Failure to Maintain Effective QAPI Program for Sexual Abuse Prevention
Summary
Facility staff failed to maintain an effective Quality Assurance/Performance Improvement (QAPI) program, specifically regarding the Performance Improvement Plan (PIP) for sexual abuse. The QAPI committee did not identify or prioritize problems and opportunities based on performance indicator data, resident and staff input, or other relevant information. Despite multiple allegations of sexual abuse, including a significant incident where one resident sexually abused another in her room, the QAPI team did not implement any changes in procedures or action plans to address these issues. Meeting minutes from several months showed that abuse allegations were discussed, but no procedural changes were made. The facility's PIP documentation for incidents of inappropriate touching and abuse lacked essential elements such as baseline data and identification of barriers, and did not specify which residents were involved. The PIP was marked as ongoing, but no further information or updates were provided to the survey team. The QAPI process, as outlined in the facility's own policy, was not followed, and the committee failed to conduct root cause analyses or implement systematic actions to address the recurring abuse allegations. Interviews with facility leadership confirmed that after months of abuse allegations, the only action taken was to instruct nursing staff to report incidents to the DON and Administrator, with no changes to existing procedures. Staff were required to discuss incidents with leadership before reporting, and no new processes or interventions were introduced following the sexual abuse incident. The facility's approach to handling sexual abuse remained unchanged, limited to notifying authorities and family, without any proactive measures to prevent recurrence or address systemic issues.
Removal Plan
- The QAPI committee reviewed reportable adverse events to determine if any trends were identified, noted that some behaviors were a result of GDRs, and established a communication tool to provide to the behavioral health provider upon entrance and to schedule an exit meeting after the visit to include review of GDRs.
- An ad hoc meeting was held by the Director of Quality and Regulatory to review F-835, F-867, F-740, and F-600, and a performance improvement plan was developed.
- The policy for abuse education was reviewed to include response to sexual abuse and non-pharmacological interventions to manage behaviors.
- Patient interviews were completed by social service director to interview residents to ensure they feel safe and associate interviews to ensure they know process for reporting and can identify abuse to include sexual and physical aggression. Audit will continue until IJ removed.
- QAPI education was provided to include trending RCA to analyze resources needed to decrease or prevent reoccurrence.
- A communication tool was developed and implemented by DON to improve the communication between the behavior provider and center to provide notification of any recommendations timely. The behavior provider will meet with the DON, ADON, and/or nurse supervisor upon entrance and exit to make aware of any new recommendation and to receive report of new adverse events.
- Nurse Managers will update the patient care plan with any non-pharmacological interventions to the patient care plan.
- An audit tool was developed by DON to review patients with inappropriate behaviors to ensure they have non-pharmacological interventions noted on care plan. Audit will continue until IJ removed.
- Education of this process has been provided to the nurse leadership and behavior provider by the DON.
- Any noncompliance will be brought back through QAPI process and addressed through the PDSA framework to identify RCA through the QAPI committee.
- A daily review for oversight will be completed by the Divisional President and/or Senior Director of Clinical Standards to ensure that audits were completed for F600, F867, and F740, ensuring that patients were safe and that staff understood the education on non-pharmacological interventions for inappropriate sexual/physical behavior, and QAPI review completed as indicated on reportable for trends.
- Any noncompliance noted will be addressed through written education by the Divisional President.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
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.
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.
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.
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.
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.
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.
Ineffective QAPI Program Fails to Correct Repeated Medication Storage Deficiencies
Penalty
Summary
The deficiency involves the facility’s failure to demonstrate an effective Quality Assurance and Performance Improvement (QAPI/QAA) program to correct repeated deficiencies related to medication storage (F0761). Surveyors identified that the facility had previously been cited for failing to properly store medications during a recertification and re-licensure survey with an exit date of October 31, 2024. Despite this prior citation, the same deficient practice of improper medication storage was again identified, indicating that the facility did not effectively correct or prevent recurrence of the problem area. Record review showed that the facility held monthly QAA Committee meetings, as evidenced by sign-in sheets dated 02/10/2026, 03/10/2026, and 04/14/2026. Attendees included the Administrator, DON, Medical Director, and other department heads. The facility’s written QAPI policy, implemented on 9/1/2022 and revised on 1/1/2026, stated that it was the facility’s policy to maintain an effective, comprehensive, data-driven QAPI program focusing on outcomes of care and quality of life, and that the QA Committee was to develop and implement appropriate plans of action to correct identified quality deficiencies. During an interview, the Administrator reported that the QAA Committee membership included the Medical Director, nursing home administrator, other department heads, and invited direct care staff, and that they met monthly and as needed to assess ways to make improvements. However, the survey findings indicated that, despite these meetings and the written QAPI policy, the facility’s QAPI/QAA activities did not result in an effective plan of action to correct the repeated deficiency in medication storage. At the time of the survey, there were 94 residents residing in the facility, and the Administrator was informed of concerns related to the repeated deficiencies and the facility’s QAPI activities.
