F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
J

Failure to Verify Code Status Leads to Unmet Resident Wishes

Westminster TowersOrlando, Florida Survey Completed on 03-04-2025

Summary

Licensed nurses at the facility failed to adhere to the policy and procedure for verifying code status in an emergency situation for a resident who was receiving hospice care. The resident, who had a history of severe cognitive impairment and was on hospice care, had a documented Full Code status, which was not honored when she was found unresponsive. The failure to verify the resident's code status led to the omission of life-saving measures, as the staff assumed she was a Do Not Resuscitate (DNR) due to her hospice status. On the evening of the incident, the resident was found unresponsive in her bed by RN A, who did not verify the resident's code status and failed to initiate cardiopulmonary resuscitation (CPR) as per the resident's wishes. RN A, along with RN C, provided postmortem care without calling a Code Blue or contacting emergency medical services. RN A later acknowledged that she was unaware of the resident's Full Code status and admitted that she did not check the resident's chart, which would have indicated the need for resuscitative measures. The RN Supervisor B, who was informed of the resident's passing, also assumed the resident was a DNR due to her hospice care and did not verify the code status. This assumption was incorrect, as the resident's husband had confirmed her desire to be a Full Code. The facility's failure to ensure staff followed procedures related to honoring an advance directive resulted in Immediate Jeopardy, as it placed all residents receiving hospice care at risk of not having their wishes honored.

Plan Of Correction

Preparation and execution of this plan of correction does not constitute admission or agreement of the facts alleged or conclusion set forth in the statement of deficiencies. The plan of correction is prepared and/or executed solely because it is required by both federal and State laws. 1. Resident #1 expired on Nurse A and Nurse B were suspended immediately. 2. Residents who , in house in the past 3 months were reviewed to ensure all advanced directives were followed. This was completed by and no discrepancies were noted. All Code statuses were followed as ordered. Social services validated all current residents code status and validated the status is correct according to their individual wishes on Nurse A is no longer employed at the facility and the results of the investigation were reported to the board of nursing. Education was provided to Nurse B prior returning to work. 3. Facility completed code blue drills each shift 72 hours post incident and re-educated staff on our code blue policies. Completed by Staff received an electronic communication with immediate education on resident rights, advanced directives, and validating residents code status in their chart prior to calling a code blue on The nursing supervisors were re-educated by the ADON and/or designee by regarding verifying code status on any resident found without vital signs or unresponsive prior to having contact with residents. Licensed nurses have been in serviced by the ADON and/or designee by that residents receiving hospice service does not equate to the resident being a and staff must check all residents code status when they are found unresponsive. This was completed prior to having contact with residents. A new process was put into place where the Facility will add residents full code status order to the MAR to be signed off every shift by the nurse if the patient is on hospice and is a full code to increase visibility to nursing staff on. Written Code blue competency tests were administered to the licensed staff and CNAs and validated by the DON/Designee. Regularly scheduled staff completed by and PRN staff will complete testing prior to having contact with residents. Any new staff members will receive code blue education and competency testing during their orientation days before working the floor alone ongoing. Facility staff were re-educated by the ADON and/or designee of the advance directive processes; neglect and; resident's rights regarding treatment and advance directives; communication of code status; and physician notification of changes. Regularly scheduled staff completed by and PRN staff will complete education prior to having contact with residents. 4. Facility completed ad hoc QAPI on and continued with ad hoc QAPI for the following three weeks on and Code blue drills varying day/shift will continue weekly for one month, followed by three drills a month varying day/shift monthly thereafter to be completed by DON/designee. Random weekly checks will be completed by DON and/or designee for three months to ensure the nurses & CNAs are competent with checking the residents code status when a resident is found unresponsive, regardless of status, ie Hospice, STR, etc. ADON and/or designee will complete Weekly audits of current hospice residents to ensure there is a separate order being signed off stating the resident full code status if appropriate. Audits will be completed weekly for one month, followed by monthly for two months. DON and/or Designee will audit any new hires to ensure a code blue competency test has been satisfactorily completed monthly x3 months. Incident was reviewed during QAPI meeting on and committee agrees with this corrective action. Results of the previously mentioned audits including checking the code status, code blue drills, auditing of hospice resident orders, physician notification of change of condition for full code hospice residents and new hire competencies will be submitted to the Administrator and brought to QAPI for review and evaluation monthly. Audits will continue for a minimum of 3 months or until significant compliance has been met as deemed by the QAPI committee.

Removal Plan

  • Administrator and DON initiated an investigation into discrepancies in resident #1's chart regarding her passing.
  • The facility completed an in-house audit for code status of all residents.
  • Licensed nurses were educated on the facility's policy and procedure for verifying code status prior to initiating or withholding lifesaving procedures including Code Blue drills to validate comprehension.
  • Resident #1's husband was notified regarding discrepancies found and investigation.
  • Law enforcement and elderly affairs were notified out of abundance of caution. An immediate report was filed with the state agency.
  • A record review of resident #1 was completed by the DON.
  • Social Service Director completed an audit of all current residents' code status.
  • RN Supervisor B and RN A received personal training from the DON on checking residents' code status and starting Code Blue procedures. Both nurses were suspended pending investigation.
  • Nursing Supervisors received individual education on checking code status when residents were unresponsive and initiating Code Blue procedures from the DON.
  • A text was sent to all nursing staff containing education regarding if a resident was found unresponsive, it was the responsibility of the nurse to verify code status in the chart and initiate if Full Code.
  • 64 of 81 total licensed nurses received education.
  • 48 out of 81 nurses completed the education.
  • An additional 10 of 81 nurses completed their education.
  • An additional 6 of 81 nurses completed their education.
  • Remaining licensed nurses would receive education prior to working next shift.
  • New hire nurses at the facility would receive the above education during orientation and prior to working an assignment.
  • Mock Code Blue drills were conducted to validate education received was retained.
  • Starting weekly code blue drills to be conducted on varying shifts and days to include all shifts.
  • Random weekly audits to be completed to ensure staff follow facility procedure for verifying residents' code status prior to initiating or withholding.
  • New hire nurses at the facility to participate in a mock code drill during orientation and prior to working an assignment.
  • Ad Hoc Quality Assurance and Performance Improvement (QAPI) held to review the recommendations made from the investigation. The QAPI committee reviewed education in progress and code blue drills.

