administration and during the day and evening shift. The March 2026 eMAR showed an agency LPN accessed the PICC line to administer flushes and IV antibiotics, including Ampicillin Sodium and Ceftriaxone Sodium. Employee personnel records showed no documented education, training, or competency validation related to PICC line management for either agency LPN. The report also states there was no evidence that the facility or contracted agency provided a structured training program, competency validation, or ongoing education specific to PICC line care for licensed nursing staff. During interview, the Regional Administrator of Clinical Operations confirmed the facility could not provide documentation of PICC line-specific training or competency validation and had not developed or implemented a training program specific to PICC line management for agency licensed nurses.
Failure to Implement Effective Nurse Orientation and Competency Validation Leading to Medication Errors
Penalty
Summary
The deficiency involves the facility’s failure to implement an effective nurse training and competency program for new LPN staff, resulting in incomplete orientation and unverified competencies for at least two nurses. The facility maintained a New Trainee Folder and a Licensed Nurse Competency Skills Check-off form intended to cover unit safety, communication, infection control, nursing care, emergency procedures, equipment, medication administration, pain management, resident rights, abuse, dementia care, QAPI, person-centered care, cultural competency, and HIPAA. Human Resources reported that the competency checklist was to be printed and placed in a staffing binder, completed by the preceptor over the first three days, and then signed off by leadership. However, for both reviewed LPNs, these competency checklists were not completed, and there was no documented verification that they had met medication administration or other required competencies before functioning independently. One LPN, on her first day working in the facility and with no prior LTC experience, was involved in a medication error in which a resident received another resident’s medications. This LPN reported that she had only been trained by an RN from 6 AM to 10 AM on how residents took their medications and who had swallowing issues, and that she did not know how to enter orders into the computer system and was unfamiliar with the software. The RN preceptor stated that the LPN had only observed her and had not performed any tasks independently before the RN left, and that she had not checked the LPN off to administer medications alone. The Unit Manager acknowledged that the LPN had no LTC experience, that she did not complete the medication portion of the competency checklist, and that she left the LPN alone on the cart after the LPN stated she felt comfortable, despite not having seen her pass medications. The facility’s Medication Administration policy required that new personnel not administer medications until oriented to the system and that a charge nurse accompany them on medication rounds for a minimum of three days, but this process was not followed or documented for this LPN. Another new LPN, also without a completed competency checklist, was involved in a separate medication error in which a resident requesting pain medication received sleeping pills instead. This LPN reported that she was in training with a preceptor, and that both nurses were pulling medications from the same cart, with the preceptor handling controlled substances. The error occurred when the preceptor punched a sleeping pill from the wrong card, and the trainee LPN administered it, noting that the pills were both small and white and that they were trying to hurry. The LPN stated she did not recall any specific competency check-offs being done beyond a license check. The Unit Manager and ADON both confirmed that preceptors were simply floor nurses who had been at the facility longer, with no formal preceptor training, and that the current training program had only recently started. Employee files for both LPNs lacked completed Licensed Nurse Competency Skills Check-off forms as of the survey date, and leadership interviews showed uncertainty about when competency checklists should be completed and how much training the LPNs had actually received before being allowed to function independently.
Failure to Provide Required Staff Training on Communication and Behavioral Health
Penalty
Summary
The facility failed to ensure staff were trained on effective communication and other required topics, affecting all 67 residents in the building. During review of staff in-service records on 3/24/26 at 11:00 AM, the surveyor and the Administrator (V1) identified that training subjects such as communication, behavioral health, and required annual nursing aide training were missing. At 12:50 PM, the Regional Director of Clinical Services (V7) confirmed he could only locate staff training on QAPI, infection control, resident rights, and abuse, and that he was unable to find any staff training on communication, compliance and ethics, behavioral health, or any required nursing aide training. At 1:00 PM, the Administrator acknowledged that staff had not been trained on communication or behavioral health and that nurse aides had not received their required annual training hours, stating she was not aware these were required. On 4/13/26 at 3:00 PM, the Administrator further stated that the facility did not have a policy related to staff training. The facility’s daily census report dated 3/17/26 documented 67 residents residing in the facility. No additional resident-specific clinical details, medical histories, or conditions at the time of the deficiency were provided in the report.