Plan Of Correction
The facility continues to ensure that the quality assurance and improvement program is used to identify and track areas for improvement throughout the facility. IMMEDIATE CORRECTIVE ACTION Ad hoc QA meeting performed on 5/15/26 to address QAPI/QAA concerns and plan of action for current alleged deficiencies including alleged noncompliance with QAPI/QAA Improvement Activities. IDENTIFICATION OF OTHER RESIDENTS HAVING POTENTIAL TO BE AFFECTED All active residents in the facility can potentially be affected by the alleged deficient practice. Administrator/Risk Manager reviewed and audited previous 6 months of QA meetings on 5/18/26 to ensure areas of concern were addressed. SYSTEMATIC CHANGES On 5/19/26, ongoing in-services was conducted by Regional Consultant with facility Quality Assurance Committee about Quality Assurance and Performance improvement Policy with emphasis on implementation, monitoring, and evaluation of performance improvement projects. The Quality Assessment and Assurance Committee will meet monthly and conduct random audit of 1 current performance improvement project monthly to validate reported substantial compliance. MONITORING The Interdisciplinary Team as well as Regional Consultant will attend monthly QAPI meeting to ensure QAA Committee compliance with QAPI process. Regional Consultant will assist with random audit process for 3 months. Any and all findings will be reported during monthly quality assurance meeting until substantial compliance is achieved.
QAPI Failure Related to Resident Smoking Material Supervision
Penalty
Summary
The facility failed to develop, implement, and maintain an effective QAPI program after identifying smoking material concerns for residents, including a resident with dementia, schizophrenia, and continuous oxygen use. Resident #15’s record showed chronic obstructive pulmonary disease requiring oxygen at 2 liters per minute via nasal cannula, impaired cognitive function related to dementia, and a supervised smoker status with instructions to return all smoking materials to the Activities Department after smoking. A quarterly smoking assessment documented that staff were responsible for storing the resident’s lighter and cigarettes, and the resident’s BIMS score was 6, indicating severe cognitive impairment. During observation of the designated smoking patio, Resident #15 was seen sitting in a wheelchair with a plastic bag on her lap. Closer observation showed the bag contained cigarettes and a lighter. Staff B, a CNA and Activities Director, stated the resident required a smoking apron and that they were in the process of removing the cigarettes from her possession. Review of the smoking records for all 27 residents identified as smokers showed care plan interventions requiring return of smoking materials to the Activities Department after re-entering the building after smoking. The Medical Director stated that residents were not permitted to keep cigarettes or lighters and that smoking materials were to be supervised by staff regardless of BIMS score. He also stated that residents with a low BIMS score or those receiving oxygen should not have access to smoking materials. The Facility Administrator stated she had identified smoking concerns when she was hired, including residents smoking whenever they wanted, a nonworking fire alarm, and no fire watch, but she never brought the issue to QAPI and had no active or completed PIPs for identified quality deficiencies. The DON stated the smoking concerns related to residents keeping smoking paraphernalia on their person were planned for the next QAPI meeting.
QAPI/QAA Deficiency Review and Corrective Planning
Penalty
Summary
The facility's QAPI/QAA activities failed to demonstrate an effective plan of action to correct repeated deficiencies in the problem area, as evidenced by repeated deficient practices for F689-Free of Accident and Hazards/Supervision/Devices and F867; QAPI/QAA improvement activities. The facility had 147 residents at the time of survey. Record review of the facility's survey history showed it was cited for F689 and F867 during the recertification and re-licensure survey with an exit date of October 24, 2024. Review of the QAPI Committee Meeting sign-in sheets dated 02/17/2026, 03/17/2026, and 04/21/2026 showed the QAA Committee met monthly and included the Administrator, Medical Director, DON, other department heads, and staff members. During interview, the Administrator stated the members included the Medical Director, nursing home administrator, pharmacist, compliance director, infection preventionist, and some nurses, and that the group met every month and as needed to identify trends and improve quality of care and quality of life. Review of the facility's QAPI Plan policy stated the committee was to assess resident care practices, review facility quality indicators, incident reports, deficiencies cited by AHCA, and resident grievances, and develop plans of action to correct and respond quickly to identified quality deficiencies.