Penalty

Inspection fine: $34,050
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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 F0678 citations
Failure to Provide Required CPR and Activate EMS for Full Code Resident
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple cardiopulmonary conditions and a documented full code status was found unresponsive without pulse or respirations during the night shift. A CNA notified the RN, who either instructed CNAs to clean and cover the resident or, per her and an LPN’s account, called a code blue and performed CPR with the LPN for about 20 minutes before stopping, without calling 911. The RN believed the resident was on hospice and did not verify code status, then notified the DON, provider, and family instead of EMS. Several hours later, after the DON called the facility and asked whether 911 had been contacted, the RN called 911 and briefly reinitiated CPR shortly before EMS arrived and pronounced the resident deceased, documenting postmortem changes. The facility’s investigation and root cause analysis found that staff failed to follow policy requiring immediate EMS activation and continuous CPR for full code residents until EMS arrival, leading to an Immediate Jeopardy finding.

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 Initiate CPR for Resident With Unknown Code Status
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple chronic conditions and severe cognitive impairment was found unresponsive and not breathing, with no documented code status, POLST, or DNR in the medical record. Nursing staff verified the absence of respirations and pulse but did not initiate CPR or call 911. An LPN reported she proposed starting CPR due to the unknown code status, but an RN declined. Leadership and clinical staff stated in interviews that facility practice and expectations are that, when a code status is unknown or no POLST is on file, the resident is to be treated as full code and CPR should be initiated.

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.
Inaccurate Crash Cart Audits and Missing Emergency Equipment
E
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

The facility failed to maintain accurate and complete crash cart audits for multiple full-code residents. Surveyors, accompanied by the DON, found that daily crash cart checks did not include verification of supply expiration dates, and that an extension cord documented as present on several audit dates was not actually in the cart. Audit logs also conflicted with the cart’s contents by indicating that required items such as eye protection, saline, and clear plastic were present when they were not. These findings were inconsistent with the facility’s policy requiring the crash cart to be checked every 24 hours and after each use, with prompt replacement of equipment and supplies.

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 Initiate CPR and Contact EMS for Full Code Resident Found Unresponsive
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with NASH, diabetes, ascites, obesity, and a documented Full Code status was found unresponsive during early morning med pass, cool to the touch and without measurable vital signs. Her care plan and orders required staff to call 911 and start CPR and life-saving measures if she had no pulse or respirations, but the LPN and RN who assessed her did not initiate CPR, did not contact EMS, and did not verify her code status in the medical record at the time. The resident had not been checked for several hours overnight despite policies requiring at least q2h rounding for changes in condition. There was no documentation that she had been deceased for an extended period, no report of rigor mortis, and no evidence of any change in condition prior to being found unresponsive, resulting in a cited deficiency for failure to follow code status and emergency response policies.

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 Verify and Honor DNR Status Before Initiating CPR
D
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with documented dementia, depression, coronary artery disease, and a clearly established DNR/DNI status on the care plan, orders, and MOLST was found unresponsive in the bathroom without pulse or respirations. An LPN, notified by a CNA, initiated CPR without checking the resident’s code status in the paper chart or EMR. When the RN supervisor arrived and asked about code status, the LPN incorrectly reported the resident as full code, and another RN assisted with chest compressions without verifying code status. Staff experienced confusion and delay locating the MOLST and paper chart, and EMS requested confirmation of the resident’s code status. The MOLST ultimately confirmed DNR/DNI, but CPR had already been performed until EMS consulted their provider and stopped the code, after which the resident was pronounced deceased.

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 Provide Timely and Complete CPR to a Full Code Resident
J
F0678 F678: Provide basic life support, including CPR, prior to the arrival of emergency medical personnel , subject to physician orders and the resident’s advance directives.
Short Summary

A resident with multiple cardiac and renal conditions and a documented Full Code status was found unresponsive and not breathing by a transportation aide, who immediately sought help from an LPN and the assigned RN. The LPN refused to assist, stating it was not their resident, and the RN twice delayed responding despite being told it was an emergency, leading to a reported five- to ten-minute delay before any nurse entered the room. An LPN from another unit eventually initiated chest compressions, and other nurses joined, but no artificial respirations were provided at any time, even though the resident was apneic and an Ambu bag was available. This response did not follow the facility’s CPR policy or AHA guidelines for trained healthcare providers, which require full BLS with both compressions and rescue breaths for a Full Code resident prior to EMS arrival, and the situation was cited as Immediate Jeopardy with actual serious harm and subsequent death.

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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