Inadequate Training and Inaccurate MDS Assessments
Penalty
Summary
The facility failed to ensure staff responsible for participation in the MDS assessment process were adequately trained and competent to perform assigned duties in accordance with federal requirements and professional standards of practice. A review of the facility job description for the MDS Coordinator RN showed the role was responsible for coordinating completion of the resident assessment process and verifying interdisciplinary team members completed, dated, and signed assessments according to federal regulations. The report also noted that while an LPN may contribute to data collection and observation, the comprehensive nursing assessment and certification of the MDS require RN judgment and RNAC sign-off. Review of MDS assessments for six residents showed inaccuracies, with 14 of 15 identified errors involving Section GG Functional Abilities. The facility failed to accurately document the level of assistance residents required during the assessment look-back period, and the clinical record information did not match the MDS submissions. During interviews, the RNAC confirmed the assessments were not accurate, and an LPN assisting with the MDS process stated she was responsible for collecting data and observations for RNAC review but could not explain the discrepancies and reported she had not received sufficient training for her assigned duties. The RNAC stated the LPN had been identified as needing additional training, and the DON and NHA were unable to provide documentation showing the LPN had been trained in facility policies and procedures related to completion of the MDS assessment process.
Staff Training Program Not Completed for New Hires
Penalty
Summary
The facility failed to develop, implement, and maintain an effective training program for 2 of 17 employees reviewed for training requirements: the Activity Director and the Dietary Manager. Record review showed the Activity Director was hired on 04/01/2026 and did not have evidence of on-hire training in effective communication, HIV, dementia, infection control, or restraint reduction. Record review also showed the Dietary Manager was hired on 03/10/2026 and did not have evidence of required training on falls, dementia, infection control, or behavioral health on hire. During interviews, the HR staff member stated she was new to her position and was responsible for completing orientation and paperwork, but was not aware that new hire training had not been completed as required for all employees. The Administrator stated staff were initially trained by logging into a website and watching training videos that included abuse/neglect, blood borne pathogens, HIV, misuse of resident property, resident rights, behavioral health, effective communication, dementia, and fall prevention, and said she was ultimately responsible for ensuring required training was completed during orientation, prior to employment, and annually. The DON stated she was responsible for ensuring nursing staff received required training during orientation, prior to employment, and annually.
Incomplete Staff Training Records
Penalty
Summary
The facility failed to maintain an effective training program for multiple existing staff members after record review showed missing required education in several areas, including Infection Control, Abuse and Neglect, Fall Prevention, HIV, and Restraint Reduction. Personnel files reviewed on 3/23/2026 and 3/24/2026 showed that 14 of 16 staff members had incomplete training records in one or more required topics, including the ADMIN, DON, SW, AD, DM, MS, ADON, LVN A, CMA C, CNA E, CNA B, LA F, HK G, and TA D. The record review identified that the ADMIN had not completed Infection Control, Abuse & Neglect, and HIV training; the DON, SW, AD, DM, MS, ADON, CMA C, HK G, and TA D had not completed HIV training; LVN A had not completed Fall Prevention, HIV, and Restraint Reduction training; CNA B had not completed Infection Control, Fall Prevention, and HIV training; CNA E had not completed Restraint Reduction training; and LA F had not completed HIV and Restraint Reduction training. The facility’s 2025 calendar showed monthly education topics assigned for Infection Control, Resident Abuse Prevention, Restraints, HIV Education, and Fall Prevention. During interviews, LVN A stated she thought her trainings were up to date but said the facility used several different computer-based training sites and it was hard to keep up with them. CMA C stated training was done online and she believed she was up to date, and no staff had told her about any recent training that was due. The CCO stated some training courses had not been completed and were out of compliance, that she had just taken over responsibility for ensuring education was current, and that HIV training had not been recognized as a separate requirement. The DON stated there were three staff responsible for education oversight and that HIV education had been overlooked.
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