Failure to Sustain QAPI Actions and Documentation for Pharmacist Medication Reviews
Penalty
Summary
The deficiency involves the facility’s failure, as part of its performance improvement activities, to take actions aimed at performance improvement, measure the success of those actions, and track performance to ensure that improvements were realized and sustained, specifically related to F756. Record review and interviews showed that the facility did not maintain documentation in the medical records to demonstrate that a pharmacist reviewed residents’ medications, identified potential irregularities, or provided recommendations to the attending physician for four sampled residents, despite this same issue having been cited in the previous health survey in 2024. During an interview, the DON stated she did not have time to maintain this required documentation. In a separate interview, the Administrator stated he did not have a performance improvement project, though he had QAPI minutes that captured some improvement plans, and he believed the facility had achieved compliance with F756, which had been cited previously, but no documents demonstrating compliance were provided when requested by surveyors.
Failure to Maintain Comprehensive QAPI Program and Performance Improvement Projects
Penalty
Summary
The facility failed to implement and maintain a comprehensive QAPI (Quality Assurance Performance Improvement) program, including performance improvement projects, for at least three of four reviewed quarters, affecting all residents. During a survey in which substandard quality of care was identified and an extended survey was initiated, surveyors determined that the facility did not have evidence of ongoing QAPI activities or current performance improvement projects. In an interview, the Assistant Administrator reported having no information about QAPI prior to January 2026 and stated that the current administrative staff could not locate any documentation of QAPI activities from the previous administrator. She also stated that the facility was expected to meet monthly for Quality Assurance and quarterly for QAPI meetings, but four quarters of records were reviewed and three had no information. The Administrator and other leadership staff were informed of the substandard quality of care findings during end-of-day debriefings on multiple days of the survey. No specific resident medical histories or individual clinical conditions were described in the report; the deficiency was systemic, involving the absence of documented QAPI processes and performance improvement projects intended to monitor and improve care for all residents.
QAPI Committee Failed to Address Staffing and Supervision as Causes of Resident Falls
Penalty
Summary
The facility failed to ensure its Quality Assurance and Performance Improvement (QAPI) committee effectively identified and addressed lack of supervision and inadequate nurse staffing as contributing factors to resident falls. A facility list showed 46 resident falls between 1/1/26 and 3/30/26, of which 34 were unwitnessed, meaning staff were not present to see what happened. The unit manager (UM) assigned as the QA nurse for falls tracking since January 2026 stated she had identified a pattern of falls related to lack of supervision, including in the unwitnessed falls of Resident 1 and Resident 2. She reported that while staffing issues were discussed during monthly QA meetings, staffing had not been identified as contributing to the lack of supervision, was not included as part of the QAPI committee’s work, and was not an action item or performance improvement project, despite her belief that falls, supervision, and staffing should have been thoroughly examined by the QA/QAPI committee. During a joint interview and record review, another UM stated the QA/QAPI committee met for a quarterly meeting and that staffing had been part of QAPI, presenting an undated QAPI Performance Improvement Plan on CNA and LVN staffing stability that described staffing instability, call-offs, workers’ compensation absences, extended hiring processes, and new-hire turnover, with an impact of short staffing, increased workload, and risk to resident care and regulatory compliance. However, the interim DON stated that resident falls, supervision, and staffing should have been addressed and made a focused part of QAPI. The administrator acknowledged that residents’ supervision needs should have been met, that many residents were observed in front of the nurses’ stations while staff were occupied with other tasks, and that he had not realized staffing was such an issue. He confirmed that although staffing was discussed at every QA/QAPI meeting, it was not actively worked on by the QAPI committee, and that while falls were a QA/QAPI action item, supervision and staffing had not been identified as contributing factors, contrary to the facility’s QAPI policy requiring identification of issues, planning and implementation of actions, and monitoring and follow-up.
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